Introduction and Purpose
Upinion is committed to upholding the highest standards of integrity, transparency, and ethical conduct in all aspects of its operations. As a social enterprise, the company places great importance on avoiding conflicts of interest to ensure that its decisions and actions align with its mission and the best interests of its stakeholders.
The purpose of this Conflict of Interest Policy (the “Policy”) is to provide guidance to all directors, officers, employees, consultants, partners, clients and volunteers of Upinion on how to recognize and handle conflicts of interest.
This document can be found online on: https://upinion.com/resources/policies/conflict-of-interest-policy/.
Definitions
- Conflict of Interest: A conflict of interest arises when an individual’s personal or financial interests conflict with the best interests of Upinion. This includes situations where there is a direct or indirect financial interest in a matter involving the company, as well as situations where personal relationships may influence decision-making.
- Interested Person: An Interested Person refers to any individual who has a duty of loyalty towards Upinion, including directors, officers, employees, consultants, and volunteers.
Duty of Loyalty and Disclosure
- Duty of Loyalty: All Interested Persons have a duty of loyalty to Upinion and must act in the best interests of the company. They should refrain from using their position for personal gain and avoid conflicts between their personal or financial interests and the interests of Upinion.
- Disclosure of Conflicts: It is the responsibility of all Interested Persons to promptly disclose any conflicts of interest or potential conflicts of interest to Upinion. This includes disclosing any financial interests, personal relationships, or other circumstances that may influence their ability to act in the best interests of the company.
Procedures for Disclosure and Resolution
- Duty to Self-Disclose: Interested Persons must make an appropriate disclosure of any conflicts or potential conflicts of interest as soon as they become aware of them. This includes disclosing all material facts related to the conflict or potential conflict. The person needs to reach out to the CEO via Slack or mail. Alternatively the person can use the Incident Report Form.
- Evaluation of Conflicts: Upon disclosure, Upinion will evaluate the disclosed conflict or potential conflict of interest to determine its materiality and impact on the company’s operations. The evaluation will consider the proximity of the Interested Person to the decision-making process, the financial or personal interest involved, and whether it could affect the best interests of Upinion.
- Voting and Decision-Making: In cases where an actual conflict of interest is determined to exist, the Interested Person involved should refrain from voting or participating in any decision-making process related to the conflict. The decision-making body, such as the Executive Board, will evaluate the conflict and make decisions in the best interests of Upinion.
- Alternatives and Mitigation: Upinion will strive to find alternatives or mitigation measures to address conflicts of interest and ensure the best interests of the company are protected. This may involve seeking advice from independent experts, revisiting the decision-making process, or considering alternative options.
Record-Keeping and Compliance
- Documentation: Upinion will maintain accurate and complete records of all disclosures, evaluations, and decisions related to conflicts of interest. These records will be kept confidential and securely stored on Google Drive.
- Compliance Monitoring: Upinion will regularly monitor compliance with this Policy and ensure that all Interested Persons are aware of their obligations to disclose conflicts of interest.
- Training and Awareness: Upinion will provide training and educational programs to all Interested Persons to raise awareness about conflicts of interest and the importance of adhering to this Policy.
- Violations of the Policy: Any violations of this Policy will be taken seriously and may result in disciplinary action, up to and including termination of employment or engagement with Upinion.
Review and Amendments
- This Policy will be periodically reviewed and updated by Upinion to ensure its effectiveness and compliance with applicable laws and regulations.
- Amendments to the Policy may be made by the Executive Board.
Adoption
By adhering to this Conflict of Interest Policy, Upinion aims to maintain the highest standards of integrity and protect the best interests of the company and its stakeholders. Therefore we ask all directors, officers, employees, consultants, and volunteers of Upinion to approve this document and follow the above guidelines.