Conflicts of Interest

The Company recognizes an employee’s right to engage in activities outside of his/her employment that are of a private nature and unrelated to the Company’s business. However, if such activities relate to, or are competitive with, the Company’s business, then the employee must disclose the activities to a supervisor or Director. The Company can then assess actual conflicts and/or may be able to prevent a potential conflict from arising. For purposes of this policy, the term “employee” refers to all individuals bound by this policy, including, officers, directors, contractors, consultants etc.

An actual or potential conflict of interest exists when an employee is in a position to influence a decision that may result in personal gain for that employee or an employee’s close friend or relative as a result of the Company’s business dealings. Employees must avoid any situation which actually or potentially involves a conflict between their personal interests and the interests of the Company.

Examples of some conflicts of interest employees may face, include, but are not limited to, the following:

  • A conflict of interest may arise from an employee’s business or personal relationship with a customer, supplier, competitor, business partner, or other employee, if that relationship impairs the employee’s objective business judgment.
  • A conflict of interest may also arise when an employee and/or an employee’s friend or family member receives a personal benefit as a result of the employee’s position with the Company, including, any loan to, or guarantee of any obligation of, the employee and/or the employee’s friend or family member.
  • It is almost always a conflict of interest for a Company employee to work simultaneously for a competitor, customer or supplier. Thus, employees are not allowed to work for a competitor in any capacity, including as a consultant or board member. The best policy is to avoid any direct or indirect business connection with the Company’s customers, suppliers or competitors, except on the Company’s behalf.
  • Conflicts of interest are prohibited as a matter of Company policy, except under guidelines approved by the Board.Conflicts of interest are not always clear-cut, so employees should consult a supervisor if they have any questions in this regard.