Conflict of Interest Policy

Pursuant to the Conflict of Interest policy, all employees, contingent workers, and volunteers have an obligation to avoid actual or potential conflicts of interest with their provision of services to CFA Institute. A conflict of interest may exist when you or a member of your family are involved in activities that may impact your ability to conduct CFA Institute business fairly and impartially. A conflict may be actual or perceived and could result in personal or professional gain for that employee, contingent worker or volunteer, or persons close to them. For the purposes of this policy, family members include an employee, contingent worker or volunteer’s spouse, children, parents, siblings, grandparents or grandchildren; the parents, children, or siblings of the employee, contingent worker or volunteer’s spouse; or any other person whose association with the employee, contingent worker or volunteer is similar to any of these relationships.

An employee, contingent worker, or volunteer’s participation in any CFA Institute exam program, or participation of any family members/ household members can create a potential or perceived conflict of interest or advantage. Employees, contingent workers, and volunteers must request and receive approval from Exam Security prior to enrolling in any CFA Institute exam program. Further, employees, contingent workers, and volunteers must disclose to Exam Security any immediate family/household member participating in the CFA or CIPM programs.

Business dealings with outside firms should not result in unusual gains for CFA Institute or the outside firm. Unusual gains refer to bribes, product bonuses, special fringe benefits, unusual price breaks, or other windfalls designed to ultimately benefit the employer, the employee, contingent worker or volunteer, or both. Anything that could be interpreted as involving an unusual gain requires disclosure and approval by the Chief Compliance Officer.

All employees, contingent workers, and volunteers with any influence over CFA Institute business with outside firms must disclose to their CFA Institute liaison and the Chief Compliance Officer any relationships with the firm and any personal gain to the employee, contingent worker, or volunteer, or persons close to them. Disclosures should be made as soon as possible so that safeguards can be established to protect all parties. Personal gain may result not only in cases where an employee, contingent worker or volunteer or an employee, contingent worker or volunteer’s family member has significant ownership in a firm with which CFA Institute does business but also when an employee, contingent worker or volunteer or an employee, contingent worker or volunteer’s family member receives any kickback, bribe, substantial gift (e.g., all-expense-paid vacation, weekend getaway, etc.) or special consideration as a result of any transaction or business dealings involving CFA Institute.