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1.1    Introduction
The organization is committed to achieving the highest standards of professionalism and ethical conduct in its operations and activities/expects its employees to conduct their business according to the highest ethical standards of conduct and to comply with all applicable laws. This policy is intended to increase awareness of potential conflicts of interest and establish a procedure for reporting them.

 

1.2    Conflict of Interest
Employees should always act in the best interest of the organization and not permit outside interests to interfere with their job duties.  The organization prohibits all employees from using their position with the organization or the organization 's relationship with its clients/customers/vendors/suppliers/contractors for private gain or to obtain benefits for themselves or members of their family.
For purposes of this policy, a potential conflict of interest occurs when an employee's outside interests (for example, financial or personal interests) interfere with the organization's interests or the employee's work-related duties. For example, a conflict of interest can occur when an employee is able to influence a decision that may result in a personal gain for the employee or the employee's family member as a result of the organization 's business dealings.


If you have a question about whether a situation is a potential conflict of interest, please contact the Ethics & Compliance Department.


1.3    Favors and Gifts
Business decisions should be made in the best interests of the organization. The organization prohibits employees from seeking or accepting any gifts, favors, entertainment, payment, or loans for themselves or their family members from any client/customer/vendor/supplier/contractor or other party doing business with the organization except in accordance with the Gifts & Entertainment policy and subject to the appropriate approvals set out therein. Cash should never be accepted. 


The organization also prohibits employees from giving any gifts or favors to any client/customer/vendor/supplier/contractor or other party doing business with the organization except in accordance with the Gifts & Entertainment policy and subject to the appropriate approvals set out therein. Cash gifts should never be made.
If an employee violates this policy, the organization will take prompt corrective action, including discipline, if appropriate.]


Please find a link to the Gifts & Entertainment policy here.


1.4    Reporting Procedure
If you become aware of any potential conflict of interest or ethical concern regarding your employment or another employee at the organization, you must promptly speak to, write, or otherwise contact your direct supervisor or, if the conduct involves your direct supervisor, the next level above your direct supervisor or Head of Department as soon as possible. You should be as detailed as possible. the organization will directly and thoroughly investigate all concerns regarding conflicts of interest. the organization will determine whether a conflict of interest exists and what action should be taken.
Please find a link to the Reporting procedure here.


1.5    No Retaliation
The organization prohibits any form of discipline, reprisal, intimidation, or retaliation for reporting a potential conflict of interest or violation of this policy or cooperating in related investigations.


1.6    Administration of This Policy
The Ethics & Compliance Department is responsible for the administration of this policy. If you have any questions regarding this policy or if you have questions about conflicts of interest that are not addressed in this policy, please contact the Ethics & Compliance Department.


1.7    Conduct Not Prohibited by This Policy
This policy is not intended to restrict communications or actions protected or required by state or federal law

 

1.8 Useful Links