Conflict of Interest

Employees are expected to limit the possibility of any conflicts of interest that may arise as a result of their employment at Alloya. Employees should avoid circumstances where they are an interested party in a transaction or activity with a competitor, supplier, member or other party that Alloya has or may reasonably have a contractual or business relationship with.

Employees are interested parties if they or their immediate family members have a financial interest in the other party. Immediate family members include any familial members living in the same household. Employees may not use their position at Alloya to further personal or business interests, or secure special privileges for themselves or immediate family members. Examples of potential conflicts of interest may include, but are not limited to:

• Employment by a company that their immediate family members work with and Alloya has a contractual or business relationship with.
• Working for audit firms that Alloya has a contractual or business relationship with.
• Working for Alloya members.
• Being an Official (Board or Senior Management) for an entity that Alloya has an existing contractual or business relationship with.
• Receiving compensation, directly or indirectly, for directing Alloya business to an entity with which the employee or their immediate family member has a pecuniary interest.

Employees who believe they may create a conflict of interest under this guideline are required to report this information directly to Human Resources. If, solely in Alloya’s opinion, a conflict of interest might exist that may not be reasonably avoided by the employee, Alloya may request the employee not pursue that activity to maintain their employment at Alloya.

2/17/2026