Employee Conflict of Interest Policy

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A financial interest is not necessarily a conflict of inter est. A person who has a financial interest may have a conflict of interest only if the Audit Committee or Executive Board of the Boy Scouts of America decides that a conflict exists, in accordance with policy.

Significant financial interest A person has a significant financial interest if the person has, directly or indirectly, through business, investment, or family a financial interest that: a. exceeds $10,000 in value or represents more than 5% ownership interest in any one enterprise or entity, when aggregated for the member and his or her family members for the disclosure period.

Direct financial interest A financial interest that is Owned directly by an individual or business, investment, or family (including those managed on a discretionary basis) a. Under the control of an individual or business (including those managed on a discretionary basis). b. Beneficially owned through an investment vehicle, estate, trust, or other intermediar y when the beneficiary controls the intermediary; or has the authority to supervise or participate in the intermediary’s investment decisions.

Indirect financial interest A financial interest beneficially owned through an investment vehicle, estate, trust, or other intermediary when the beneficiary neither controls the intermediary nor has the authority to supervise or participate in the intermediary’s investment decisions.

Beneficially owned A financial interest in which an individual or business is not the owner of record but has some right to some or all of the underlying benefits of ownership.

It is the responsibility of every employee of the Boy Scouts of America to be aware of and to observe these standards. Accordingly, you are asked to sign and return the accompanying Employee Statement relating to these standards. Employee Statements will be held in complete confidence. The Employee Statement will be re-executed on annual basis.

The Executive Board and/or Audit Committee of the Boy Scouts of America shall regularly and consistently monitor and enforce compliance with this policy and taking such other actions as are necessary for effective oversight.