This Conflict of Interest Policy reflects the policy and practices of Senda Strategy LLC (the "Company") from its date of adoption. Members, managers, officers, contractors acting in a decision-making capacity, and employees with authority over Company matters (collectively, "Covered Persons") each have an obligation to act in the best interests of the Company.
Duty of Loyalty
Each Covered Person owes a duty of loyalty to the Company and shall subordinate personal, financial, third-party, and affiliated business interests to the best interests of the Company when acting on Company matters.
What Is a Conflict of Interest?
A conflict of interest exists when a Covered Person has an actual or potential financial, business, family, or personal interest that could impair, or appear to impair, that person's independence, objectivity, or judgment on behalf of the Company.
Conflicts may arise from:
- ownership in or advisory roles with clients, vendors, counterparties, or competitors;
- family or close personal relationships affecting Company decisions;
- receipt of gifts, benefits, or side compensation; and
- use of Company opportunities or confidential information for personal benefit.
Disclosure
Each Covered Person shall disclose any actual, apparent, or potential conflict of interest promptly after becoming aware of it. Covered Persons are encouraged to err on the side of disclosure.
Review Process
Any disclosed conflict shall be reviewed by the disinterested Member or Members, or by a delegated reviewer approved by the Members. The reviewer shall determine whether a conflict exists, whether the conflict is material, and what response is appropriate to protect the Company.
Remedies
Possible remedies include determining no material conflict exists, requiring enhanced disclosure to the Members, recusal from discussion or approval of the matter, requiring modification or termination of the relationship, or requiring resignation from a position of authority if necessary.
Documentation
All disclosures, determinations, recusals, and approvals under this policy shall be documented in Company records.
Annual Confirmation
Each Covered Person with ongoing decision-making authority shall review this policy periodically and confirm any known conflicts in writing.
I acknowledge that I have read the Senda Strategy LLC Conflict of Interest Policy and agree to comply with it.
Name:
Title or Role:
Disclosed conflicts, if any:
Signature
Date: