As part of its conflict of interest policy, Nuvolution requires that directors, officers and employees decline to accept certain gifts, consideration or remuneration from individuals or companies that seek to do business with Nuvolution or are a competitor of it. This policy and disclosure form is intended to implement that prohibition on gifts.

Section 1

“Responsible Person” is any person serving as an officer, employee or a member of the board of directors of Nuvolution.

Section 2

“Family Member” is a spouse, domestic partner, parent, child or spouse of a child, or a brother, sister, or spouse of a brother or sister, of a Responsible Person.

Section 3

“Contract or Transaction” is any agreement or relationship involving the sale or purchase of goods, services or rights of any kind, receipt of a loan or grant, or the establishment of any other pecuniary relationship. The making of a gift to Nuvolution is not a “contract” or “transaction.”

Section 4

Prohibited gifts, gratuities and entertainment. Except as approved by the President of the Board or his designee or for gifts of a value less than $100 which could not be refused without discourtesy, no Responsible Person or Family Member shall accept gifts, entertainment or other favors from any person or entity which:

  1. Does or seeks to do business with Nuvolution or,
  2. Does or seeks to compete with Nuvolution or,
  3. Has received, is receiving, or is seeking to receive a Contract or Transaction with Nuvolution.


I certify that I have read the above policy concerning gifts, and I agree that I will not accept gifts, entertainment or other favors from any individual or entity, which would be prohibited by the above policy. Following my initial statement, I agree to provide a signed statement at the end of each calendar year certifying that I have not received any such gifts, entertainment or other favors during the preceding year.