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Contract or Transaction
A Contract or Transaction is any agreement or relationship involving the sale or purchase of goods/ services, transfer of rights of any kind or the making of loans or grants. Receiving a gift is not a Contract or Transaction.

Responsible Person
This includes (but is not limited to) the following persons:
• Directors
• Principal officers
• Members of a committee with governing body delegated powers
• Those with a direct or indirect financial interest
• Family Member (spouse, domestic partner, parent, child, or spouse of a child, brother, sister, or spouse of a brother or sister) of a Responsible Person
• Employees

Materiality is a concept or convention within auditing and accounting relating to the importance/ significance of the amount of a transaction or discrepancy. It is the threshold above which non-disclosure or incorrect disclosure of the amount may affect the decision-making attitude of users.

Financial Interest
A decision-maker has a financial interest if they have, directly or indirectly, through business,
investment, or family:
• An ownership or investment interest in any entity with which the decision-maker’s organization has a transaction or arrangement,
• A potential ownership or investment interest in any entity with which the decision-maker’s organization is negotiating a transaction or arrangement.

Material Financial Interest

A Material Financial Interest in an entity is a financial interest that a reasonable person would consider to be substantial enough to possibly affect a Responsible Person’s judgment with respect to transactions with the entity.

Conflict of Interest
A Conflict of Interest may occur or be perceived to occur when there is a potential risk that a Person or Organisation may make a decision that is unduly influenced. The decision, financial or otherwise, may benefit the decision-maker personally, may undermine the impartiality of the decision-maker and may not be in the public’s or company’s best interest.

Policy Statement
EDUWEB College is committed to identifying and resolving all conflicts of interest as well as promoting an environment where students and staff are able to study and work effectively.
We believe that possible conflicts of interests should be identified as early as possible and that the college should adopt policies and procedures that mitigate these conflicts at EDUWEB College.

The aims of this policy are:
• To identify the risks which may lead to a possible conflict of interest
• To develop procedures to mitigate the real and perceived risks
• The procedure(s) so developed will allow a transaction to be treated as valid even though a responsible person may or may not have a conflict of interest with respect to the transaction.
• To ensure that staff has a full understanding of the policy and procedures and how to apply them in practice
• To observe all conflicts of interest principles when providing services.
• To promoting individual responsibility for integrity and impartiality
• To support transparency and accountability

Members of the EDUWEB College Community

All members of the EDUWEB College community have a responsibility to work individually and collectively to achieve a work and study environment in which conflicts of interest are identified and effectively dealt with.
All employees are responsible for:
• Being aware of their obligations with regard to possible conflicts of interest
• Continually assessing their private interests and company duties with regard to possible conflicts of interest
• Reporting possible conflicts of interest to their manager, Committee or Body

Responsible Persons
• Responsible Persons must support their staff by:
• Being aware of the risks inherent to the work of their staff
• Ensure their staff’s awareness of their obligations under the policy and procedures
• Identifying the training needs of their staff
• Recording reports of possible conflicts of interest by their staff members
• Taking appropriate disciplinary action in relation to their staff members who fail to meet their obligations

Each Responsible Person must review and sign a copy of the policy every three (3) years or whenever there are amendments. This is to ensure that they have:
• Received a copy of the Conflicts of Interest policy
• Read and understood the policy
• Agreed to comply with the policy

Procedures for Addressing a Conflict of Interest
All staff members are expected to:
• Act with honesty and integrity and in good faith
• Act fairly and impartially
• Act in a financially responsible manner
• Use information appropriately
• Use their position appropriately
• Exercise due care, diligence and skills

Duty to Disclose
For any actual or perceived conflict of interest, a responsible person must disclose the existence of any financial interest to the relevant body or committee considering the proposed transaction or contract.
A Responsible person must disclose to the relevant body or committee all material facts relating to a contract or transaction is they have or may be perceived to have a possible conflict of interest,
The relevant body or committee must consider all material facts so disclosed and determine if a conflict of interest exists.

Determining Whether a Conflict of Interest Exists
A financial interest may not be a conflict of interest. A conflict of interest would exist only if the relevant body or committee determines that a conflict of interest exists.
If a conflict of interest is determined to exist then the relevant person must not participate in discussions or vote on the transaction
The chairperson of the relevant body or committee may temporarily appoint a disinterested person only if it is necessary to maintain a quorum
The relevant body or committee will consider the proposed contract or transaction to determine if the company can, with reasonable effort, obtain a more advantageous transaction or contract
that would not give rise to a conflict of interest.
The relevant body or committee shall vote to decide if the contract or transaction will be entered into for the benefit of the company.

Possible violations of the Conflicts of Interest Policy
If a body or committee has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, the member will be informed of this and given an opportunity to explain the alleged failure to disclose.
Based on the member’s explanation and any warranted investigations, the body or committee will determine if a breach of the policy has occurred and the appropriate disciplinary and
corrective action.

Steps already taken to reduce Conflicts of Interest:

A learner can register and start a course at any time and from any location on the internet. The learner can choose their username to register and log into the system. This shields the learner’s personal identification whilst they are pursuing the course(s).

The lecturer and other learners in a course only see the username (not the name) of the other learners. Communication amongst learners and lecturers are done by messaging the usernames.

Learner management:
Lecturers only see usernames when managing learners in their course including the assigning of grades. The lecturer can set a quiz for each lesson. Some questions can be auto graded by the system and suggested answers shown.

Separation of Duties:
After a learner completes a course, the mark sheets and grades for their assignments, assessments and examinations are submitted by the lecturer to the Accounts department for verification and record keeping. Certificates are physically printed by the Accounts department only after they verify that there are no outstanding payments. Printed certificates are sent directly to the learner via courier.

Human Resources:
An external recruitment firm will be used to select some candidates when interviews are being held. Persons wishing to join the college can also apply directly through our website. Job description have been developed for every position on the Organisational Chart. Candidates will be matched against these job descriptions.

A separate policy has been developed which gives detailed guidelines for procurement.

Effective January 1st, 2019