Conflict of Interest Policy for

A. Purpose

At, our reputation and the trust of our users are paramount. As a leading news, deals, coupons, and reviews website, we are committed to maintaining the highest standards of integrity and transparency. The purpose of our Conflict of Interest Policy is to ensure that the interests of and its stakeholders are protected when potential conflicts arise.

B. Definitions

  1. Representatives: Representatives include directors, officers, committee members, volunteers, staff, contracted parties, agents, and individuals in decision-making roles designated by the organization.
  2. Conflict of Interest: A conflict of interest occurs when a person’s personal relationships or interests interfere with their duty of loyalty to or compromise their ability to act impartially in the best interests of the organization. This conflict can arise when there is an actual adverse interest or competing interest between the individual and
  3. Related Party: Related Party refers to any individual or entity associated with, including directors, officers, employees, volunteers, their relatives, entities with significant ownership or beneficial interest, partnerships, or professional corporations in which individuals associated with have a direct or indirect ownership interest, or any entity with a material financial interest involving individuals associated with
  4. Relationship: In this policy, “Relationship” refers to any financial, familial, or non-financial connection or interest held by the person making the disclosure.
  5. Relative: “Relative” includes a person’s spouse or domestic partner, ancestors, siblings or half-siblings, children (natural or adopted), grandchildren, and great-grandchildren, or the spouse or domestic partner of any person mentioned in this definition.

C. Disclosure Principles

At, we are committed to transparently managing conflicts of interest. To ensure the integrity of our operations, we have established the following disclosure principles:

  1. Disclosure: Representatives are required to fully disclose all financial and non-financial relationships, including employment, ownership interests, memberships, arrangements, investments, and holdings, both for themselves and their family members. This disclosure should be provided through the Relationship Disclosure Questionnaire.
  • Initial disclosure is typically required before appointment or election, with subsequent updates on material changes and annually thereafter.
  • During meetings or activities, Representatives must disclose any direct or indirect interests in transactions or decisions that may present a conflict of interest.
  • The Corporate Secretary is responsible for maintaining appropriate records of all disclosures as required by this policy and applicable law. Additionally, copies of disclosures by Board members are provided annually to the Audit Committee Chairperson.
  1. Evaluation: We evaluate both financial and non-financial relationships reported by Representatives to identify any actual or perceived conflicts of interest. The evaluation considers the individual’s position(s), decision-making authority, the significance of relationships, and the potential impact on’s integrity and reputation.
  2. Resolution: Conflicts of interest may be resolved by having the Representative refrain from participating in deliberations and voting on specific transactions or matters, abstaining from exerting influence on’s decisions, or implementing other appropriate measures. The resolution approach is determined based on the facts and circumstances of each situation, and in some cases, may require the individual to withdraw from the conflicting relationship or their position within No person with a conflict of interest should attempt to improperly influence the deliberation or voting on matters related to the conflict.
  3. Transactions with Related Parties: Unless excluded below, the Executive Committee of the Board of Directors is responsible for reviewing any proposed transactions between and Related Parties, or transactionsin which a Related Party has a substantial financial interest. The Executive Committee follows this Policy and adopted procedures when evaluating such transactions. The following activities are exempt from the review requirements:
  • Transactions or financial interests that are deemed de minimis.
  • Transactions that are not typically subject to board review in the ordinary course of business and are available to others on similar terms.
  • Transactions that benefit a Related Party as part of a class of beneficiaries intended to further’s mission and are available to all similarly situated members of the class on the same terms.

D. Requirements for Certain Positions

Given the diverse nature of’s activities, specific procedures may be required for different volunteer and staff positions to address potential conflicts of interest. These procedures must be consistent with applicable laws and this Policy.

Volunteers acting on behalf of must refrain from soliciting or accepting gifts, gratuities, honoraria, entertainment, favors, or other goods or services from current or prospective vendors, service providers, corporate partners, or competitors of for personal, professional, or business gain.

E. Confidentiality

All information disclosed in response to the request for relationship disclosure will be treated as strictly confidential and used solely for the purposes for which it was collected.

F. Implementation

The CEO and designated individuals are responsible for developing and maintaining appropriate procedures to implement this Conflict of Interest Policy. These procedures should cover specific areas while aligning with the disclosure principles outlined in this policy. The Audit Committee oversees compliance with the policy and ensures its effective implementation.

The existence and resolution of conflicts of interest must be documented in’s corporate records, including minutes of relevant meetings where conflicts were discussed or voted upon. Each director, officer, employee, and volunteer has a responsibility to report any suspected failure to disclose by any Representative, regardless of their position, in accordance with’s Whistleblower Policy.

Conduct that violates this policy is considered outside the scope of employment for any employee acting on behalf of