SAMPLE
written conflicts of interest policy that should be incorporated within the company
employee manual. Conflicts
of Interest
At ("Company Name") there can be no room for a conflict
of interest between an employee's personal affairs and company business. ("Company
Name") employees may not engage in any business activity or investment that
could prevent the employee from impartially performing his or her duties at ("Company
Name"). This requires that each employee avoid any actual or apparent conflict
of interest between personal affairs and company business. Any time a conflict
appears, or the possibility exists that such conflict might develop, employees
should discuss and resolve the matter with their supervisor or Human Resources
Manager. Examples
of some clear conflict of interest situations which must be avoided are:
Any
financial interest (other than small amounts of stocks or bonds in publicly traded
companies) in any supplier, customer, or competitor;
Any consulting, contract,
or employment relationship with any customer, supplier, or competitor;
Any
outside business activity which is competitive with any of ("Company Name")'s
businesses;
The receipt of gifts, gratuities (see the policies set out
in these guidelines dealing with gifts and gratuities), or excessive entertainment
from any company with which we have business dealings;
Any outside activity
of any type which is so substantial as to call into question your ability to devote
appropriate time and attention to your job responsibilities with ("Company
Name");
The service on any board of directors of any customer, supplier,
or competitor unless such board service has been disclosed to ("Company Name")
and approved by the General Counsel;
Being in the position of supervising,
reviewing, or having any influence on the job evaluation, pay, or benefits of
any close relative or person with whom you have a close personal relationship
within ("Company Name") or approving, authorizing, or processing a transaction
that was prepared, approved, or initiated by such a person;
Taking advantage
of an opportunity which you learned of in the course of your employment with ("Company
Name"), such as acquiring property that ("Company Name") may be
interested in; and
Selling anything to ("Company Name") or buying
anything from ("Company Name") (except through any normal program of
disposal of surplus ("Company Name") property which is offered to all
employees in general).
Anything that presents a conflict for you would
probably also present a conflict if it relates to a member of your family or someone
with whom you have a close personal relationship. For example, ownership of stock
in competitors or suppliers, or receipt of gifts or entertainment by members of
your family or spouse, would likely create the same conflict of interest as if
you owned the stock or received the gift. As
a ("Company Name") employee, you may not conduct business on behalf
of ("Company Name") with a member of your family, or a business organization
in which you or a family member has a significant financial interest, or is a
stockholder, director, officer, creditor, or proprietor. Employees
are expected to disclose to their manager, in writing, any potential conflict.
No employee may engage in any activity involving a potential conflict unless they
have a written, signed statement from their manager advising the employee that
the activity does not violate ("Company Name") policies. No manager
may give such a statement unless approved by the head of the Human Resources department. |