ANTI-DISCRIMINATION POLICY
Maiden Labs does not discriminate on the basis of race, ethnicity, national origin, ancestry, religion or creed, legal status, gender identity, sexual orientation, gender expression, age, ability, physical appearance, veteran status, military obligations, or marital or family status. This policy applies to our hiring practices, Board development, opportunities for advancement, selection of vendors, provision of services, and relationships with research collaborators.

CONFLICT OF INTEREST POLICY
1.  Purposes and Principles
The purpose of the conflict of interest policy (“the Policy”) is to protect Maiden Labs’ (“Maiden Labs” or “the Organization”) research independence and integrity and tax-exempt interest when it is considering entering into a research assignment, a transaction or any arrangement that might benefit the private interest of an officer or Director of the Organization, another person in a position of influence in the Organization or as a contractor, or someone or group closely related to an officer or Director (“Person with Interest“). This Policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and tax-exempt organizations, or any additional grant-specific requirements, and is compliant with 42 CFR 50.601, 604.

Maiden Labs acknowledges that as the recipient and sub-recipient of influential research grants and sub-grants, it has a heightened responsibility to ensure the integrity of its work and its reputation for independence. Especially because of the scholarly and independent nature of our charitable and educational services, we believe even the appearance of conflict can be contrary to the Organization’s Section 501(c )(3) mission and its integrity as an independent research institute, even if there is in fact no conflict. We also recognize that conflicts occur because the people associated with the Organization are likely to have multiple interests and affiliations and various positions of responsibility that overlap. In these situations, a person sometimes will owe similar or identical duties of loyalty to two or more corporations and organizations.

2. Duty of Loyalty.
Our Policy begins with the duty of loyalty owed to Maiden Labs and its charitable and educational mission by each member of the Board of Directors and the staff and contractors of the Organization. The duty of loyalty generally requires a Director or staff/contractor to defer to the interests of the Organization over the Director’s or individual’s interest or the interests of other private parties. In addition, Directors and staff/contractors of Maiden Labs must avoid acts of self-dealing that may adversely affect the tax-exempt status of the Organization, or its independence as a research institute, give rise to any sanction or penalty by a governmental authority, or create doubt regarding Maiden Labs’s integrity and independence.

3. Duty to Disclose.  
In connection with any actual or possible conflict of interest with respect to a transaction or payment, a Person with Interest must disclose to the Board of Directors or to the ED/CEO the existence of any financial interest in the transaction. The Person with Interest will be given the opportunity to explain the potential conflict, including their financial interest in the relevant transaction or relationship. This shall be done as quickly as possible once the potential conflict has been raised.
The Board of Directors or the ED/CEO as appropriate then will determine whether a conflict exists; and, if they determine a conflict exists, how to resolve the conflict in keeping with the Organization’s tax-exempt status, research independence, and integrity, and public benefit commitment. They may decide (1) that the potential conflict will not impact or influence the individual’s performance or compensation with the Organization or the Organization’s relationship with any 3rd party, and the individual may remain with the Organization; or, (2) the potential conflict reasonably could impact or influence a matter from which the individual may derive an inappropriate financial benefit or compromise the integrity of the Organization.
In the event the Organization is the sub-recipient of a grant award, it will notify the institutional top awardee of any financial conflict of interest found after its own review within 5 business days of that determination, in compliance with 42 C.F.R. 50-604(c), Subpart F. The Organization shall follow any additional protocols requested by the institutional awardee in any such review in keeping with its own conflict of interest policy.  

4.  Compensation.
In any compensation matter involving a Person with Interest, that person will abstain from consideration of and voting on their compensation. Any compensation for a Person with Interest will be in keeping with prevailing market rates for comparable work, as all compensation will be determined. The Board and/or staff will maintain records of comparable value due diligence in any review subject to this Policy.

5.  Affirmation.
Each member of the Board of Directors and officers, on assuming their positions, shall sign a statement which affirms such person:
(a)   Has received a copy of this Conflict of Interest policy,
(b)   Has read and understands the policy,
(c)   Has agreed to comply with the policy, and
(d)   Understands that the corporation is charitable and engages in research and other activities dedicated
       to the public benefit which accomplish one or more of its tax-exempt purposes.

Relevant officers of the Organization shall ensure that Board Directors and staff or contractors are provided with a copy of the Policy.

6.  Violations of Conflict of Interest Policy.
If the Board or the ED/CEO has reasonable cause to believe a Person with Interest has failed to disclose actual or possible conflicts of interest, it shall inform the person of the basis for this belief and afford the person an opportunity to explain the alleged failure to disclose.
If, after hearing the person’s response and after making further investigation as warranted by the circumstances, the Board or the ED/CEO determines the person has failed to disclose an actual or possible conflict of interest, it shall take appropriate corrective action in compliance with Section 3(c), above.