We Avoid Conflicts of Interest

Our Principle

We do not let personal interests interfere with making business decisions on behalf of the Company.

Why It Matters

Avoiding conflicts of interest helps us make unbiased, smart decisions that benefit our business. Using good judgment allows us to pursue our goals without distraction or divided loyalty. This builds trust with our colleagues, customers, business partners, and communities.

Understanding Conflicts of Interest

We avoid putting ourselves in situations where our loyalties to friends or family could improperly influence our judgment. Examples include reporting relationships, and hiring friends or family members as employees or
suppliers

We ensure that personal and family investments do not get in the way of our decisions. Avoid taking a personal financial interest in any transaction in which the Company is interested and avoid making an undisclosed investment in a supplier, customer, or competitor.

We do not take personal advantage of business opportunities we discover in the course of our work, as they belong to the Company. Avoid using proprietary information or contacts acquired on the job for personal gain. Never compete with the Company. Always bring business opportunities to your manager’s attention.

We ensure that outside jobs or other activities don’t interfere with our obligations to the Company. Avoid any outside activities that compete with the Company, interfere with our job responsibilities or performance, require attention while at work, involve the use of our resources, or involves working for a competitor, supplier, or customer of the Company.

How We Live Our Values

  • Being Alert

    Being alert for situations where our personal activities or relationships could interfere with our objectivity.

  • Disclosing Conflicts

    Disclosing all actual or potential conflicts of interest through the Conflicts of Interest Disclosure Process.

  • Removing Ourselves

    Removing ourselves from situations where our objectivity could be questioned.

  • Supporting the Outcome

    Supporting the outcome of a conflict resolution.

Food for Thought

Disclosing a conflict of interest prevents you from accidentally acting without objectivity, or without considering the interests of the Company. The perspectives of managers and the Ethics and Compliance Office help you examine the situation, consider options, weigh consequences, and select an appropriate course of action.

Know the Code

We are looking for a company to provide employee contracting services. My sister owns a company that provides this exact service and would provide us with a good deal. Can I hire my sister’s company?

No. Hiring this company could create a conflict of interest. Disclose the relationship with your manager and remove yourself from the decision-making process. Your sister’s company may compete along with other vendors, as long as you are not involved in the selection process.

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