Avoiding Conflicts of Interest and Protecting T4HIM’s Assets

A conflict of interest occurs when an employees private interests interfere in any way with the interests of T4HIM as a whole. An appearance of impropriety involving an actual or potential conflict of interest should also be avoided. T4HIMs employees are expected to conduct business in an honest and ethical manner, which includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. Before making any investment, accepting any position or benefits, participating in any transaction or business arrangement or otherwise acting in a manner that creates or appears to create a conflict of interest, full disclosure must be made to and written approval obtained from Senior Management (unless otherwise specified below)

Avoiding conflicts of interests also means that an employee may not:

1. Accept a Business Entertainment (as defined below) if such Business Entertainment is worth more than a nominal amount (as defined below), or unless such Business Entertainment is specifically approved in advance by Senior Management after full disclosure. In the event of any inadvertent or unintentional acceptance of a Business Entertainment in violation of this directive, the employee shall have seven (7) days within which to make full disclosure of the circumstances to Senior Management. A “Business Entertainment” is a meal or entertainment provided for by anyone who does business with or seeks to do business with T4HIM or who is a resident of a T4HIM managed property. In the case of a Business Entertainment or a Gift (as defined below), “nominal” generally means less than $25, and such a Business Entertainment or Gift is something ordinarily used in establishing or maintaining business relationships or in a sales promotion, such as ordinary business meals and reasonable entertainment, services or gifts consistent with local social and business customs.

2. Accept a Gift (as defined below) if such Gift is worth more than a nominal amount (as defined above), or unless such Gift is specifically approved in advance by Senior Management after full disclosure. In the event of any inadvertent or unintentional acceptance of a Gift in violation of this directive, the employee shall have seven (7) days within which to make full disclosure of the circumstances to Senior Management. A “Gift” is a service or gift from anyone who does business with or seeks to do business with T4HIM or who is a resident of a T4HIM managed property.

3. Accept any fee, commission, payment or gratuity, from anyone who does business with or seeks to do business with T4HIM or is a resident of a T4HIM managed property.

4. Make or offer, directly or indirectly, anything of value (such as a bribe or kickback or a lavish gift which could be viewed as a bribe or kickback). A business courtesy, such as a gift, contribution or entertainment, should never be offered under circumstances that might create the appearance of impropriety.

5. Engage in any activity that would conflict with or detract from the employees ability to carry out their assigned duties and responsibilities.

6. Do business with, or authorize a T4HIM property to do business with, any vendor who employs a relative of an employee without notifying and receiving prior written approval from Senior Management.

7. Have any material personal interest in any vendor who does business with any T4HIM property.

8. Participate in any outside business activity with a person that the employee has met through their employment at T4HIM without notifying and receiving prior written approval from Senior Management.

9. Use or take any property that belongs to T4HIM or one of its properties without proper authorization.

10. Make any political contributions for, on behalf of, or in the name of, T4HIM, or seek direct or indirect reimbursement for contributions made in any form. T4HIM encourages all employees to exercise their individual rights of citizenship by voting, by making personal political contributions if they wish to do so with their own funds and by being otherwise politically active, in support of candidates or parties of the employees own personal selection. Such political activity by employees must be performed strictly in their individual and private capacity and not on behalf of T4HIM or with the use of T4HIM resources.