Conflict of interest

Policy Elements

Conflict of interest may occur whenever an employee’s interest in a particular subject may lead them to actions, activities or relationships that undermine the company and may place it to disadvantage.

What is an employee conflict of interest?

This situation may take many different forms that include, but are not limited to, conflict of interest examples:

• Employees’ ability to use their position with the company to their personal advantage

• Employees engaging in activities that will bring direct or indirect profit to a competitor

• Employees owning shares of a competitor’s stock

• Employees using connections obtained through the company for their own private purposes

• Employees using company equipment or means to support an external business

• Employees acting in ways that may compromise the company’s legality

When an employee understands or suspects that a conflict of interest exists, they should bring this matter to the attention of management so corrective actions may be taken. Managers must also keep an eye on potential conflicts of interest of their subordinates. The responsibility of resolving a conflict of interest starts with the immediate manager and may reach senior management. All conflicts of interest will be resolved as fairly as possible. Senior management has the responsibility for the final decision when a solution can not be found. In general, employees are advised to refrain from letting personal and/or financial interests and external activities come into opposition with the company’s fundamental interests.

Policy Violation

In case the employee does not follow the Conflict of interest measures, the following actions will be taken:

• Disciplinary action: if a minor violation

• Termination of Employment: if a severe violation