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Conflict of Interest Policy

Guidelines for identifying and managing conflicts of interest.

Purpose

This policy provides guidelines for identifying, disclosing, and managing conflicts of interest at TTT.

Definition

A conflict of interest occurs when personal interests interfere, or appear to interfere, with the interests of TTT.

Types of Conflicts

Potential conflicts include:

  • Financial interests in competitors, suppliers, or customers
  • Outside employment or business activities
  • Personal relationships affecting business decisions
  • Use of company resources for personal benefit
  • Accepting gifts that could influence decisions

    • Disclosure Requirements

    All employees must:

  • Disclose actual or potential conflicts promptly
  • Update disclosures when circumstances change
  • Seek guidance when uncertain about potential conflicts

    • Management of Conflicts

    When a conflict is identified:

  • The conflict will be assessed
  • Appropriate measures will be implemented
  • The resolution will be documented
  • Ongoing monitoring will occur as needed

    • Consequences

    Failure to disclose or properly manage conflicts may result in disciplinary action.

    Contact

    For questions about conflicts of interest, contact info@transparenttransfers.com.

    Last updated: December 19, 2025

    If you have any questions about this policy, please contact us at info@transparenttransfers.com