INTRODUCTION 

 This policy applies to the following members of The Western Canadian District of the Christian and Missionary Alliance (“WCD”): District Executive Committee (DEXCOM); and 

Members of committees of DEXCOM(“Committee Members”) appointed by DEXCOM. This document sets out the WCD’s policy on conflict of interest and the processes for addressing conflicts (see Appendix A). 

POLICY OF DEXCOM 

Conflict of Interest 

DEXCOM Members and Committee Members may not be placed or place themselves in situations where they have a conflict of interest, i.e., they may not participate in decisions and processes where they have an obligation to act in the best interests of WCD, but have a personal interest that will interfere with that obligation. 

When DEXCOM Members and Committee Members find themselves in a conflict of interest, they are to disclose it to DEXCOM Chair (“Chair”) who will work to find a solution that eliminates or manages the conflict. Examples of conflict of interest include, but are not limited to: 

Personal relationships 

DEXCOM Members and Committee Members may not participate in DEXCOM decisions or activities that will affect or directly benefit them or a closely associated person [1]. For example: 

They may not evaluate compensation of an employee who is a closely associated person; 

They may not assess a project if the outcome of the assessment could enhance their personal interests or a closely associated person’s interest; 

They may not direct employees to work for a business that a DEXCOM Member or a closely associated person owns or has a financial interest in; 

They may not participate in a decision to bind WCD to a contract that may advance their personal interests or a closely associated person’s interest; 

They may not participate in a decision to hire or contract a closely associated person. 

 Financial Interests 

DEXCOM Members and Committee Members are to disclose to DEXCOM chair a financial interest in any entity that does business with WCD. 

Outside employment 

DEXCOM Members and Committee Members are to disclose to the DEXCOM Chair any work they do for an outside entity that may give the entity a preferred position with respect to grants or contracts with WCD. 

Reporting Conflicts of Interests 

All DEXCOM Members and Committee Members are to report conflicts or perceived conflicts of interest to the DEXCOM Chair. Any other DEXCOM Member or Committee Member who has reason to believe that an undisclosed conflict of interest exists is required to report it to the DEXCOM Chair. 

 Confidentiality of Disclosures and Reports 

The WCD handles all disclosures of conflicts of interest with discretion. In some circumstances, however, the law or a policy may make it necessary to give people internal and/or external to the WCD access to information about a disclosure and the terms and conditions set by WCD. The WCD will make reasonable efforts to advise the DEXCOM Member or Committee Member inwriting before giving information about a disclosure to anyone external to WCD. 

 Appeals 

DEXCOM Members and Committee Members may appeal the WCD or decisions regarding a conflict of interest to the Chair. The appeal must be registered within thirty days of receiving written notice of the decision. 

Declaration/Disclosure Forms 

DEXCOM Members and Committee Members are asked to complete WCD’s Conflict of Interest Declaration annually. 

Consequences for Noncompliance 

The existence or the perception of a conflict of interest does not imply wrongdoing on anyone’s part. It means 

the conflict must be disclosed and eliminated or managed. 

Failure to disclose a conflict of interest or otherwise comply with this policy could result in a request for resignation from DEXCOM or a DEXCOM Committee or suspension for so long as the DEXCOM may determine. 

“closely associated person” shall be defined as spouse, child or parent of the DEXCOM Member or Committee Member and any other relative by blood or marriage. 

“have a financial interest in” or “affiliated with” shall be understood to include: 

serving as an officer, employee, member, trustee of the entity, 

owning more than 5% of the voting stock or the equity or capital interest of the entity, or 

being a debtor or creditor, or an employee, officer, trustee of a debtor or creditor of the entity. 

In somecases,beinginthistypeofsituationmayprecludeapotentialDEXCOMMemberoraCommitteeMember from sitting on DEXCOM or Committee altogether. 

CONFLICT OFINTEREST POLICY - APPENDIX “A” 

PROCESSES 

Disclosing a Conflict of Interest 

The DEXCOM Member or Committee Member discloses the potential, real, or perceived conflict in writing to the Chair and removes himself or herself from the activity. (A DEXCOM Member or a Committee Member may disclose a conflict in a meeting and excuse himself or herself from the portion of the meeting that creates the conflict. The Chair or Committee Chair will consult the other DEXCOM Members and Committee Members, determine if a conflict exists, and decide how to resolve the situation. The recording secretary will capture the disclosure and DEXCOM or Committee’s decision in the minutes of the meeting.) 

The Chair investigates the situation and decides if a conflict exists, if the activity will be permitted to continue, and if so, under what conditions. 

The Chair will consult with the DEXCOM Member or Committee Member and other people as necessary and will consider the following factors when making a decision: 

If it is possible to arrange an alternative that does not involve a conflict, 

If the activity/conflict is allowed to continue, the possible harm that could come to WCD and employees, or others acting on behalf of the WCD, 

If the activity/conflict is allowed to continue, the possible consequences to the WCD, its reputation, and future activities, 

The rights and interests of the DEXCOM Member or Committee Member, and Guidelines set out in all relevant WCD policies. 

The Chair communicates his or her decision in writing to the DEXCOM Member or Committee Member. 

The DEXCOM Member or Committee Member accepts or appeals the decision. 

Appealing a Conflict of Interest Decision 

Within 30 days of receiving the decision regarding a conflict of interest the DEXCOM Member or Committee Member submits a written statement outlining the grounds for the appeal and any relevant documentation to the Chair. 

The Chair’s third party independent designate investigates the situation and makes a decision on the appeal. The Chair’s designate may ask the DEXCOM Member or Committee Member for more information and may consult with others as required to make the decision. 

The decision of the Chair’s designate is final and binding on the DEXCOM Member or Committee Member.