1. Introduction

At [Company Name], we are committed to maintaining the highest standards of ethical conduct and professional integrity. This Conflict of Interest Policy is designed to provide clear guidelines for all employees, managers, executives, and board members to identify, disclose, and manage potential conflicts of interest.

1.1 Purpose

The purpose of this policy is to protect the integrity of our company's decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of all our employees, managers, and board members.

1.2 Scope

This policy applies to all employees, managers, executives, board members, contractors, and volunteers of [Company Name], as well as to third parties who may be in a position to influence the company's decisions or operations.

2. Definition of Conflict of Interest

A conflict of interest arises when an individual's personal interests – family, friendships, financial, or social factors – could compromise their judgment, decisions, or actions in the workplace. Conflicts of interest may be actual, potential, or perceived.

2.1 Types of Conflicts

• Financial Conflicts: When an employee or their family member has a significant financial interest in a competitor, supplier, or customer of the company.
• Personal Relationships: When personal relationships between employees or with external parties could affect professional judgment or create favoritism.
• Outside Employment: When an employee's secondary employment or business interests compete with or affect their work at [Company Name].
• Gifts and Entertainment: When accepting gifts, favors, or entertainment could influence business decisions.
• Use of Company Resources: When company assets, including intellectual property or confidential information, are used for personal gain.
• Board Memberships: When serving on the board of another organization could create divided loyalties.

3. Employee Responsibilities

3.1 Disclosure

All employees are required to disclose any situations that may give rise to a conflict of interest. Disclosures should be made promptly and in writing to the immediate supervisor or the Human Resources department.

3.2 Annual Declaration

Employees in sensitive positions or at management level and above are required to complete an annual Conflict of Interest Declaration Form, disclosing any potential conflicts or confirming that no conflicts exist.