Conflicts of
Interest
Employees have an obligation to
conduct business within guidelines that prohibit actual
or potential conflicts of interest. This policy
establishes only the framework within which The Sample
Company wishes the business to operate. 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. Contact the President for more information or
questions about conflicts of interest.
Transactions with outside firms
must be conducted within a framework established and
controlled by the executive level of The Sample Company.
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 designed to ultimately
benefit either 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 as a result of The
Sample Company's 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 The Sample 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.
Personal gain may result not only
in cases where an employee or relative has a significant
ownership in a firm with which The Sample Company does
business, but also when an employee or relative receives
any kickback, bribe, substantial gift, or special
consideration as a result of any transaction or business
dealings involving The Sample Company.
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