Conflict of Interest Policy and Interests Register (v2)

1. Why this version replaces the July 2026 policy

The July 2026 policy was written for a charity applying for CRA charitable registration (Form T2050). AWARE Community Foundation was instead incorporated as a non-profit company under Alberta's Companies Act (Corporate Access No. 5128599791), and it is not a registered charity. This version replaces the July policy, reflects the directors on the filed Notice of Directors, and adds two things the July policy lacked:

• a published Interests Register; and
• rules specific to an organization funded by gambling operators and working with athletes.

Everything else in the July policy (disclosure, recusal, record-keeping) is carried forward.

2. Purpose

AWARE is funded by licensed gambling operators and works with athletes whose sports are bet on. Its credibility depends on people being able to see that no director, officer, staff member or educator benefits personally from those relationships, and that anyone with a competing interest steps out of the decisions it touches. This policy sets out how interests are declared, published and managed.

3. Scope

This policy applies to directors, officers, employees, contractors, Athlete Educator Corps members, committee members and volunteers ("Covered Persons").

4. Definitions

• Conflict of interest: any situation in which a Covered Person's personal interests, or those of a Related Person or an organization to which they owe a duty, conflict or could reasonably be seen to conflict with AWARE's interests or its independence commitments.
• Related Person: a spouse or common-law partner, child, parent, sibling, or anyone with whom the Covered Person has a close personal or financial relationship.
• Gambling Interest: any employment, contract, shareholding (other than less than 1% of a publicly traded company held passively), advisory role, sponsorship, affiliate arrangement or paid relationship with a gambling operator, a gambling supplier, a betting data company or an affiliate marketer.
• Sport Interest: any governance, executive, ownership, commercial, promotional or competitive role in a sport, league, event, team or athlete-management business, including esports and combat sports.

5. Rules specific to AWARE

1. Gambling Interests disqualify. No person with a current Gambling Interest, or one ended within the past 24 months, may serve as an independent director, Executive Director or Corps educator. A founding director with such an interest must declare it and may not vote on any partner, funding or program matter.
2. Sport Interests are declared and managed, not prohibited. Athlete betting education needs people from sport. Every Sport Interest is declared on the Register. The holder is recused from any decision that could affect that sport, league, event, team or athlete, including any decision about funding from an operator that sponsors or takes bets on it.
3. No sponsorship cross-over. No Covered Person may use their AWARE role to seek or negotiate sponsorship from a gambling operator for any other organization they are involved in. Any existing operator sponsorship of a Covered Person's other organization is declared on the Register.
4. Related-party transactions need independent approval and publication. No contract between AWARE and a Covered Person, a Related Person or an entity they control (including any delivery or consulting company) may proceed without all of the following:
   • approval by the independent directors, with the interested person absent;
   • evidence of arm's-length pricing;
   • publication of the counterparty, purpose and value in the annual report.

   Until independent directors are seated, no such contract may be entered into at all.

5. The founder as interim chair. While the founder is interim chair, any matter in which the founder has a declared interest is chaired by another director. Conflict declarations by the chair are reviewed by the other directors, and later by the independent directors.
6. Corps educators. An educator may not hold any commercial relationship with a gambling operator, including a responsible-gambling ambassador role, during their AWARE engagement and for 12 months afterward, subject to legal advice on SRIG s.4.1.4(d).

6. Disclosure

• On appointment and every year: each Covered Person completes the Annual Disclosure Form (Appendix B).
• At meetings: interests are declared at the start of the relevant agenda item and recorded in the minutes.
• As things change: new interests are declared in writing within 14 days.

7. Managing a declared conflict

The Covered Person leaves the discussion and the vote, and does not try to influence the outcome. The remaining directors decide whether a conflict exists and how to manage it, and the minutes record the decision. Quorum is unaffected unless the conflicted person is needed for quorum. In that case the matter is deferred until enough disinterested directors are available.

8. Publication

The Interests Register (Appendix A) is published on AWARE's website and updated within 30 days of any change. Published entries name the organization and the nature of the role. Private financial amounts are not published, but are disclosed to the board.

9. Records and breach

The Secretary keeps the Register, disclosures and minutes for seven years. Failure to declare is a serious breach. The board may void affected decisions, require repayment of any benefit, or remove the person from their role. A substantiated breach is reported in the annual report.

10. Review

The board reviews this policy every two years, and immediately after independent directors are seated.

11. Adoption

Adopted by the Board of Directors on 9 October 2026.

Appendix A: Interests Register

Each director completes their own row. Declarations on file are published as soon as each is complete.

Nil returns are recorded as "No declarable interests" and are published too.

Appendix B: Annual Disclosure Form

Name · AWARE role · Date

1. List every Sport Interest you or a Related Person hold (organization, role, paid or unpaid).
2. List every Gambling Interest you or a Related Person hold, or held in the past 24 months.
3. Does any organization you are involved in receive sponsorship, advertising or other payment from a gambling operator? Give details.
4. Do you or a Related Person control any entity that supplies, or could supply, goods or services to AWARE?
5. Is there anything else a reasonable person might see as affecting your independence?

I confirm this disclosure is complete and that I will update it within 14 days of any change.

Signature · Date

← All governance documents · Questions: info@awarecf.com