Conflict of Interest Policy

1. Objective

The purpose of this Conflict of Interest Policy is to protect the integrity and tax-exempt status of Reaching Sky Foundation when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer, Trustee, director, or key stakeholder.

2. Definition of Conflict of Interest

A conflict of interest arises whenever the personal or financial interests of an interested person (Trustee, staff member, or key advisor) are inconsistent with or compete with the best interests of Reaching Sky Foundation. This includes, but is not limited to:

• Ownership or investment in an entity providing goods or services to RSF.
• Compensation agreements or employment arrangements with prospective vendors.
• Familial or close personal relationships influencing procurement or hiring decisions.

3. Duty to Disclose

In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial or personal interest and be given the opportunity to disclose all material facts to the Board of Trustees.

4. Procedures for Addressing Conflicts

After disclosure of the financial interest and all material facts:

• The interested person shall recuse themselves from the meeting while the determination of a conflict of interest is discussed and voted upon.
• The Board of Trustees shall evaluate alternative arrangements or comparable competitive bids.
• A transaction may only be approved if the Board determines by a majority vote of disinterested Trustees that the transaction is in the foundation's best interest, for its own benefit, and fair and reasonable.

5. Annual Statements

Each Trustee, principal officer, and key management personnel shall annually sign a statement affirming compliance with this policy and disclosing any relevant outside associations.