Policy Number: 28102022D Effective Date: October 28, 2022 Last Reviewed Date: October 28, 2022 Owner: Special Assistant to the President Summary: This policy establishes procedures for identifying and resolving conflicts of interest related to financial transactions involving South Geauga Theology University (SGTU). 1. Policy Statement: The policy addresses conflicts of interest in transactions where an Interested Person may have a Financial Interest in an entity with which SGTU is negotiating a transaction or arrangement. It supplements state laws governing conflicts of interest and the University’s Policy on Conflicts of Interest. 2. Definitions: Compensation: Includes direct and indirect remuneration and substantial gifts or favors. Family: Includes relatives as defined in the policy. Financial Interest: Ownership, compensation arrangements, or potential interests in entities with which SGTU transacts. Gift: Excludes certain customary transactions outlined in the policy. Interested Person: Trustees, officers, employees, or volunteers with a financial interest. Volunteer: Includes designated personnel notified of the policy by their manager.

Procedures Regarding Financial Transactions: 1. Duty to Disclose: Interested Persons must disclose Financial Interests in any transaction or arrangement with SGTU. Disclosure is also required if the person becomes aware of discussions or negotiations involving a Financial Interest. 2. Determining Whether a Conflict of Interest Exists: The Board decides if a conflict of interest exists after disclosure and discussion of all material facts. Certain ownership of publicly traded securities is exempt from creating a material Financial Interest. 3. Procedures for Addressing a Conflict of Interest or Apparent Conflict of Interest: Interested Persons involved in a conflict must recuse themselves from discussions and votes related to the transaction. The Board may appoint a disinterested person or committee to investigate alternatives to the proposed transaction. The Board determines whether SGTU can obtain a more advantageous transaction without a conflict of interest. If a more advantageous transaction is not feasible, the Board decides whether the transaction is in SGTU’s best interest and fair to the organization.

4. Violations of the Conflicts of Interest Policy: The Board investigates and takes disciplinary action against individuals failing to disclose conflicts of interest. 5. Records of Proceedings: Board minutes include details of disclosed Financial Interests and actions taken regarding conflicts of interest. 6. Compensation Committees: Members receiving compensation from SGTU are restricted from voting on matters concerning their compensation. 7. Annual Statements: Trustees, officers, employees, and volunteers annually sign a Declaration of Interests Form. Periodic Reviews: Reviews ensure compliance with charitable purposes, reasonable compensation, and proper transactions with other organizations. Use of Outside Experts: SGTU may use outside experts for periodic reviews, but the Board remains responsible for ensuring compliance. This policy aims to maintain integrity and transparency in SGTU’s financial transactions while mitigating conflicts of interest.