Conflict of Interest Policy

CONFLICT OF INTEREST POLICY
FOR The Port Jefferson Station Teachers Association Welfare Fund
OFFICIALS AND EMPLOYEES
__________________________________

The Port Jefferson Station Teachers association Welfare Fund
(Hereinafter referred to as the “Organization”) officials have a fiduciary
obligation to act in the best interests of the Organization. Organization
employees have an obligation to carry out their organizational responsibilities
in a manner that advances the interests of the Organization, and to take no
action in the course of their employment or otherwise that could be detrimental
to those interests. The purpose of this Conflict of Interest Policy for
Organization officials and employees (“CI Policy”) is to provide guidance to the
Organization’s officials and employees in complying with their fiduciary and
employment obligations.

I. DEFINITIONS
As used in the CI Policy, the following terms have the meanings
indicated:

A. The term “Organization official” means a member of the applicable
governance (i.e., a trustee of the Organization), Beth Ziff-Dimino, Beth Shapiro, Maurizio Milana and any other person designated by the Organization’s governance to
represent the Organization. The term does not mean an employee
Of, or a consultant retained by the Organization.

B. The term “Organization employee” means a regular, probationary,
part-time, or temporary employee of the Organization. The term
does not mean the Organization official.

C. The term “immediate family” of the Organization official or of an
Organization employee means his or her parent, spouse or spousal
equivalent, child, stepparent, stepchild, grandparent, grandchild,
sibling, mother-or father-in-law, sister-or brother-in-law, or
daughter-or son-in-law.

D. The term “directly or indirectly” means an action taken by the
Organization official or the Organization employee in his or her
own name (i.e. directly), or through a member of the immediate
family or a business associate of the Organization official or an
Organization employee (i.e. indirectly).

E. The term “participate in an Organization decision” means the
authority to approve, disapprove, recommend, or otherwise
influence the position taken by the Organization.

F. The term “Conflict of Interest Officer” (“CI Officer”) means the
person who is responsible for the implementation of the CI Policy.

II. STATEMENT OF PRINCIPLE
No Organization official and no Organization employee shall, directly or
indirectly, have any interest or relationship, take any action or engage in any
transaction, or incur any obligation which is in conflict with, or gives the
appearance of a conflict with, the proper and faithful performance of his or her
organizational responsibilities.

III. PROHIBITED ACTIVITIES
The activities that are prohibited by the Statement of Principle set forth
in Section II include, but are not limited to, the following:

A. No Organization official or Organization employee shall, without
the advance written approval of the CI Officer, have a direct or
indirect financial or personal interest in or relationship with any
business, firm, person, or entity that does or seeks to do business
with the Organization. This prohibition shall not apply to
investments in a business, firm, or other entity through the
purchase of securities that are traded on a registered national
securities exchange, or utilizing any services that the business,
firm, person, or entity makes available to the general public in the
normal course of business. Additionally, this prohibition shall not
apply to the sponsoring labor organization official’s or employee’s
participation in any Organization member benefit program to
which the sponsoring labor organization official or employee is
eligible to take part by virtue of their status as a sponsoring labor
organization member or employee.

B. No Organization official or Organization employee shall receive any
compensation, gift, gratuity, loan or other thing of value from any
business, firm, person, or other entity which does or seeks to do
business with the Organization, or which has financial or other
interests that may be affected by the performance or
nonperformance of the Organization official’s or Organization
employee’s organizational responsibilities. The “compensation, gift,
gratuity, loan, or any other thing of value” does not include an item
or items received during the Organization’s applicable year with an
aggregate value of $250 or less, or a loan that is available to the
general public on similar terms. The prohibition in this Section III
(B) shall not apply if the Organization official or Organization
employee receives the item in question in the performance his or
her organizational responsibilities (i.e. business dinner or
function).

C. No Organization official or Organization employee shall (1) except
in the performance of his or her organizational responsibilities or
in response to a legal mandate, disclose any information obtained
by reason of his or her position that is not otherwise available to
the general membership of the sponsoring labor organization, and
that could be used to the detriment of the Organization; or (2) use
or permit others to use any information obtained by reason of his
or her position that is not otherwise available to the general
membership of the sponsoring labor organization to directly or
indirectly further the Organization official’s or Organization
employee’s financial or personal interest.

D. No Organization official or Organization employee shall, without
the advance written approval of the CI Officer, directly or indirectly
sell goods or services to the Organization. This prohibition shall
not apply to the payment of stipend, or travel expenses to the
Organization official or Organization employee for carrying out his
or her organizational responsibilities.

E. No Organization official or Organization employee shall accept any
other position or assignment which would conflict with his or her
fiduciary obligation to act in a manner that advances the best
interests of the Organization, or interfere with the Organization
official’s or Organization employee’s ability to properly carry out his
or her organizational responsibilities.

F. No Organization official or Organization employee shall use or
permit others to use his or her position with the Organization to
create the impression that the Organization endorses or has
endorsed a product, service or program when that is not in fact the
case, or to otherwise directly or indirectly further the Organization
official’s or Organization employee’s financial or personal interest.

IV. IMPLEMENTATION PROCEDURE

A. Beth Ziff-Dimino, Beth Shapiro, and Maurizio Milana
shall serve as the CI Officers, and shall in that capacity be
responsible for the implementation of the CI Policy. The CI Officer
shall monitor the implementation of the CI Policy and, recommend
to the Organization’s governance such modifications in the Policy
as he or she may from time to time deem appropriate (see, Section
VI. A).

B. (1) If the Organization official or Organization employee believes
that he or she may be engaged or about to become engaged in an
activity that is prohibited by the CI Policy, he or she shall consult
with the CI Officer. The Organization official or Organization
employee and the CI Officer shall attempt to deal with the matter
informally. If they are unable to do so, the CI Officer shall submit
to the Organization official or Organization employee, as may be
applicable, a written opinion indicating whether the activity in
question is prohibited by the CI Policy, and, if so, what should be
done to correct the situation.

(2) Applicable only to Organization employees: If the Organization employee
disagrees, in whole or in part, with the conclusions of the CI
Officer, he or she may appeal to The Port Jefferson Station Teachers Association Executive Board(hereinafter referred to as the “Appeals
Committee”) by filing a written notice of appeal with the
Organization’s Appeals Committee within ten (10) calendar days
after receiving the opinion of the CI Officer. The Organization’s
Appeals Committee shall decide the appeal as expeditiously as
possible, and the resulting decision of the Organization’s Appeals
Committee shall be final and binding, subject to whatever
contractual rights the Organization employee may have to
challenge the final decision, including, without limitation, his or
her right to challenge said decision through the grievance
procedure in a collective bargaining agreement with the sponsoring
labor organization. If the Organization employee files a timely
appeal, he or she need not comply with the opinion of the CI
Officer pending the outcome of the appeal. If the Organization
employee does not file a timely appeal, he or she shall comply with
the opinion of the CI Officer.

C. Applicable only to Organization officials: If
the Organization official disagrees, in whole or in part, with the
conclusions of the CI Officer, he or she may appeal to the
Organization’s Appeals Committee by filing a written notice of
appeal to the Organization’s Appeals Committee within ten (10)
calendar days after receiving the opinion of the CI Officer.
Thereafter, the Organization’s Appeals Committee shall act on the
appeal as expeditiously as possible. If the Organization official files
a timely appeal, he or she need not comply with the opinion of the
CI Officer pending the outcome of the appeal. If the Organization
official does not file a timely appeal, he or she shall comply with
the opinion of the CI Officer.

D. (1) If a member or employee of the sponsoring labor organization
believes that an Organization official or Organization employee is
engaged or is about to become engaged in an activity that is
prohibited by the CI Policy, the member or employee may file a
written complaint with the CI Officer. The complainant shall
identify himself or herself to the CI Officer, but the CI Officer shall,
if requested to do so by the complainant, treat the complaint as
anonymous and not reveal the complainant’s name.

(2) Upon receiving a complaint, the CI Officer shall consult with the
complainant and, as may be applicable, the Organization official or
Organization employee in question. Based upon the information
received from the complainant and the Organization official, or
Organization employee and/or other relevant information, the CI
Officer shall decide whether the Organization official or
Organization employee is engaged or is about to become engaged in
an activity that is prohibited by the CI Policy, and, if so, what
should be done to correct the situation. The CI Officer shall submit
to the Organization official or Organization employee, as may be
applicable, and to the complainant a written opinion setting forth
his or her conclusions.

(3) Applicable only to Organization employees: If the Organization employee
disagrees, in whole or in part, with the conclusions of the CI
Officer, he or she may appeal to the Organization’s Appeals
Committee by filing a written notice of appeal with the
Organization’s Appeals Committee within ten (10) calendar days
after receiving the opinion of the CI Officer. The Organization’s
Appeals Committee shall decide the appeal as expeditiously as
possible, and the resulting decision of the Appeals Committee shall
be final and binding, subject to whatever contractual rights the
Organization employee may have to challenge the final decision,
including, without limitation, his or her right to challenge said
decision through the grievance procedure in a collective bargaining
agreement with sponsoring labor organization. If the Organization
employee files a timely appeal, he or she need not comply with the
opinion of the CI Officer pending the outcome of the appeal. If the
Organization employee does not file a timely appeal, he or she shall
comply with the opinion of the CI Officer.

(4) Applicable only to Organization officials: If the Organization official disagrees, in whole or in part,with the conclusions of the CI Officer, he or she may appeal to the
Organization’s Appeals Committee by filing a written notice of
appeal with the Organization’s Appeals Committee within ten (10)
calendar days after receiving the opinion of the CI Officer.
Thereafter, the Organization’s Appeals Committee shall act on the
appeal as expeditiously as possible. If the Organization official files
a timely appeal, he or she need not comply with the opinion of the
CI Officer pending the outcome of the appeal. If the Organization
official does not file a timely appeal, he or she shall comply with
the opinion of the CI Officer.
D. In implementing the CI Policy, the CI Officer and the Appeals
Committee shall consider all relevant factors, including the specific
organizational responsibilities of the Organization official or Organization employee and the nature of the allegedly prohibited activity, and shall interpret and apply the CI Policy in a mannerthat furthers its intended purpose.

V. MISCELLANEOUS

A. Nothing in the CI Policy shall be interpreted or applied to deprive
the Organization official or Organization employee of any rights
that he or she may have under the Organization’s governing
documents, policies, a contract with the sponsoring labor
Organization, statute, or as an elected leader of a national or state
affiliate of the sponsoring labor organization. To the extent that the
CI Policy is inconsistent with any such right, the Organization’s
governing documents, policies, a contract with the sponsoring
labor organization, statutory right or right as an elected leader of a
national or state affiliate of the sponsoring labor organization shall
take precedence.

B. If a question arises as to whether the CI officer has engaged, may
be engaged, or is about to become engaged in an activity that is
prohibited by the CI Policy, the matter shall be dealt with by the
remaining members of the Organization’s Appeals Committee.

C. All information and documents involved in the implementation of
the CI Policy shall be treated as confidential, and the CI Officer
shall make such information and documents available to others
only on an “as needed” basis. To the extent relevant, all privileges,
including the attorney/client and attorney work product privileges,
shall apply to information and documents involved in the
implementation of the CI Policy, including any and all CI
complaints and investigations thereof.

VI. EFFECTIVE DATE AND AMENDMENT; DISTRIBUTION

A. The CI Policy shall be made effective as of  January 6, 2010 and shall supersede all prior conflict of interest policies of the Organization dealing with the same subject or other policy dealing with any provision expressly covered by this policy. The
Organization’s governance, may amend, from time to time as it deems appropriate, those provisions of the CI Policy pertaining to Organization employees.

B. the CI Policy shall be posted on the Organization’s Web site, and a copy of the Policy shall be distributed to all Organization officials and Organization employees.

Effective: January 6, 2010

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