This is a policy used by a company to establish the rules and guidelines for employees
to follow in case they have a potential conflict of interest with the company. The policy
sets forth the actions employees must take in case of a conflict, what a conflict actually
means, and which conflicts to avoid. Additionally, this policy provides that some
conflicts of interest can be waived by the human resources department or the
management of the company. This policy should be used by small businesses or other
entities that wish to establish a conflict of interest policy with their employees.
Conflict of Interest Policy
It is this company's policy that employees and others acting on behalf of employees must be free
from conflicts of interest that could adversely influence their judgment, objectivity or loyalty to
the company in conducting the company's business activities and assignments. The company
recognizes that employees may take part in legitimate financial, business, charitable and other
activities outside their jobs, but any potential conflict of interest raised by those activities must
be disclosed promptly to management.
If you have an avoidable conflict, you should notify the Human Resource Department. An
example of this would be a family member that works for a competitor or supplier. When you
notify Human Resources, a note will be placed in your file indicating the conflict. This will help
in avoiding any potential problems down the road between yourself and the company.
What it means
Request management approval of outside activities, financial interests or relationships
that may pose a real or potential conflict of interest. Remember that management
approval is subject to ongoing review, so you need to periodically update your
management on your involvement. Since it is impossible to ever look into the mind of
another person, this company requires employees to report actual conflicts of interest,
AND, IN ADDITION, any situation or relationship that might raise the appearance of a
conflict of interest.
Avoid personal relationships with other employees of this company, where parties in the
relationship may receive or give unfair advantage or preferential treatment because of the
Avoid actions or relationships that might conflict or appear to conflict with your job
responsibilities or the interests of this company.
Even the appearance of a conflict of interest can damage an important company interest.
Obtain necessary approvals before accepting any position as an officer or director of an
outside business concern.
Prior to serving on the board of directors of a bona fide charitable, educational or other
nonprofit organization, you are encouraged to advise your supervisor or your human
It NEVER is a conflict of interest to donate money to any political candidate or political
party, or to any bona fide charitable, educational, or other nonprofit organization, so long
as the employee's donation is made as an individual, and is not identified as coming from
an employee of this company.
What to avoid
Working with a business outside your work responsibilities that is in competition with
any of our company's business.
Accepting a gift that does not meet the standards in our company's employee
handbook/manual or in our policy statement regarding the acceptance of gifts.
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Having a direct or indirect financial interest in or a financial relationship with a
competitor, supplier or customer of our business. It is permissible to hold an insignificant
amount of stock in any publicly-held company.
Taking part in any company business decision involving a company that employs your
spouse or family member, unless this potential conflict has been disclosed, in writing to
Human Resources well in advance of the decision-making process, and unless each and
every other person who is part of the decision-making process has been so informed. In
addition to giving the above notice, an employee must ALSO receive a written
authorization/exception, allowing him or her to participate in the business decision.
Having a second job where your other employer is a direct or indirect competitor,
distributor, suppler or customer of this company.
Having a second job or consulting relationship that affects your ability to satisfactorily
perform your assignments at this company.
Using nonpublic company information for your personal gain or advantage, or for the
gain or advantage of another, including the purchase or sale of securities in a business this
company is interested in acquiring, selling or otherwise establishing (or terminating)
business relations with.
Investing in an outside business opportunity in which this company has an interest, except
for having an insignificant stock interest in publicly-held companies.
Receiving personal discounts or other benefits from suppliers, service providers or
customers that are not available to all employees of this company.
Receiving personal honoraria for services you perform that are closely related to your
work at this company. Your supervisor is authorized to give approval for occasional
honoraria, such as for a university presentation or symposium. This approval must be
requested in advance, in writing, and any such approval must also be in writing.
Having romantic relationships with certain