Conflict of Interest Policy

This Conflict of Interest Policy ensures that all decisions and actions of Global Bright Futures Foundation, Inc. (the "Corporation") are made solely in the best interests of the Corporation and its charitable mission, without improper influence from personal, financial, or business interests. This policy is intended to comply with IRS requirements, state nonprofit law, and expectations of grantors, banks, auditors, and regulators.

This policy applies to all directors, officers, key employees, staff members, contractors in decision-making roles, and volunteers with substantial authority.

A conflict of interest exists when a Covered Person has a direct or indirect personal, financial, or business interest that could compromise—or appear to compromise—their objectivity, independence, or fiduciary duty to the Corporation.

1. Initial and Annual Disclosure: All Covered Persons must complete a written Conflict of Interest Disclosure upon appointment or engagement and annually thereafter.
2. Ongoing Duty to Disclose: Covered Persons must promptly disclose any actual or potential conflict as soon as it arises.
3. Recordkeeping: All disclosures shall be maintained as part of the Corporation's official records.

1. Recusal: A Covered Person with a conflict must recuse themselves from all discussions, deliberations, decisions, and votes related to the matter.
2. Determination: The Board of Directors or an authorized committee shall determine whether a conflict exists.
3. Approval of Related-Party Transactions:
   • All related-party transactions must be reviewed and approved in advance by disinterested members of the Board.
   • Approval must be based on a determination that the transaction is fair, reasonable, and in the best interest of the Corporation.
4. Documentation: All disclosures, recusals, determinations, and approvals must be fully documented in Board or committee minutes.