GRACE INTERNATIONAL, INC. CONFLICT OF INTEREST POLICY

Statement

Grace International believes that effective governance and operation depend on unbiased decision-making by Board of Directors (Board) and staff. Grace International recognizes that directors and staff may have financial and personal interests unrelated to the organization. However, conflicts of interest or the appearance of conflicts of interest may occasionally arise. Whether or not self-dealing results from a conflict of interest, the existence of a conflict or potential conflict must be disclosed to protect the ministry integrity of Grace International and the individual concerned.

In order to avoid impermissible conflict between the personal interests of members of the Board or staff, the Board of Grace International has adopted the following policies regarding conflicts of interest.

Conflict of Interest

A conflict of interest may exist when a Director, employee or member of his or her immediate family has a personal interest in a decision by or on behalf of Grace International. It may also come up when affiliations or other conflicts of loyalties of a Director or employee, with or without

having any personal and financial interest, may lead to, or suggest, or influence changes in a decision made or to be taken by or on behalf of Grace International.

Policy

It is the policy of Grace International that no Director or employee shall derive any personal profit, or gain, directly or indirectly, by reason of his or her directorship or employment by Grace International, except as authorized by the Board.

Each Board member, Director and covered employee shall disclose to the Board any personal interest or possible conflict of interest which he or she may have in any matter pending before the Board or any action taken or to be taken by or on behalf of Grace International.

Each individual covered by this policy agrees that such individual, except as authorized by the Board, will not participate in any decision by or on behalf of Grace International that materially benefits:

(a) such individual,

(b) a member of such individual’s immediate family, or

(c) any organization with which such individual has a formal relationship (regardless as to whether the organization in question is for profit or nonprofit).

Notwithstanding the foregoing, with respect to subsection (c) above, members of the Board shall not be precluded thereby from participating in any general policy-making decision (i.e., a decision that is not being made with reference to such organization) by or on behalf of Grace International, even if such decision will, directly or indirectly, affect such organization.

Disclosure Statement

A conflict of interest disclosure statement in the form (annexed) shall be furnished annually by the Board of Directors to the board members, departmental Directors, officers and covered employees disclosing any anticipated or possible conflict of interest situations.

Covered employees shall be defined as senior employees, office managers and other employees who have a decision-making role in hiring or contracting on behalf of Grace International. The President may determine any other employee who should be a covered employee.

Each new Board member, Director or employee shall be advised of the policy and furnished a disclosure statement upon undertaking the duties of such position.

Implementation and Voting

When any conflict of interest is involved in a matter requiring action by the Board, the interested Director shall call it to the attention of the Board. The Director or board member involved in this conflict of interest situation shall not vote on such matter. In each such case, the interested person shall recuse him/herself when the vote on the matter is called. If a person recuses him/herself he/she shall leave the room during the discussion and during the vote on the issue if requested to do so by a majority vote of the Board or applicable committee.

The minutes of the meeting shall reflect that the conflict of interest was disclosed and whether the interested person was or was not present during the final discussion or vote. When there is a doubt as to whether or not a conflict exists, the matter shall be resolved by a vote of the Board, excluding the potentially interested person.

When any conflict of interest may be involved in a matter involving an employee, such employee shall notify the President of Grace International in writing, which shall constitute notice to the Board, and if the conflicted person is the President, he/she shall notify the Board Chair.

Definition

Members of the immediate family shall mean spouse, descendants, parents, and siblings. If a question arises in this regard, the President or legal counsel should be consulted.

Adopted October 2013

How to Contact Us

If you have questions about this Privacy Policy, please contact Grace International via:

e-mail at grace@graceintl.org with “PRIVACY POLICY” in the subject line; or
postal mail to: Grace International, PO BOX 694137, Miami FL 33269

Ph. 305-231-1117 or 954-394-8929

Visit us at: www.graceintl.org