Actonomics, Inc. is listed on the NYSE and has a code of conduct that among other features requires that "any transaction must be approved by the company's Audit Committee if the transaction involves an amount in excess of $10,000 between the company and a senior officer, or between the company and an entity in which its senior officer has a financial interest, is a director, or is an officer." Willis is Actonomics' CEO, a devoted alumnus of prestigious Ivy University, and a member of that institution's board of trustees. To make it more likely that he will be selected to be the next chair of Ivy's board of trustees, he persuades Actonomics' board of directors to approve a $5 million donation to establish the Willis Student Center at Ivy University. Are there reasonable arguments for concluding this transaction is not material