Conflict of Interests


Employees must not engage in activities or transactions which may give rise, or which may be seen to have given rise, to conflict between their personal interests and the interest of the Company.

There is a likely conflict of interest if an employee:

  • Causes the Company to engage in business transactions with his/her relatives or friends;
  • Uses nonpublic information about the Company, its customers or suppliers for personal gains or to benefit relatives or friends (including securities transactions based on such information);
  • Has more than a modest financial interest in the Company’s suppliers, customers or competitors;
  • Receives a loan, or guarantee of obligations, from the Company (other than those specifically allowed) or a third party as a result of his/her position within the Company;
  • Competes, or prepares to compete, with the Company while still employed;
  • Performs work (with or without compensation) for a competitor, governmental or regulatory entity, customer or supplier of the Company, or does any work for a third party that may adversely affect his/her performance or judgment on the job or diminish his/her ability to devote the necessary time and attention to the duties assigned.