CONFLICTS OF INTEREST POLICY

Summit Impact

Revised March 25, 2022

PURPOSE

Summit Impact believes the trust and confidence of our donors, partners, and other supporters depend on our continuing to maintain the highest standards of ethical and lawful conduct. It is Summit Impact’s position that all individuals involved with its mission must comport themselves so that there is not even the appearance of conflict between personal interests and those of Summit Impact. To ensure the continuity of its high standards of conduct, Summit Impact desires to set forth the common understandings that must exist among the members of its community regarding practices. The purpose of the Conflict of Interest Policy is to protect Summit Impact’s interest when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer, director, or employee of Summit Impact. The policy is designed to ensure that all institutional decisions are made solely to promote the best interests of Summit Impact without favor or preference based on personal considerations, and to provide the highest ethical conduct.

Disclosure

Any director, officer or key employee who has an interest in a contract or other transaction presented to the Board of Directors or a committee of the Corporation for authorization, approval or ratification shall promptly and fully disclose his or her interest to the Board of Directors or applicable committee prior to the proposed authorization, approval or ratification.

Determination and Effect of Conflict

The Board of Directors or committee (as applicable) to which such disclosure is made shall determine, by a majority vote of the other directors or committee members, whether the disclosure shows that a conflict of interest exists or can reasonably be construed to exist. If a conflict is deemed to exist, such person shall not vote on, nor use his or her personal influence on, nor participate in (other than to present factual information or to respond to questions), the discussions or deliberations with respect to such contract or transaction. Such person may be counted in determining whether a quorum is present but may not be counted when the Board of Directors or committee takes action on the transaction. The minutes of the meeting shall reflect the disclosure made, the vote thereon and, when applicable, the abstention from voting and participation, and whether a quorum is present.

Basis of Decisions

All institutional decisions are to be made solely to promote the best interests of Summit Impact without favor or preference based on personal considerations, and to provide the highest ethical conduct. Accordingly, with respect to their personal economic interests, Summit Impact officers, Board members, and employees should not be allowed to participate actively as advocates in their own behalf (or on behalf of other organizations in which they have a personal interest), either formally at Board or committee meetings or informally through private contact, communication, and discussion. Similarly, officers, Board members, or employees may not obtain for themselves, their relatives, or their friends a material benefit of any kind from their association with Summit Impact, or from the knowledge gained therefrom.

Confidential Information

In addition, one of Summit Impact’s most valuable assets is its confidential information, which includes includes donor and constituent data and lists, research data, financial data, computer software and equipment information, and other information which might reasonably be consider to not be of a public nature, whether in printed, digital, or other format. The security and integrity of all confidential data must be diligently protected. Accordingly, officers, Board members and employees should not disclose or use any confidential information involving Summit Impact for personal benefit or for non-Summit Impact related purposes.

Violation of Conflict of Interest Policy

If the Board or a committee has reasonable cause to believe that a member of the Board, committee, officer or employee of Summit Impact has failed to disclose actual or possible conflicts of interest, it shall inform the person of the basis of such belief and afford the person an opportunity to explain the alleged failure to disclose. If, after hearing the response of the person and making such further investigation as may be warranted in the circumstances, the Board or committee determined that the person has in fact failed to disclose an actual or possible conflict of interest, it may take appropriate corrective action as is needed in the circumstances.