Conflict of Interest and Code of Ethics Policy

Company Name: Toronto Montessori School (TMS) Policy Title: Conflict of Interest Policy Policy Owner: Vince Haines, CAO Approver: Andrew Cross, Head of School Version: 1 Last Review: September 30th 2021

Policy Statement

It is the policy of TMS (TMS) to follow the highest ethical standards in the conduct of its own affairs in the interest of the TMS Students, Parents, the Board of Trustees, Staff and Faculty members. The faculty, staff, administrators and Board at TMS recognize a responsibility to ensure that they conduct themselves in an unbiased manner and serve the goals of the School (the “School”). It is thus the responsibility of TMS, its employees and its Board to guard against conflicts of interest, which might compromise the integrity and objectivity of the school community (“Conflict of Interest”). By adopting this Conflict of Interest Policy and Code of Ethics (“Conflict of Interest Policy”), TMS also (i) demonstrates its commitment to ethical principles that guide the School’s daily functions and purpose and (ii) establishes a mechanism to safeguard the School, employees, and Board integrity and objectivity so that school interactions can optimally benefit society.

Purpose

This Conflict of Interest Policy has been prepared to outline the TMS approach to identifying and evaluating potential conflicts and assisting its employees in addressing conflict of interest issues. Also, this will provide employees, trustees and committee members with necessary guidelines to avoid conflicts of interest or the appearance of a conflict of interest between their financial or other personal interests and the goals and policies of the School.

Application

This policy is applicable to: 1. All members of the TMS Board 2. All members of TMS Committees 3. Parent community 4. All members of TMS Faculty and Staff

Definitions

Family. For purposes of this policy, family is defined as a Board’s, Committee member’s or employee’s spouse and minor children. Financial Interest. Any relationship, including a consulting relationship, entered into by an employee or his or her family, other than employment by the School, which could result in a financial gain for the employee or his or her family. Conflicts of Interest: Many employees, Board or Committee members either occupy positions that allow them to influence School decisions, or they have been entrusted with the authority to make decisions for the School. A Conflict of Interest exists if one’s position or authority may be used to influence or make decisions that lead to any form of financial or personal gain for the individual or for his or her family.

Principles

1. General Principles for Faculty and Staff. As a natural consequence of personal commitment to academic principles, TMS employees must ensure the integrity of their academic pursuits by taking steps to avoid conflict of interest, or even the appearance of conflict of interest. Because the complexity and diversity of personal relationships is extensive, and the perception of conflict of interest may vary from one individual to another, the most effective means to address conflict of interest is to establish a system under which employees disclose and obtain an evaluation of potential conflict. Thus, TMS employees shall disclose to the Head of School any potential conflict of interest that is or may be material. In the case of the Head of School, he/she will disclose any potential conflict of interest to the Chair of the TMS Board.

2. Identification of Conflict of Interest for Faculty and Staff. Identifying conflict of interest is not a simple task. A TMS employee has a conflict of interest if his or her judgment and discretion in other matters affecting the School are or may be influenced by considerations either of personal gain or financial benefit. The following is a partial list of activities or actions that merit case-by-case examination to determine whether such an activity creates a material conflict of interest that should either be managed appropriately or eliminated. a. Consulting or tutoring activities. At no times may a TMS teacher tutor his or her own student for additional remuneration. b. The purchase of goods or services for the School from businesses in which the employee, or his or her family, has a financial interest, or as a result of such purchase, may directly benefit. c. Receipt of gifts, gratuities, loans, or special favours (including trips or speaker's fees) from research sponsors or vendors. d. Holding of an ownership interest by the employee or the employee's family in any real or personal property leased or purchased by the School. e. Holding of an equity, royalty, or debt instrument interest by the employee or the employee's family in an entity providing to the School financial support, including research or other support or services, when such support will benefit the employee or persons supervised, directly or indirectly, by the employee. f. Receipt, directly to the employee from non-School sources, of cash, services, or equipment provided in support of the employee's School activities. g. Some memberships on Boards, committees, advisory groups (or similar bodies) of governmental, for-profit or not-for-profit entities. h. Use of information received as a School employee for personal purposes. 3. General Principles for Board and Committee Members. As a natural consequence of personal commitment to the principles of good governance, TMS trustees and committee members must ensure the integrity of their volunteer pursuits by taking steps to avoid a conflict of interest, or even the appearance of a conflict of interest. Because the complexity and diversity of personal relationships is extensive, and the perception of conflict of interest may vary from one individual to another, the most effective means to address conflict of interest is to establish a system under which trustees and committee members disclose and obtain an evaluation of potential conflict. Thus, TMS Trustees and committee members shall disclose to the Chair of their committee or the Chair of the TMS Board any potential conflict of interest.

4. Identification of Conflict of Interest for Board and Committee Members. Identifying conflict of interest is not a simple task. A TMS Board or committee member has a conflict of interest if his or her judgment and discretion in other matters affecting the School are or may be influenced by considerations either of personal gain or financial benefit. The following is a partial list of activities or actions that merit case-by-case examination to determine whether such an activity creates a material conflict of interest that should either be managed appropriately or eliminated. a. Consulting activities. b. The purchase of goods or services for the School from businesses in which the trustee or committee member, or his/her family, has a financial interest, or as a result of such purchase, may directly benefit. c. Receipt of gifts, gratuities, loans, or special favours (including trips or speaker's fees) from research sponsors or vendors to the School. d. Holding of an ownership interest by the trustee or committee member or his/her family in any real or personal property leased or purchased by the School. e. Holding of an equity, royalty, or debt instrument interest by the trustee, committee member or his/her family in an entity providing to the School financial support, including research or other support or services, when such support will benefit the trustee, committee member or persons supervised, directly or indirectly, by the trustee or committee member. f. Receipt, directly to the trustee or committee member from non-School sources, of cash, services, or equipment provided in support of the trustee’s or committee member’s School activities. g. Some memberships on Boards, committees, advisory groups (or similar bodies) of governmental, for-profit or not-for-profit entities. h. Use of information received as a School trustee or committee member for personal purposes. i. Trustees and committee members are not entitled to remuneration and no trustee or committee member shall directly or indirectly receive any payment. This will include professional fees, salary, payment for goods received by the School, etc. A trustee or committee member may be reimbursed for reasonable expenses incurred by him or her in the performance of his or her duties. j. Trustees and committee members must refrain from influencing the academic content of the School’s program, and especially disciplinary process or admissions, where the primary intention is to affect their children, the children of family members or close personal friends. Trustees and committee members must distinguish their motives as a member of the Corporation or parent, as opposed to using their position as a trustee or committee member when discussing potentially conflicting issues.

5. Gifts or Favours

a. No employees, trustees or committee members shall accept or seek any gifts, favours, cash, rebates, secret commissions, fees or anything of value for themselves or members of their families that could influence or appear to influence decisions they may be obligated to make on behalf of TMS. b. Employees, governors, or committee members may accept normal business courtesies extended by external organizations such as meals, invitations to meetings or associations on the understanding that these invitations imply no special consideration in return. c. Employees, trustees or committee members may accept on behalf of the School, reasonable gifts from members of the Corporation, which contribute to the well-being of the School on the understanding that such a gift is accepted without any form of future expectations, considerations, favour or reciprocation other than acknowledgement of the donation.

d. Employees, trustees and committee members may accept gifts from members of the Corporation for themselves on the understanding that such a gift is accepted without any form of future expectations, considerations, favour or reciprocation other than acknowledgement of the gift. Class gifts, group gifts and nominal Holiday and Birthday gifts from members of the TMS community for employees, trustees and committee members for their contributions are acceptable forms of gifts.

6. Contributions and Subscriptions

a. No contribution of any kind will be made by any employee of TMS, governor or committee member on behalf of the School to any political party group or person running for public office. b. No contribution of any kind will be made to any organization, group or association on behalf of TMS outside of our normal community service activities without the approval of the Head of School. c. Annual subscriptions and memberships to educational and academic associations or organizations may be entered into by the Head of School (within budget requirements) on the basis it is beneficial to TMS or its employees. Whenever possible, subscriptions or memberships should be corporate, rather than for individual staff persons or trustees.

7. Review of Ongoing Activities.

Increased research support from the private sector, changes in federal law and regulations encouraging technology transfer and the continued need of the School and its employees to demonstrate public accountability have necessitated new approaches in the management of conflict of interest. Some previously acceptable activities may now require re-evaluation, and ongoing activities that involve potential conflict of interest should be disclosed and re-evaluated periodically. If re-evaluation indicates that any problems exist, provision will be made to correct them in an orderly and reasonable fashion.

Non-Compliance with Policy

1. Violations of the requirements of this policy by any employee shall, if not resolved, subject the employee to sanctions or other actions permitted by the employee’s contract of employment. 2. Violations of the requirements of this policy by any governor or committee member of TMS shall, if not resolved, be communicated to the Head of School to review and take appropriate action.

Interpretation

Questions concerning the interpretation or applicability of this conflict of interest policy should be directed to the Head of School as appropriate.

Confidential Information

No employee, trustee, or committee member of TMS shall disclose, release or sell to persons outside of the Corporation any information of a confidential nature concerning TMS.

Prohibition of Illegal Activity and Corruption

Activities which are in violation of federal, provincial, or local law, including the offering or acceptance of a bribe or “kickback” , are strictly prohibited.

Company Name: Toronto Montessori School (TMS) Policy Title: COVID-19 Vaccination Policy Policy Owner: Vince Haines, CAO Approver: Andrew Cross, Head of School Version: 1 Last Review: September 30th, 2021

COVID-19 VACCINATION POLICY FOR TEACHERS, SCHOOL STAFF AND ELIGIBLE STUDENTS

PURPOSE

At TMS (the “School”), we are committed to providing and maintaining a safe school environment for all. Consistent with this commitment, the School has established this COVID-19 Vaccination Policy (the “Policy”). The Policy requires that, in accordance with the terms set forth below, all persons subject to this Policy (as defined in Scope, below) be vaccinated for COVID-19 or obtain an approved accommodation or exemption. The School has established this Policy, considering reliable scientific evidence, government guidance and protocols, its Occupational Health and Safety Act (“OHSA”) requirements and relevant human rights legislation.

BACKGROUND

The objective underlying this Policy is to provide a healthy and safe school environment for students, teachers and staff, and safeguard the broader communities in which they live. The COVID-19 Science Advisory Table for Ontario reported that as of August 15, 2021, 91.4% of the new cases in the province were the Delta variant. It stated that the Delta variant is more transmissible and may be more dangerous than other variants of COVID-19, including the Alpha variant. The Delta variant was the dominant form of the virus during summer 2021. Medical experts warn that as the Delta variant increases significantly in Ontario, unvaccinated populations remain most vulnerable. Among them are children under the age of 12, who are not yet eligible for vaccination.

The Government of Canada currently has authorized a number of COVID-19 vaccines for use in Canada, for individuals 18 years of age and older (or 12 years of age and older for the Pfizer-BioNTech COVID-19 vaccine). In a report dated May 3, 2021, the National Advisory Committee on Immunization (NACI) stated that in clinical trials, all approved COVID-19 vaccines are efficacious in the short term against symptomatic, confirmed COVID-19 disease. Safe and reliable vaccines are an important tool to help stop the spread of COVID-19, build immunity in Ontario and protect our communities. As a school, we have a heightened responsibility to ensure we are doing everything we can to protect our staff, students and their families. As the majority of roles at the School involve close contact with students and staff members, the School has determined that vaccinations of teachers, school staff and eligible students are mandatory, with certain accommodations or exemptions, as set out in this Policy.

SCOPE

This Policy applies to all faculty, staff and students of the School who will be attending in-person for the 2021/22 school year and that are eligible to receive a COVID-19 Vaccination (“Eligible Members of the Community”). This includes students over the age of 12, school administrators, full-time and part time teachers, administrative staff, contract staff, visitors, on-site contractors and volunteers.

PROOF OF VACCINATION

Once an Eligible Member of the Community has been fully vaccinated, they are required to provide proof of vaccination to the School. For the 2021/22 School Year, the deadline is October 15, 2021. Proof can be in the form of a copy of the proof of vaccination given at the time of receiving vaccination, or a letter from a medical practitioner, confirming the individual has been vaccinated and the dates of the vaccinations.

Any new employee who joins TMS during the school year must be fully vaccinated as part of the employment contract and before their first day of work, or have an approved exemption. Any new student eligible for the vaccine who joins TMS during the school year must be fully vaccinated (or have an approved exemption) before their first day of school. All contractors coming on site must show proof of being fully vaccinated. TMS will not engage any contractor or company for any on-site work unless they can show evidence of vaccination. This includes school bus drivers. This policy also applies to specialists who are essential to the delivery of TMS programs and athletics. The School will only collect, use and disclose information regarding an individual staff member’s vaccination status in accordance with its Privacy Policy and all applicable privacy laws. Proof of vaccination will be kept in a confidential file, stored in a secure location and managed by Human Resources.

EXEMPTIONS

The School recognizes its responsibilities and duties under provincial human rights legislation, such as the Ontario Human Rights Code (the “Code”). If an Eligible Member of the Community is unable to be vaccinated, due to a protected ground, as defined by the Code, the School has a duty to accommodate to a point of undue hardship.

Medical Condition Exemption

An Eligible Member of the Community who is requesting an exemption from this Policy on the basis of a medical condition must provide the School with a letter from a medical practitioner, clearly stating the reason why the individual should be exempted from receiving the vaccine. However, this duty to accommodate must be balanced against the School’s obligations to protect the health and safety of staff and students. Due to the serious health threat COVID-19 presents to the public, if an Eligible Member of the Community will not be vaccinated because of a protected ground under the Code, they must request an accommodation or exemption which falls under one of the following two categories:

For employees: 1. Medical Condition; or 2. Any other reason. TMS has a policy that requires ALL employees to be fully vaccinated against COVID-19 at least 14 days prior to participating in any In-person school activities. This is a condition of employment for all employees. The expectation is that this position will be carried out in person at one or both of our campuses. Individuals who cannot be vaccinated due to substantiated grounds (medical and other protected grounds under the Ontario Human Rights Code) or choose not to be vaccinated for any other reason, may ask the school to validate the exemption and request an accommodation. They will be subject to additional health and safety measures. In the event of an approved medical exemption for an employee, or a decision by the employee not to be vaccinated, the employee must agree to conduct an antigen self-test twice a week using tests provided by TMS and report the result to the school Nurse in a timely manner and as soon as possible after the test result is known. This applies whether the result is negative or positive. Please note that prior to declining a first or second vaccination dose for any reason other than a medical reason, an educational session about the benefits of Covid-19 vaccination must be undertaken. The school will provide an online video for this purpose. The regulation permitting employees to opt out of having one or both doses of the Covid-19 vaccine is found in a Government of Ontario document dated September 7, 2021, entitled “Instructions Issued by the Office of the Chief Medical Officer of Health.

For students:

1. Medical Condition; or 2. Religious/Creed exemption. In the event of an approved exemption for an eligible student, the student (and their parents) must agree that the student will carry out antigen self-testing twice a week using tests provided by TMS where such testing is approved by the Ontario government. If the student (and their parents) refuse the testing, the student must move to on-line learning.

Other Exemption

A student may apply for an exemption due to religious belief or creed. The School reserves the right to ask for supporting materials, including a letter from a religious leader verifying that Covid-19 immunization is contrary to the teachings and beliefs of that person's religion.

Process to Receive an Accommodation (see separate document)

The accommodation process is a shared responsibility. All parties should cooperatively engage in the process, share information and consider potential accommodation solutions. Eligible Members of the Community and parents/guardians who are requesting an accommodation are required to: ● make the accommodation needs known to the best of their ability, preferably in writing, in a timely manner; ● answer reasonable questions or provide information about relevant restrictions or limitations, including information from health care professionals; ● take part in discussions about possible accommodation solutions; ● co-operate with any experts whose assistance is required to manage the accommodation process; ● meet agreed-upon performance standards and requirements, once accommodation is provided; and ● work with school administration on an ongoing basis to manage the accommodation process. Depending on workplace and learning and teaching considerations, possible accommodations may include masking, physical distancing, regular testing, remote learning arrangements, work-from-home arrangements, job-protected leave of absence and/or restructured duties and responsibilities, or other measures the school deems necessary to protect the health and safety of students and staff.