Conflict of interest policy

Studee Ltd

Studee Ltd incorporated and registered in England and Wales with company number 06842641 whose registered office is at Studee Ltd, 15 The Woolmarket, Cirencester, GL7 2PR, (the “Company”).

Policy brief and purpose

Our company conflict of interest policy refers to any case where a team member's personal interest might contradict the interest of the company they work for. This is an unwanted circumstance as it may have heavy implications on the team members' judgment and commitment to the company, and by extension to the realization of its goals.

Scope

Our conflict of interest policy applies to all prospective or current team members of the company, as well as independent contractors and persons acting on behalf of the company.

Definitions

Team member (Employee)

Any person who is employed by Studee Ltd in a part or full-time capacity and in accordance with English law.

Agent

An owner, director, stakeholder, education agent, contractor, or other third-party that is in the position to act on behalf of Studee Ltd.

Financial interest

The interest that any individual may have in the monetary transactions of Studee Ltd . In particular, any interest that could have a direct bearing on the financial gain/loss of said individual.

What is an employee conflict of interest?

This situation may take many different forms that include, but are not limited to, these conflict of interest examples:

• team members or agents ability to use their position with the company to their personal advantage
• team members or agents engaging in activities that will bring direct or indirect profit to a competitor
• team members owning shares of a competitor’s stock
• team members or agents using connections obtained through the company for their own private purposes
• team members or agents using company equipment or means to support an external business
• team members or agents acting in ways that may compromise the company’s legality (e.g. taking bribes or bribing representatives of legal authorities)

The possibility that a conflict of interest may occur can be addressed and resolved before any actual damage is done. Therefore, when an employee understands or suspects that a conflict of interest exists, they should bring this matter to the attention of management so corrective actions may be taken. Team Leads must also keep an eye on potential conflicts of interests of their team members.

The responsibility of resolving a conflict of interest starts from the immediate supervisor and may reach senior management. All conflicts of interest will be resolved as fairly as possible. Senior management has the responsibility of the final decision when a solution can not be found.

In general, team members are advised to refrain from letting personal and/or financial interests and external activities come into opposition with the company’s fundamental interests.

Procedure

Duty to disclose

Every employee/agent of Studee Ltd is obligated to disclose any known or potential conflicts of interest as soon as they arise. Failure to do so could result in termination of employment or contract of services of an education agent.

Investigating potential conflicts

When a possible conflict of interest arises, the board of directors will collect the pertinent information and may question any concerned parties. If the board determines that a conflict exists, steps will be taken to address the conflict. If no conflict exists, the inquiry may be documented but no further action will be taken.

Addressing conflicts of interest

When an actual conflict of interest is found, any transactions that may have been affected will be reviewed retroactively. Affected parties both within and outside of the business, including shareholders, directors, employees, education agents, and contractors will be notified.

An investigation will also be conducted by the board of directors to determine the extent of the conflict and the intentions of the parties involved.

If the conflict in question involves a member or members of the board of directors, such a member will be excused from the deliberations.

Disciplinary action

As all conflicts of interest will be reviewed on a case-by-case basis, a review may result in disciplinary action. The board of directors has full discretion to deem what disciplinary action is both fitting and necessary, including suspension and/or termination of employment or services agreement.

Acknowledgement

Team members are notified of this policy in the Studee employee handbook and confirm that they understand the procedure for conflicts of interest with Studee Ltd, including their duty to disclose any known or potential conflicts of interest. This policy is available to the public and all agents who work with Studee should make themselves aware of it.

The team member/agent named below understands the procedure for conflicts of interest with Studee Ltd, including their duty to disclose any known or potential conflicts.

Furthermore, the employee/agent agrees to abide by the procedures outlined in this policy for the duration of their professional relationship with Studee Ltd.

Governing law and jurisdiction

These Terms of Use, any documents they refer to, and any disputes arising from or in relation to them or any documents they refer to, whether contractual or non-contractual, shall be governed by and construed in accordance with English law.

The courts of England and Wales shall have exclusive jurisdiction over any claims or disputes arising from or in relation to these Terms of Use and any documents they refer to.