Purpose
                                
                                The purpose of this policy is to protect the integrity of Sultan Institute of Management
                                Training (SIMT) by providing guidance on identifying, disclosing, and managing conflicts of
                                interest.
                                
                                Scope
                                
                                This policy applies to all staff, faculty, board members, subcontractors, and any other
                                relevant individuals associated with SIMT.
                                
                                Definitions
                                
                                • Conflict of Interest: Any situation where personal, financial, or other interests could
                                compromise or appear to compromise an individual’s decisions or actions on behalf
                                of SIMT.
                                
                                Duty to Disclose
                                
                                All individuals must disclose any potential conflicts of interest as soon as they become
                                aware of them. Disclosures should be made in writing to the designated Conflict of Interest
                                Officer.
                                
                                Review Process
                                
                                The Conflict of Interest Officer will review all disclosures and determine whether a conflict
                                of interest exists. If a conflict is identified, the officer will recommend steps to manage,
                                reduce, or eliminate the conflict.
                                
                                Managing Conflicts of Interest
                                
                                • Recusal: The individual may be required to abstain from decision-making processes
                                related to the conflict.
                                • Divestment: The individual may need to divest financial interests that create a
                                conflict.
                                • Restructuring Duties: Adjusting the individual’s responsibilities to mitigate the
                                conflict.
                                Confidentiality
                                
                                All disclosures and related discussions will be handled confidentially and shared only with
                                those involved in the review process.
                                
                                Consequences of Non-Compliance
                                
                                Failure to disclose a conflict of interest or comply with this policy may result in disciplinary
                                action, up to and including termination of employment or association with SIMT.
                                
                                Regular Review
                                
                                This policy will be reviewed annually to ensure its effectiveness and relevance. Amendments
                                will be made as necessary.