Employee Conflict of Interest Policy

Employee Conflict of Interest Policy

General

An employee shall not engage in any activities which create a conflict of interest, or might appear to conflict, with the employee’s responsibilities and obligations with the Company.  Good judgment of employees is essential, and no list of rules can provide for all of the possible circumstances that arise.  Decisions by employees involving a conflict of interest may create an appearance of impropriety which should be avoided.  This would include, but is not limited to, making any decisions; taking any actions; or seeking to influence any decision or action that may appear to create or does create a conflict of interest, whether involving the Company, the Company’s business or personnel actions involving any employee of the Company.

Best Interest of the Company

Each employee should act in the best interests of the Company, always using good judgment.

Suppliers of Goods or Services

An employee who has a direct or indirect interest (whether through family or business connections) in suppliers of products or services to the Company, or an interest in contractors or potential contractors who would do business with the Company, should not act or be involved in decisions with respect to that interest.  No employee should participate in a potential contract, partnership, or other business relationship with any party that the employee is discussing potential employment.

Disclosure

An employee should provide full disclosure of any business, personal or financial interest in which the employee might influence (or might appear to influence) his or her official decisions or actions on behalf of the Company.  Disclosure should be made on a timely basis in writing to the employee’s immediate supervisor.

Personal Gifts

Personal gifts from or to people whom the Company has a business relationship are discouraged.  Personal gifts of more than nominal value should be politely declined or returned to avoid any appearance of improper behavior.  Federal, state or local laws may also prohibit the solicitation or acceptance of gifts or money from contractors or other third parties...