Conflict of Interest/Confidentiality Policy

ELHM Conflict of Interest/Confidentiality Policy

Updates:
Staff members and Board members will be presented with this policy on an annual basis and given an opportunity to review the above-mentioned disclosure in order to provide any necessary updates. Interim updates are encouraged as necessary.

Abstention:
Any person in a position to affect a decision in which he/she may have a conflict of interest or be a related party must abstain from discussion of that decision and voting on that decision by absenting themselves from the room during such discussion and vote. No ELHM Board member should vote on a question in which he/she has a direct personal or pecuniary interest not common to other members.

Documentation:
Documentation in accordance with ECFA Standard #6 must be followed. Specifics of related party transactions should be reflected in the minutes of the Board meetings. The minutes must reflect that the related party was absent from the room during discussion and voting on the transaction. The audited financial statements of ELHM must disclose any material related party transactions.

Confidentiality:
All deliberations concerning a matter under ELHM review shall be regarded as confidential. Accordingly, disclosure of any information relating to the matter under review to any third party, not a member of ELHM staff, or Board of Directors shall be prohibited.

Authorized Spokespersons for Public Disclosure:
The Chairman of the Board of Directors and the President of ELHM shall be the sole points of contact from requests from the press or the public concerning a specific Compliance Review, and shall be the only ones authorized to speak on behalf of ELHM in connection with a Compliance Review matter.

Public Disclosure:
The Board of Directors, or if authorized, the Executive Committee thereof, shall determine the nature and extent of public disclosure, either by public announcement or response to inquiries, authorized.

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