CONFLICT OF INTEREST POLICY

The Conflict-of-Interest policy of this trust is set forth here, in Article Twelfth of this Declaration of Trust.  In the case where the Trustee is either Kenneth Wayne League or Janet Andrews Kling, no conflict-of-interest is possible as neither of these Trustees shall be paid any compensation and no trust assets will be spent on professional services, fees, taxes, benefits, insurance, etc., or any other form of expenses other than payments directly to existing charitable organization(s) as defined in section C of Article Forth of this Declaration of Trust.

In the case where the Independent Corporate Trustee is PNC Bank N.A. or its legal successor, the same organization that employs the Trustee will also have the authority to approve the compensation arrangements for the services provided by the Trustee and the independent contractors.  Therefore, to avoid any possible conflict-of-interest and/or a possible excess benefit transactions arising from this institution and individuals unavoidably being in a position to set their own compensation, the following procedures will be used:

a) The compensation for the services of the Independent corporate Trustee and other professional services provided (legal, tax, accounting, etc.) will be set at rates prescribed for similar Trust services in the Trustee’s standard compensation schedule last adopted prior to each time such compensation is charged, and, as such, will be monitored by responsible government watchdog agencies to verify that they are reasonable and within industry norms.

b) The Trustee shall avoid any arrangements or transactions in which the trust assets are used to create a beneficial private interest of the Trustee through business, investment or family, through direct or indirect remuneration as well as loans, investments, gifts, favors or arrangements such as partnerships, joint ventures or other transactions.  Any inadvertent beneficial private interest that may be discovered by the Trustee, contractors providing professional services to the trust, internal auditors, members of the public, governmental watchdog agencies or by any other means, shall be eliminated expediently and reported in full in the annual statement of the trust, including details of how the beneficial arrangement came to exist and how the situation was fully resolved.

c) The Trustee shall create and/or maintain a publicly accessible website that will allow free public access to Trust documents including the Declaration of Trust and all amendments to the Declaration of Trust, all IRS 1023 forms filed by the Trustee concerning the Trust, all IRS determination letters approving tax-exempt status concerning the Trust, all annual IRS 990PF forms concerning the Trust

d) The Trustee shall annually sign a statement which affirms that the Trustee:

• Has received a copy of the Conflict-of-Interest policy,
• Has read and understands the policy,
• Has agreed to comply with the policy, and
• Understands the trust is charitable and in order to maintain its federal tax exemption it must engage primarily in activities that accomplish one or more of its tax-exempt purposes.
• Has disclosed in writing in the annual public statement any beneficial private interest of the Trustee arising from the disposition of the trust fund assets, and how such an interest was discovered and how it was resolved.

e) All annual statements as well as Trustee compensation, fees, benefits, taxes, and other expenses will be recorded and publicly reported annually on the trust’s 990PF form and made freely available on the trust’s publicly accessible website.