SIGMA GAMMA RHO SORORITY, INC. Legal Issues of Sorority Operations Appendices. Bonita M. Herring, 23 RD International Grand Basileus

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1 SIGMA GAMMA RHO SORORITY, INC. Legal Issues of Sorority Operations Appendices Bonita M. Herring, 23 RD International Grand Basileus

2 Legal Issues of Chapter Operations Toolkit - Appendix of Forms 1. Records Retention and Document Destruction Policy (Sample) 2. Incident/Claim Reporting Form 3. Event Planning Checklist 4. Additional Insured Request Form 5. Athletic Event Participation Waiver 6. Third Party Vendor Contract 7. Local Property Ownership Reporting Form 8. Helpful Information on Raffles and Fundraising 9. Local Chapter Publicity Release & Various Board Governance Forms

3 Sigma Gamma Rho Sorority Records Retention and Document Destruction Policy (Sample) The purpose of this policy is to provide a system for complying with document retention laws, ensure that the chapter retains valuable documents, saves money, time, and space, protects the chapter against allegations of selective document destruction, and provide for routine destruction of non-business, superfluous, and outdated documents. The chapter Basileus is in charge of making sure that the appropriate officers are complying with the document retention schedule established herein. The chapter Basileus is also in charge of training her officers on this policy. Within 90 days of the end of the Sorority s fiscal year, the chapter Basileus shall make a list of the documents that have been sent to storage or destroyed. Lists of documents destroyed or stored shall be kept on file in the records of the chapter Grammateus. All documents, including electronic documents, that are no longer relevant to the chapter s business, should be destroyed every 60 days. Drafts of documents that have been finalized should not be retained. Personal notes should not be kept after they are no longer needed. Sigma Gamma Rho Sorority, Inc. has a legal duty to retain relevant documents which it knows or believes may be relevant to any legal action. This includes those documents that could lead to discovery of admissible evidence. Accordingly, all document destruction is automatically suspended when a lawsuit, claim, or government investigation is pending, threatened or foreseeable. Both paper document destruction as well as electronic document destruction should be suspended immediately. Documents that should be retained and the period of retention are listed in the attached schedule. The schedule should be reviewed annually to ensure compliance with the schedule and applicable law. The chapter s Board of Directors should annually include review of compliance with this document retention schedule, as a part of its internal audit. DOCUMENT DESCRIPTION Bank Reconciliations/Statements Checks Correspondence Customers/vendors Expenses/Purchase Documents.i.e. Account statements, receipts, canceled checks, invoices, credit card sales slips RETENTION SCHEDULE 5 years 5 years General rule 5 years; but if threat of litigation, or if possibility of a contract claim, until such threat is no longer viable 7 years

4 Gross Receipts Cash register tapes, bank deposit slips, Receipt books, invoices, credit card Charges, Form l099 Policies and other Guidelines Contracts Grant applications and awards Internal Audit Report Inventories of products, materials and supplies 7 years As long as current plus three years 4 years after contract term expires Life of grant plus 3 years, unless grant specifies differently 7 years Until all audit requirements are met. DOCUMENTS THAT SHOULD BE KEPT PERMANENTLY Charter All Editions of the Chapter s Bylaws and Standard Operating Procedures All Board and General Membership Meeting Minutes Organization IRS EIN Letter Form 990 and Any Schedules Deeds, Mortgages, Notes, Leases Audit Reports Appropriate Membership Records Year End Financial Statements

5 Sigma Gamma Rho Sorority INCIDENT/CLAIM REPORTING FORM When an incident arises at the chapter causing bodily injury or property damage to any person, the following information must be obtained immediately. This report is being prepared for submission to a Sigma Gamma Rho General Counsel, so please be thorough. Do not withhold reporting an incident to obtain all required information. Because timeliness is of the essence, report it immediately and send a copy within 24 hours to the National Headquarters of Sigma Gamma Rho Sorority, 1000 Southhill Drive, Suite 200, Cary, NC with copy to LegalAdvisor@SGRho1922.org. If the bodily injury is of a serious nature, a telephone call should also be made to (888) Chapter Name: Address: City, State, Zip: Phone #: Chapter President: Chapter Advisor: Date of Incident: Injured Party (IP): IP Address: IP City, State, Zip: IP Phone #: CA Address: CA Phone#: Witnesses & Phone #'s: Did Incident Happen Off Premises? (Leased or Rented) Yes No If yes, Owner's Name: Owner's Phone #: Owner's Address: Police Investigation? Yes No Name of Agency & Case #:

6 Description of Injury & Where Was Injured Party Taken: Description of What Happened (What, When, Where, How): Form Completed by (Name, Title, Telephone #, Address): Please add paper necessary if you should run short of room.

7 Sigma Gamma Rho Sorority EVENT PLANNING CHECKLIST MUST BE COMPLETED THIRTY DAYS PRIOR TO EVENT AND BE SUBMITTED WITH THE CONTRACT TO THE RESPECTIVE LEGAL ADVISOR. Chapter Name Chapter Location Graduate Chapter Undergraduate Chapter Total Number of Chapter Members I. DESCRIPTION OF EVENT A. Name of Event B. Purpose of Event C. Date of Event D. Location of Event Name Address Phone E. Additional Sponsor(s) of Event (All chapter presidents of sponsoring organizations must sign all contracts.) F. Beginning and Ending Time of Event G. Capacity of Facility Number of Chapter Members Attending Event Number of Guests Attending Event Number of Members of Co-Sponsor(s) Attending Event Number of Guests of Co-Sponsor(s) Attending Event Number of Chaperones Attending Event Total Attendance at the Event H. Indicate Type of Event Non-alcoholic event Alcohol served by a third party vendor (Graduate Chapters only)

8 I. What is the form of transportation to the event? If the event is out-of-town, explain the plan to ensure that all chapter members utilize the chartered transportation: J. Activities 1. Describe the event and the activities that are planned for the event. 2. Is this an athletic event? Yes No (If yes, all participants must complete the Athletic Participation Waiver.) II. RISK MANAGEMENT A. Guest List 1. Who is responsible for preparation of the guest list? 2. Explain how those in attendance will sign in and out of the event. B. Identification 1. Who is responsible for checking legal identification? 2. Who will be matching identifications to the guest list?

9 C. Security 1. Will there be security guards present? Yes No If so, how many guards will be present, and what are their responsibilities? 2. List members who will be responsible for monitoring: D. Entrance/Exits a. underage members and guests b. condition of members and guests entering the event c. members and/or guests acting inappropriately d. condition of property Verified that there is only one entrance to the Event. Yes No E. Third Party Vendor Please answer the below questions and if any answer is Yes please include the documentation with this request. 1) Are Certificates of Insurance obtained from vendors? Must show that vendor has off premise liquor liability coverage and non-owned and hired coverage. A. Liquor Legal Liability Yes No Not Applicable B. General Liability ($1M minimum) Yes No Not Applicable 2) Has vendor(s) provided proof of liquor license and temporary license to see on premises? Yes No Not Applicable

10 3) Is Sigma Gamma Rho (both the chapter and the National Sorority) shown as an additional insured on all certificates from vendors? Yes No Not Applicable 4) Have applicable permits and permission been obtained from authorities: A. College/University Yes No Not Applicable B. Fund Raiser Yes No Not Applicable 5) Has any written contract or agreement been reviewed by the Legal Advisor and signed for any part of this special event? Yes No Not Applicable 6) Has the vendor assumed in writing all responsibilities that any other purveyor of alcoholic beverages would assume in the normal course of business, including but not limited to: A. Checking identification card upon entry; B. Not serving minors; C. Not serving individuals who appear to be intoxicated; D. Maintaining absolute control of all alcoholic containers present; E. Collecting all remaining alcohol at the end of a function (no excess alcohol opened or unopened is to be given, sold or furnished to the chapter); F. Removing all alcohol from the premises. Yes No Not Applicable 7) Have you received any correspondence requesting proof of insurance for the event? Yes No Not Applicable 8) Refreshments Please note: No alcoholic beverages may be served at an undergraduate event No alcoholic beverages may be removed from the event area by members or guests The vendor must stop serving alcohol at least ½ hour prior to the conclusion of the event What type(s) and quantity of food and non-alcoholic beverages will be provided? III. SITE INSPECTION A. Pre-event condition of the property: Prior to the event, both parties have verified the condition of the property. Yes No

11 B. Reminders for post-event condition of the property: 1. Walk through with a manager at the conclusion of the event. 2. Sign off on the condition of the property. IV. EMERGENCY CONTACTS Have the following phone numbers available in case of an emergency: 1. Emergency personnel 2. Chapter President 3. Chapter Advisor 4. Greek Advisor 5. Headquarters (919) V. CHAPTER EVENT SIGNATURE APPROVAL A. This event was planned by: Name Office Signature Phone Date If applicable, this executive board officer oversaw the planning of the event: Name Office Signature Phone Date B. Sigma Gamma Rho Sorority, Inc. Headquarters Approval Name Office Signature Phone Date

12 Sigma Gamma Rho Sorority ADDITIONAL INSURED REQUEST FORM MUST BE COMPLETED THIRTY DAYS PRIOR TO EVENT AND BE APPROVED BY THE INTERNATIONAL HEADQUARTERS. Chapter Name: Your Name: Your Address: City, State, Zip: Phone: Address: FAX (if available): Additional Insured s Name: Address: City, State, Zip: Phone: Address: Date and Time of Event: Description:. Fax, Mail or the completed forms to: Sigma Gamma Rho Sorority, Inc. Attn: Rachel Morris 1000 Southhill Drive, Suite 200 Cary, NC Fax: (919) administrativeassistant@sgrho1922.org

13 Sigma Gamma Rho Sorority ATHLETIC EVENT PARTICIPATION WAIVER I, _, a registered participant in the activity sponsored by the Chapter of Sigma Gamma Rho Sorority, Inc. to be held on, understand and agree that I am participating in this event on my own free will and accord and that neither the chapter, nor Sigma Gamma Rho Sorority, Inc., nor its insurer(s) will share in or accept responsibility for any liability for bodily injury, property damage, medical expense or other loss that may arise from my participation in this event. I further understand and agree, and have no expectation that the chapter, or Sigma Gamma Rho Sorority, Inc. will provide any form of security or other measure of safeguarding for this event, as there is no reasonable expectation that such will be necessary. I further understand and agree that this event is considered a no-fault event by me, as well as the chapter, and Sigma Gamma Rho Sorority, Inc. and in the event of bodily injury, property damage, necessity of medical expenses or other loss, I agree to incur my own expenses without input or participation from the chapter, or Sigma Gamma Rho Sorority, Inc., or its insurer(s). I further grant an irrevocable and nonexclusive license to Sigma Gamma Rho Sorority, Inc. allowing the use of my name, voice, portrait, likeness, photograph and/or motion pictures, either alone or accompanied by other material, in any media and formats whether now known or later developed, for any purpose relating to developing and promoting the growth and mission of Sigma Gamma Rho Sorority, Inc. I hereby waive all my rights to inspect and approve the finished product and materials, their use or such visual, written or audio copy as may be used in connection therewith. Guest/Participant Chapter Representative Witness Witness Date Date This form should be only used for athletic events and completed for all participants. Chapters should keep the waiver forms for possible liability issues and record keeping purposes for five (5) years.

14 Sigma Gamma Rho Sorority Third Party Vendor Contract The following agreement is between the Chapter of Sigma Gamma Rho Sorority, Inc. ( SGR ), a non-profit corporation and ( Vendor ) of. 1. Duties a. Vendor is hereby engaged to provide the following bartending services during the SGR function described on Exhibit A to this agreement. b. Vendor assumes any and all responsibility for the following: i. Checking for proper identification upon entry ii. Not serving to minors iii. Not serving individuals who appear to be intoxicated or acting in a manner that could be detrimental to other persons iv. Providing safe transportation as appropriate v. Maintaining absolute control of all alcoholic containers present vi. Collecting all remaining alcohol at the end of a function (no excess alcohol - opened or unopened - is to be given, sold or otherwise furnished to the Chapter) vii. Removing all alcohol from the premises viii. Complying with the Rules (as defined below) 2. Vendor agrees to cash/credit sales only, collected by the vendor, during the function. 3. Vendor warrants and represents that they have all licenses required by the appropriate local and state authorities (A copy of the licenses must be attached) and all bartenders provided by Vendor (1) are certified; (2) are familiar with all federal, state, local, university and SGR laws, regulations, policies and guidelines applicable to the serving of alcohol at the SGR function ( The Rules ); (3) will perform their duties in accordance with the rules; and (4) will not consume or use illegal substances or alcoholic beverages while performing their duties. 4. Nothing contained in this Agreement or otherwise shall be construed to constitute Vendor as an employee or agent of SGR, it being intended that Vendor is an independent contractor solely responsible for the actions of Vendor and Vendor s employees and agents. 5. Compensation a. Vendor will be paid upon a per-job basis in accordance with Exhibit A and will be solely responsible for paying Vendor s employees and agents. 6. Indemnification/Insurance a. Vendor shall indemnify and hold harmless SGR, Sigma Gamma Rho Sorority, Inc. and their members, officers, and agents from liability of any claim arising out of injuries or damages caused by any act or omission of the Vendor or Vendor s employees or agents. b. Vendor will provide evidence of $1,000,000 General Liability and Liquor Legal Liability insurance with above Chapter and Sigma Gamma Rho Sorority, Inc. named as additional insured. c. Vendor agrees that its insurance shall be Primary on behalf of the Additional Insureds and any other insurance available to the Additional Insureds shall be excess and non-contributory. (Attach a copy of the vendor s certificate of insurance ).

15 7. Miscellaneous a. This agreement (including Exhibits) contains the entire agreement between the parties, and no amendments, changes, additions, or qualifications may be made or will be binding unless made in writing and signed by both parties. This agreement was made on the day of,. The agreement is for an event which will be on the day of,. The event will be held from to at. The undersigned agree that the above criteria have all been fulfilled and that all required documents have been attached to this Agreement. In witness thereof, SGR and Vendor have signed this Agreement to be effective as of the date set forth above. SGR Name: Title: Date: Vendor Name: Title: Date: NOTE TO PERSON SIGNING: By signing, you agree that you have the legal authority and right to bind Vendor to this contract. Date: EXHIBIT A Bartending Services SGR Function Place: Hours: Description: Compensation Number of Bartenders: Hourly rate or other fee(s): Payment terms:

16 Sigma Gamma Rho Sorority Local Property Ownership Reporting Form Chapters may find themselves exposed to unexpected liability when they own property. This form is for the use of any chapter who owns real property to report such ownership. It is imperative that any chapter who owns property submit this form to International Headquarters immediately. It is important to assess the ownership of property at the local level in order to better quantify the risk to Sigma Gamma Rho. We appreciate your assistance in this matter. Please take a few minutes to complete this survey and return it to: Rachel Morris, Executive Director Sigma Gamma Rho Sorority, Inc Southhill Drive, Suite 200 Cary, NC Executivedirector@sgrho1922.org Legal name of titled owner: Name of your property: Address of property: Contact name: Contact Contact phone number: Size of the facility: Approximate Square Footage: Stories: Is the facility sprinkled? YES NO Description of use: Do you lease your facility to third parties? YES NO Are you listed as an additional insured by your lessee? YES NO Do you utilize a lease or contract for use? YES NO Any work with youth at the facility? YES NO Is any day care provided? YES NO Do tenants reside in the facility? YES NO Annual revenue from use: Current Insurance Carrier: Type of Coverage: Policy Limits:

17 Sigma Gamma Rho Sorority Helpful Information Related to Raffles and Fundraising Arizona An organization that has qualified for an exemption from taxation of income under section , paragraph 1, 2, 4, 5, 6, 7, 10 or 11 may conduct a raffle that is subject to restrictions. A state, county or local historical society designated by this state or a county, city or town to conduct a raffle may conduct the raffle subject to conditions. California Charities and certain other private nonprofit organizations may conduct raffles to raise funds for beneficial or charitable purposes in the state. Forms for registering and reporting activities are provided on this web page. Colorado "Qualified organization" means any bona fide chartered branch, lodge, or chapter of a national or state organization or any bona fide religious, charitable, labor, fraternal, educational, voluntary firefighters', or veterans' organization operating without profit to its members that has been in existence continuously for a period of five years immediately prior to the making of an application for a license under this article and that has had, during the entire five-year period, a dues-paying membership engaged in carrying out the objects of said corporation or organization, and the Colorado state fair authority. Connecticut Raffles are allowed with licenses by educational or charitable, civic, service or social clubs, fraternal or fraternal benefit societies, veterans', church or religious organizations, volunteer fire departments or political parties or town committees. Georgia Certain nonprofit organizations may give away certain noncash prizes to advance the purposes of such nonprofit organization. Contact your County Sheriff s Office. Idaho RAFFLES -- DUCK RACES -- HOLIDAY CHRISTMAS TREE FUNDRAISERS. (1) It is lawful for any charitable organization to conduct raffles in accordance with the provisions of this chapter. Illinois "Raffle" means a form of lottery, as defined in Section 28-2 (b) of the "Criminal Code of 1961", conducted by an organization licensed under this Act, in which: (1) the player pays or agrees to pay something of value for a chance, represented and differentiated by a number or by a combination of numbers or by some other medium, one or more of which chances is to be designated the winning chance; (2) the winning chance is to be determined

18 through a drawing or by some other method based on an element of chance by an act or set of acts on the part of persons conducting or connected with the lottery, except that the winning chance shall not be determined by the outcome of a publicly exhibited sporting contest. Contact your County Clerk's Office. Indiana The organization must be non-profit [45 IAC (a)(1)] and either have been in active, continuous existence in Indiana for at least 5 years or be affiliated with an Indiana parent organization which has been operating in Indiana at least 5 years [45 IAC (a)(2)]. Also, the organization must be exempt from taxation under either an Indiana or Federal statute [45 IAC (a)(3)]. Iowa Any individual or group conducting gambling activities in Iowa must obtain a gambling license from the Iowa Department of Inspections and Appeals, and have a permanent sales tax permit with the Iowa Department of Revenue. Kentucky KRS is amended to read as follows: (1) Any charitable organization conducting charitable gaming in the Commonwealth of Kentucky shall be licensed by the office. A charitable organization qualifying under subsection (8) of this section but not exceeding the limitations provided in this subsection shall be exempt from the licensure requirements when conducting the following charitable gaming activities: (a) Bingo in which the gross receipts do not exceed a total of twenty-five thousand dollars ($25,000) per year; (b) A raffle or raffles for which the gross receipts do not exceed twenty-five thousand dollars ($25,000) per year; and (c) A charity fundraising event or events that do not involve special limited charitable games and the gross gaming receipts for which do not exceed twenty-five thousand dollars ($25,000) per year. However, at no time shall a charitable organization's total limitations under this subsection exceed twenty-five thousand dollars ($25,000). Louisiana Charitable Gaming is defined as non-profit organizations raising funds through games of chance where all net proceeds are contributed to bona fide charitable causes. Maine Organizations eligible. Notwithstanding other provisions of law, the Chief of the State Police may issue a license to operate a game of chance to an agricultural society eligible for a stipend under Title 7, chapter 4, or to a bona fide nonprofit charitable, educational, political, civic, recreational, fraternal, patriotic or religious organization, or to a volunteer fire department or to an auxiliary of any of these organizations, any of which must be founded, chartered or organized in this State for a period of not less than 2 consecutive years before applying for a license.

19 Maryland A charitable organization may conduct a raffle of real property if it is for the exclusive benefit of the organization and the prize awarded is real property to which the charity holds title or to which the charity has the ability to transfer title. A charity can not conduct more than two (2) raffles in a calendar year. Massachusetts 940 CMR shall apply to any raffle conducted under M.G.L. c. 271, 7A in which the value of the prize or prizes to be awarded exceeds $10,000 or in which the ticket price exceeds $ Michigan Raffle is a game of chance where raffle tickets are sold, a winner(s) is determined by randomly drawing a ticket stub from a container, and a prize is awarded. Almost all raffles need to be licensed. If your organization is holding a or a "drawing for a door prize," these are raffles and should be licensed. Mississippi The Mississippi Legislature legalized Charitable Gaming with the passage of the Charitable Bingo Law during its regular session in The law went into effect October 1, Missouri In 1998 Missouri voters adopted a constitutional amendment allowing raffles and sweepstakes to be sponsored by groups recognized under federal law as charitable or religious. Montana Before conducting a raffle, refer to of the Montana Code Annotated and of the Administrative Rules of Montana. Nebraska More information at Nevada NRS New Hampshire A charitable organization may conduct a raffle to promote the purpose for which it was organized, in the manner hereinafter provided, and not otherwise. New Jersey The Commission oversees the operation of games conducted pursuant to the Bingo and Raffles Licensing Laws by approximately 12,000 charitable, educational, religious, patriotic, public-spirited organizations and senior citizen associations and clubs organizations

20 currently registered to conduct legalized games of chance, such as bingo games and raffles, throughout the state. New Mexico Properly qualified organizations may conduct certain games of chance in New Mexico for fundraising purposes on a limited basis. New York Raffle tickets may be sold and drawings conducted on an authorized organization s premises; during its licensed casino nights or carnival games of chance events; and during its licensed bingo occasions, in accordance with Section (b)(5) of the Board s Rules and Regulations. North Carolina It is lawful for any nonprofit organization or association, recognized by the Department of Revenue as tax-exempt pursuant to G.S (a), and for any government entity within the State, to conduct raffles in accordance with this section. North Dakota Gaming Division regulates, enforces and administers charitable gaming in North Dakota. Ohio To amend sections and of the Revised Code to allow a charitable organization to conduct games of chance and raffles three times per year at certain food service facilities. Oregon For charitable and fraternal organizations wishing to conduct raffles in Oregon. Pennsylvania A raffle lottery game is a lottery game that is of limited duration, having preestablished and announced beginning, end sale, and drawing dates. A limited number of tickets or chances, each unique from all others, will be offered for the opportunity to win one of a number of predetermined and announced prizes. Rhode Island Games of Chance must be conducted by a charitable organization. Only members of the organization can be involved in the control and management of the game. All proceeds, minus the expenses of the game, must be used for a charitable purpose. Tennessee Authorized types of games include raffles, reverse raffles, cakewalks, and cakewheels.

21 Texas The Charitable Raffle Enabling Act, effective January 1, 1990, permits "qualified organizations" to hold up to two raffles per calendar year, with certain specified restrictions. Vermont Non-Profit Organizations Can Hold Raffles and Lotteries. Vermont law generally prohibits gambling but allows nonprofit organizations, including municipalities to organize and execute games of chance for the purpose of raising funds for civic undertakings. Virginia The conduct of charitable gaming, like the lottery and wagering on horse racing, is an exception to the general rule of law in Virginia prohibiting gambling. Washington Licensed and Unlicensed Raffles. West Virginia CHAPTER 47. REGULATION OF TRADE. ARTICLE 23. CHARITABLE RAFFLE BOARDS AND GAMES. Wisconsin After paying a $25 license fee, qualified charitable groups may conduct up to 200 raffle drawings during a one year period.

22 Sigma Gamma Rho Sorority, Inc. Chapter Board of Directors Code of Conduct The following are standards of conduct which are expected from members of the Chapter s Board: Board members shall not engage in conduct which harms the Chapter or its membership. Board members shall not engage in any activities that conflict with their fiduciary, ethical, and legal obligations to the Chapter. Board members shall take care to ensure proper stewardship of Chapter funds, including timely reports on the use and management of such funds. Board members are responsible for determining policies and procedures necessary for maintenance of effective Board operations. Board members are expected to be in attendance at all scheduled Board meetings. Board members are expected to carry out their assigned officer and/or committee assignment, and to timely prepare and present related written reports on such activities. Board members shall participate in all fund raising activities, and are expected to use their resources and contacts to promote the achievement of fund raising goals. Board members are expected to actively participate in solicitations of support from local sources outside of the Sorority, for support of its community service programs; its auxiliaries and foundation, and in the evaluation of such programs, auxiliaries, and foundation. Board members shall not discuss the confidential proceedings of the Board outside Board meetings. Board members shall not interfere with the duties of the Chapter basileus or undermine the Chapter basileus s authority. Board members shall recognize that all authority is vested in the Board when it meets in session and not with any individual member.

23 Sigma Gamma Rho Sorority, Inc. Chapter Board of Directors Conflict of Interest Policy/Procedure Article I Purpose This conflict of interest policy is adopted for the purpose of protecting the Chapter s interest when it is contemplating entering into transactions or arrangements that might benefit the private interest of an officer, Board member, or member of a committee with Board delegated powers. It is intended to supplement, but not replace any applicable laws governing conflict of interest. Article II Definitions 1. Interested Person Any Board member, officer, member of a committee with Board delegated powers, who has a direct or indirect financial interest, as defined below, is an interested person. 2. Financial Interest A person has a financial interest if the person has, directly or indirectly, through business, investment, or family a. An ownership or substantial investment interest in any entity with which the Chapter has a transaction or arrangement, or b. A compensation arrangement with the Chapter or with any entity or individual with which the Chapter has a transaction or arrangement, or c. A potential ownership or substantial investment interest in, or compensation arrangement with any entity or individual with which the Chapter is negotiating a transaction or arrangement. Compensation includes direct and indirect remuneration as well as gifts or favors that are substantial in nature. A financial interest is not necessarily a conflict of interest. A Conflict of interest may exist when the interests or concerns of an interested person may be seen as competing with the interests or concerns of the Chapter. A conflict of interest may exist where an interested person or a relative or business associate of an interested person directly or indirectly profits as a result of a decision entered into by the Chapter. A conflict may also exist where an interested person, relative, or business associate of an interested person obtains a non-financial benefit or advantage that she/he would not have obtained absent the relationship with the Chapter; or where her/his duty or responsibility owed to the Chapter conflicts with a duty or responsibility owed to another organization. Article III Procedures 1. Duty to Disclose In connection with any actual or possible conflict of interest, an interested person must disclose the existence of his or her financial interest and must be given the opportunity to disclose all material facts to the Board, and/or where applicable, to any appointed committee

24 delegated powers to consider the proposed transaction or arrangement. 2. Determination of Whether A Conflict Exists a. After disclosure by an interested person of the financial interest (or other possible non-financial benefit or advantage) respecting a transaction or arrangement and disclosure of all material facts, and after discussions with the interested person, the interested person shall leave the Board meeting while the determination of a conflict of interest is discussed and voted upon. The Board shall decide whether the financial interest or other non-financial advantage or benefit disclosed rises to the level of a conflict of interest. b. The interested person may make a presentation at the Board meeting. After such presentation, she shall leave the meeting during the discussion and vote. c. Where it finds that a conflict exists, the Board may approve the transaction or arrangement, if it determines by a vote of a majority of the Board (where a quorum of disinterested members is present, and the interested person is not present at the time of the vote) that the transaction or arrangement (1) is in the best interest of the Chapter (2) is fair and reasonable, and (3) a more advantageous transaction or arrangement is not reasonably attainable under circumstances that would not give rise to a conflict. 3. Recordkeeping The Board minutes should reflect a record of all Board consideration of questions of conflict of interest. All votes taken by the Board should be specifically recorded, as well as any pertinent discussion regarding any matters referred to in this article (Article III). Article IV- Annual Disclosure Statements 1. Each officer, Board Member, members of a committee with Board delegated powers, shall receive a copy of the Conflict of Interest Policy and sign the Chapter s Conflict of Interest Compliance and Disclosure Statements, affirming that she (1) has received a copy of the policy, (2) has read and understands the policy, (3) has agreed to comply with the policy, and (4) understands that the Chapter maintains a charter with a not-for-profit corporation and that in order to maintain its status and exemptions it must comply with all applicable federal and state laws, and regulations. 2. The chapter basileus shall annually distribute to each person covered by the Chapter s conflict of interest policy, a copy of the policy accompanied by a copy of the Compliance Statement and the Disclosure Statement for execution. Distribution should be made on or before July 31 of each calendar year. The statements should be signed and returned to the chapter s anti-grammateus within fifteen calendar days of receipt. The chapter basileus shall review the executed statements and provide a report to the Executive Board. Copies of the executed Compliance and Disclosure statements shall be kept on file in the national headquarters. 3. The Board shall include as a part of any periodic management review and evaluation of operations, a review of the operation of the conflict of interest policy and procedure. Article V- Violations of the Conflict of Interest Policy If the Board has reasonable cause to believe that a person covered by this policy has failed to disclose an actual or possible conflict of interest, it shall inform the person of the basis for such belief, and afford the person an opportunity to explain the alleged failure to disclose. If the Executive Board in fact finds that the policy has been violated, it shall immediately take corrective action. Such action should be recorded in the minutes of the Board.

25 Sigma Gamma Rho Sorority, Inc. Chapter Board of Directors Conflict of Interest Policy Annual Compliance Statement I have received and carefully read the Sigma Gamma Rho Sorority, Inc. Conflict of Interest Policy. By signing this affirmation of compliance, I hereby affirm that I understand and agree to comply with the Conflict of Interest Policy. I also understand that the Sorority is a nonprofit organization, and that in order to maintain the exemptions that it enjoys, it must abide by all applicable federal and state laws, and regulations. Except as otherwise indicated in the Disclosure Statement and attachments, if any, I hereby state that I do not, to the best of my knowledge, have any conflict of interest that may be seen as competing with the interests of the Sorority, nor does any relative or business associate of mine have such an actual or potential conflict of interest. If any situation should arise in the future which I think may involve me in a conflict of interest, I will promptly and fully disclose the circumstances to the Executive Board of the Sorority. I further certify that the information set forth in the Disclosure Statement and any attachments is true and correct to the best of my knowledge, information, and belief. Name (print) Signature Date

26 Sigma Gamma Rho Sorority, Inc. Chapter Board of Directors Conflict of Interest Disclosure Statement NAME (print) Please indicate below any actual or potential conflicts of interest based on your review of Article III of the Sorority s conflict of interest policy. A conflict may exist where an interested person, or a relative or business associate, directly or indirectly financially benefits or profits as a result of a decision made or transaction entered into by the Sorority. A conflict may also exist where an interested person, relative, or business associate obtains a nonfinancial benefit or advantage that she/he would not have obtained absent his or her relationship with the Sorority, or where his or her duty or responsibility owed to the Sorority conflicts with a duty or responsibility owed to some other organization. DO YOU HAVE ANY ACTUAL OR POTENTIAL CONFLICT OF INTEREST TO DISCLOSE, TO THE BEST OF YOUR KNOWLEDGE, BELIEF, AND INFORMATION? YES NO If Yes, please describe (Your response should refer to any current relationship or transaction, or any which has taken place within the last twelve months you may attached additional sheets if necessary): Signature Date

27 Sigma Gamma Rho Sorority, Inc. Chapter Confidential Reporting of Misuse of Sorority Resources Any member of the staff, Board, or member of Sigma Gamma Rho Sorority, Inc., who has information about known or suspected financial improprieties, or misuse of the organization s resources, or other ethical problems, is encouraged to report their concerns to the chapter Basileus, unless she is alleged to have committed misconduct. In such scenario, the report shall be made to the chapter s board of directors. In situations of a very hostile nature, the report can be made to the Regional Syntaktes. The person reporting the alleged misconduct may choose to do so anonymously, via mail or through other means of communication that protects the individual s identity. All efforts will be made to protect the confidentiality of those who report financial improprieties and choose not to do so anonymously. However, in certain situations, legal requirements may make it impossible to keep the individual s identity confidential. In accordance with the Sarbanes-Oxley Act, no retaliatory organizational action will be taken against those who report truthful information about the commission or possible commission of any federal offense to a law enforcement officer, even if the person incorrectly believes that a violation has occurred. Law enforcement officer, is defined by the Sarbanes-Oxley Act as including any officer or employee of the Federal Government authorized under law to engage in or supervise the prevention, detection, investigation, or prosecution of an offense. This policy provides a strong, and credible means of redress for those who have concern about the misuse of the Chapter s resources. This policy does not condone allegations in the media, or in public places by members or officers, that will result in ridicule, contempt, or discredit of the Sorority.

28 Sigma Gamma Rho Sorority, Inc. Chapter Board of Directors Code of Conduct and Reporting of Misuse of Sorority Resources Annual Compliance Statement I have received and carefully read the Sigma Gamma Rho Sorority, Inc. Board of Directors Code of Conduct and Reporting of Misuse of Sorority Resources Policies. By signing this affirmation of compliance, I hereby affirm that I understand and agree to comply with these policies. I also understand that the Sorority is a nonprofit organization, and that in order to maintain the exemptions that it enjoys, it must abide by all applicable federal and state laws, and regulations. Except as otherwise indicated in the Disclosure Statement and attachments, if any, I hereby state that I do not, to the best of my knowledge, have any knowledge of any existing violations to these policies. If any situation should arise in the future which violates these policies, I will promptly and fully disclose the circumstances to the chapter s executive Board. I further certify that the information set forth in this Compliance Statement and any attachments is true and correct to the best of my knowledge, information, and belief. Name (print) Signature Date