Resources Page - Conflicts of Interests v1


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.



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