Conflict of Interest Policy

1. General

Individuals working with the University (whether remunerated or not) must avoid actual or perceived conflicts of interest that may bring into question the objectivity of decisions which they make or participate in on behalf of Tyndale.

2. Annual Attestations

Governors, Officers and Cabinet members are required annually to attest compliance with this policy.

3. Meeting Declarations

At every Board and Cabinet meeting those Governors, Employees and Volunteers in attendance must declare actual or perceived conflicts of interest with items that are on the agenda. Any declarations are required to be part of the meeting minutes.

4. Ongoing Obligations

Governors, employees and volunteers must, on an ongoing basis, review their outside interests and relationships for actual or perceived conflicts of interest. As soon as they become known, individuals are required to disclose this information to their supervisor and to complete the appropriate prescribed form listed below.

5. Determinations

When actual or perceived conflicts of interest are attested to or declared, a determination must be made about how the actual or perceived conflicts will affect the individual's participation, work or involvement in decision making. This may include but is not limited to the individual recusing themselves from the decision-making process or working relationship. The primary concern must always be the welfare of the University and the advancements of its purposes.

The decision on how the actual or perceived conflict of interest will be handled must be documented either

• through the appropriate prescribed forms listed below or
• become part of the meeting minutes

Scope and Exceptions:

The final determination of whether a conflict of interest exists remains with the University in its sole discretion.

6. Management

The existence of a perceived or actual conflict of interest does not necessarily mean that the conflict is objectionable, or significant enough to be of practical importance, or that it is necessarily averse to the interests of the University or its charitable purposes. However, the existence of any perceived or actual conflict of interest must be disclosed and evaluated before any transaction or action is carried out. If a Governor, Employee, or Volunteer has any doubt, or has questions of interpretation, the individual’s supervisor should be consulted.

Areas where conflict of interest may arise include but are not limited to:

• the acquisition or supply of goods or services
• the acquisition or granting of property and equipment leases
• investments made by Tyndale
• business dealings with donors
• dealings with any other individuals, agencies, organizations, companies, governments or associations that affect the purpose or operation of Tyndale
• where the individual is not dealing at arm's length and:
  • has a significant interest in any business which deals with Tyndale or an Affiliate
  • is engaged in a professional practice which provides services to Tyndale or an Affiliate
    organization
  • is a Governor or an Employee of Tyndale while serving on the board or holding an office in
    any entity that has dealings with Tyndale or an Affiliate
  • provides goods or services to Tyndale or an Affiliate for consideration, while serving as a
    Governor, Officer, Employee or Volunteer of Tyndale or an Affiliate
  • receives any compensation, whether cash, goods or services, from any business, charity
    or individual where such compensation is provided as a direct or indirect result of a
    relationship established through Tyndale or an Affiliate
  • uses Tyndale's or an Affiliate's personnel, equipment, supplies, name, publications, or
    other resources for non-Tyndale purposes outside of established policy
  • receives personal gifts or loans from any third parties having dealings with Tyndale or an
    Affiliate given as a direct or indirect result of the Tyndale relationship
  • has an interest in real estate, securities or other property that Tyndale or an Affiliate has
    an interest in buying or leasing

• Anti-Nepotism Policy HR-10023

• Conflict of Interest Declaration Form (for University personnel with login credentials)
• Conflict of Interest Declaration Form (for University personnel without login credentials - such as Governors or other volunteers)