The conflicts policy applies to Board members, employees and contracted personnel. It recognizes actual, potential and perceived conflicts arising when personal, family, financial or other interests could interfere—or appear to interfere—with professional responsibilities.
Centinel Securities seeks to prevent and manage conflicts through disclosure, separation of responsibilities, governance controls and recusal. Employees and leaders must avoid the appearance of impropriety and promptly raise circumstances that could compromise independent judgment.
Examples requiring disclosure include transactions involving a personal financial interest, procurement involving an employee or family member, non-customary gifts, use of company resources for related-party benefit, and participation in recruitment or evaluation of a close relation.
Disclosures must be made promptly and in writing. Interested individuals cannot participate in related decisions, and Board-level declarations must be recorded in official minutes. Concealment or non-compliance may result in disciplinary action, including termination.
This summary is for convenience and does not replace the approved document. If there is any difference, the complete PDF governs.