Conflicts of Interest Policy

Conflicts of interest policy

1. General policy

Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation.
In order to avoid conflict, the company will not employ relatives of current employees if a problem could result from doing so. Please note that a relative, for this purpose, is defined as any legally recognized relationship recognized by the two parties.

In addition, other relationships between individuals that may also cause a problem will be considered carefully before a new client is hired. The Department or Branch Manager and Human Resources will jointly consent to whether or not a conflict of interest may arise due to a certain relationship.

Transactions with outside firms must be conducted within a framework established and controlled by the executive level of company. Business dealings with outside companies should not result in unusual gains for those firms. Unusual gain refers to bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, the employee, or both. Promotional plans that could be interpreted to involve unusual gain require specific executive-level approval.

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative because of company business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage.

No “presumption of guilt” is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to an officer of company as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.
Transaction with outside firm must be conducted with in the framework established and controlled by director level. Business dealings with outside firms should not result in unusual gains for those firms. Unusual gain refers to bribes; product bonuses, special fringe benefits, unusual price breaks, and other windfalls design ultimately benefit the employer, the employee, or both. Promotional plans that could be interpreted to involve unusual gain require specific director level approval.

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or far of relative because of company business dealings. For the purpose of this policy, a relative is any person whose relationship with the employee is similar to that of persons who are related by blood or marriage.

No “presumption of guilt” is created by the mere existence of a relationship with outside firms. However, if employees have any influence or transactions involving purchases, contracts, or leases, it is imperative that they disclose to the director as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.

2. What should do to conduct policy

• 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.
• Avoid personal relationships with other company employees where parties in the relationship may receive or give unfair advantage or preferential treatment because of the relationship.
• Avoid actions or relationships that might conflict or appear to conflict with your job responsibilities or the interests of 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.
• Contact the director of Community Affairs or your human resources manager (in other countries) and notify your management prior to serving on the board of directors of a bona fide charitable, educational or other nonprofit organization.

3. What should avoid to conduct this policy

• 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 company is interested in acquiring, selling or otherwise establishing or terminating business relations with.
• Investing in an outside business opportunity in which 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 company employees.
• Receiving personal honoraria for services you perform that are closely related to your work at company. Your supervisor should approve occasional honoraria, such as for a university presentation or symposium.
• Working with a business outside your company responsibilities that is in competition with any company business.
• Accepting a gift that does not meet the standards in the company.
• Having a direct or indirect financial interest in or a financial relationship with a company competitor, supplier or customer (except for insignificant stock interests in publicly-held companies).
• Taking part in any company business decision involving a company that employs your spouse or family member.
• Having a second job where your other employer is a direct or indirect competitor, distributor, suppler or customer of company.
• Having a second job or consulting relationship that affects your ability to satisfactorily perform your company assignments.
• Having romantic relationships with certain other employees where:
There is an immediate reporting relationship between the employees.
There is no direct reporting relationship between the employees but where a romantic relationship could cause others to lose confidence in the judgment or objectivity of either employee, or the relationship could cause embarrassment to the company.

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