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POLICY: CONFLICT OF INTEREST                                                              Policy #50
              CREATION DATE: September 2015
              REVISION DATE:

              EFFECTIVE DATE: January 2016
              ***********************************************************************************

              A conflict of interest with regard to Jack & Jill Children’s Center is defined as an activity or
              interest  which  is  inconsistent  with  or  opposed  to  the  legitimate  best  interest  of  Jack  &  Jill
              Children’s Center.   It is the policy of Jack & Jill Children’s Center that all directors, officers,
              Policy  Council  members,  contractors/consultants,  and  team  members  will  avoid  personal
              transactions or situations in which their personal interest will or will appear to conflict with those
              of Jack & Jill Children’s Center.  For the purpose of this policy a member of an immediate family
              shall include any of the following persons:

                      Husband              Mother-in-Law                Niece
                      Wife                 Father-in-Law                Nephew
                      Mother               Son-in-Law                   Brother-in-Law
                      Father               Daughter-in-Law              Sister-in-Law
                      Sister               Step-Child                   Grandmother
                      Brother              Step-Parent                  Grandfather
                      Daughter             Aunt                         Granddaughter
                      Son                  Uncle                        Grandson
                      Any person residing in the team member's immediate household

              A  conflict  of  interest  occurs  whenever  a  team  member  permits  the  prospect  of  direct  or
              indirect personal gain to influence her or his judgment or action when acting on behalf of Jack
              & Jill Children’s Center. The following examples are representative but not inclusive of potential
              conflicts of interest:

                      a.  No team member shall do business with a member of her or his immediate family on
                         behalf  of  Jack  &  Jill  Children’s  Center,  unless  the  circumstances  of  the  proposed
                         relationship have been clearly reviewed by the Chief Executive Officer and has been
                         deemed to have no potential or inherent conflict of interest qualities.

                      b.  All team members must deal with suppliers, contractors, customers, and all other
                         persons doing business with Jack & Jill Children’s Center in the best interest of Jack
                         & Jill Children’s Center without favor or preference based on personal consideration.

                      c.  No team member shall misuse privileged information or reveal confidential data to
                         outsiders for the purpose of personal gain or for any reason other than Center
                         purposes.

                      d.  No team member shall deal with Jack & Jill Children’s Center or with one of Jack & Jill
                         Children’s Center clients or suppliers as a representative of another firm or for her
                         or his own account.

                      e.  No  team  member  shall  participate  in  the  selection,  award  or  administration  of  a
                         contract where to her or his knowledge she or he or her or his immediate family has
                         a financial interest.

                      f.  No team member shall solicit, accept or offer gratuities, favors, or anything of
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