1. Purpose
Apprentix is committed to maintaining the highest standards of integrity and impartiality in our operations. This Conflicts of Interest Policy ensures that our employees, contractors, and affiliates act in the best interests of our customers and avoid situations where personal or external interests could compromise business decisions, particularly those affecting customer data, service delivery, or vendor relationships.
2. Scope
This policy applies to all Apprentix employees, contractors, and third-party affiliates involved in delivering our cloud-based Apprenticeship Management System, built on Bubble.io and hosted on Amazon Web Services (AWS).
3. Definition
A conflict of interest occurs when an individual’s personal interests, financial relationships, or external affiliations could influence, or appear to influence, their professional judgment, actions, or loyalty to Apprentix and its customers.
4. Policy
Disclosure: Employees and contractors must promptly disclose any actual or potential conflicts of interest to their supervisor or the Chief Technology Officer (CTO) in writing. Examples include:
Financial interests in a competitor, customer, or vendor (e.g., AWS, Bubble.io).
Personal relationships that could affect business decisions (e.g., hiring, vendor selection).
Secondary employment or consulting that overlaps with Apprentix’s services.
Prohibited Actions: Personnel must not:
Use company resources, data, or relationships for personal gain.
Engage in activities that compete with Apprentix’s interests or those of our customers.
Accept gifts, favors, or payments from vendors or customers that could influence decisions, beyond nominal value (e.g., under $50).
Mitigation: Upon disclosure, the CEO will assess the conflict and determine appropriate actions, such as recusal from related decisions, reassignment, or termination of conflicting arrangements.
Customer Priority: Decisions affecting customer data, security, or service delivery (e.g., vendor partnerships, feature prioritization) must prioritize customer needs and contractual obligations over personal or external interests.
5. Procedures
Reporting: Disclosures are submitted via email to [email protected] or directly to the CEO, documented in a confidential log.
Review: The CEO reviews disclosures within 5 business days, consulting legal advisors if needed, and communicates decisions to the individual.
Documentation: All conflicts and resolutions are recorded and retained for 3 years, accessible only to authorized personnel.
6. Training
New employees and contractors receive training on this policy during onboarding, covering identification, disclosure, and avoidance of conflicts.
Annual refresher training is provided to all staff, integrated into our security awareness program, with examples relevant to SaaS operations (e.g., vendor impartiality, data handling).
Compliance is tracked via acknowledgment forms signed by participants.
7. Enforcement
Violations of this policy may result in disciplinary action, up to and including termination, and potential legal consequences if they breach customer trust or regulatory requirements (e.g., GDPR, CCPA).
The CEO oversees enforcement, with escalation to senior leadership as needed.
8. Contact
For questions or disclosures, contact:
Email: [email protected]
Phone: +1-303-900-2215
9. Updates
This policy is reviewed annually or upon significant changes, with updates communicated to staff and customers as needed.