Conflict of Interest Policy

CONFLICT OF INTEREST POLICY

________ ("Employer")

Effective Date: ________

________ implements this conflict of interest policy (the "Policy") to ensure that all employees act ethically and with integrity in the course of their employment. For this purpose, ________ has established this policy to assist employees in the performance of their duties and to help them avoid potential conflicts of interest. This policy also provides guidance on the disclosure of potential conflicts that may arise.

PURPOSE AND CONTEXT

The purpose of this policy is to ensure that all employees conduct themselves in accordance with the employer's practices and procedures, maintain the confidentiality of all information acquired in the course of their employment and do not use their position for the benefit of conflicting interests or personal gain.

Employees should consider this policy as a detailed guide to help them avoid actual and potential conflicts. However, the examples contained in this policy are not intended to be an exhaustive list.

POLICY

________ expects from its employees to conduct themselves ethically and honestly in the course of their employment, as follows:

• Employees must comply with all applicable laws, rules and regulations;

• Employees must conduct themselves in a manner that does not compromise the reputation of ________;

• Employees must not have financial interests that conflict with those of ________;

• Employees must not affiliate with a company that conflicts with ________;

• Employees must avoid conflicts of interest or the appearance of conflicts of interest;

• Employees are required to disclose actual or potential conflicts to ________ as soon as possible;

• Employees must not use or share confidential information belonging to ________;

• Employees are not restricted from engaging in protected political activity outside of their job duties or in any other activity that is not in conflict with ________ or that does not reflect poorly on ________. However, ________ will ultimately determine whether a conflict of interest exists.

Employees involved in a conflict of interest situation will be subject to appropriate disciplinary action, up to and including termination, if the situation warrants.

EXAMPLES

The examples provided here should not be considered an exhaustive list, rather they are intended to assist employees in making decisions that do not lead to a conflict of interest and to help them become aware of situations where a potential conflict of interest should be disclosed.

Examples of potential conflicts of interest:

• When the employee or the employee's relative has an actual or potential financial interest that would affect the employee's ability to perform the duties impartially;

• When the employee is involved or has the potential to be involved in a business that is in direct competition with ________;

• When the employee accepts significant gifts or monetary compensation from third parties working with ________, such as customers or vendors;

• When the employee uses the employer's confidential information for personal gain;

• When the employee is otherwise likely to gain personal benefit from his or her relationship with ________ outside his or her position as an employee.

DISCLOSURE

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QUESTIONS

If employees have any questions, they may contact their immediate supervisor or the human resources department.

ACKNOWLEDGEMENT

I have received and reviewed the Conflict of Interest Policy and understand my obligations contained in this Policy. Failure to comply with this Policy may result in disciplinary action, up to and including termination.

I further understand that the employer reserves the unilateral right to make changes, future amendments, and modifications as they see fit.

_________________________
Employee Signature

_________________________
Employee Name (Print)

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Date