Conflict of Interest
Policy
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Purpose -
Definitions - Core Requirements -
Employee Role & Responsibilities -
Gifts, Favors, and Entertainment Offered by Employees -
Other Potential Employment Conflicts - Access to
Confidential Information - Management Role &
Responsibilities, Beyond Those as Employees
GENERAL POLICY
ABX is proud of those who work for us, and you can be proud
of the position of trust you hold. The reputation of the company in the
community and business world depends on the actions of those who work here. It
is expected that you will maintain the highest degree of integrity, honesty, and
professional manner in dealing with all customers and any other outside parties
such as suppliers, contractors, competitors, or any person doing business or
seeking to do business with ABX.
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PURPOSE
This policy outlines ABX’s expectations with regard to
receiving or giving gifts, favors, or entertainment, along with other potential
conflicts of interest.
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DEFINITIONS
Conflict of Interest - situations in which personal considerations or
financial gain may compromise, or have the appearance of compromising, your
professional judgment and result in actions or choices that conflict with the
best interest of the company.
Relatives - parents, siblings, children, spouses, grandparents, aunts,
uncles, nieces, nephews, first cousins, in-laws, or step-relations.
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CORE REQUIREMENTS
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Act in the best interest of the company when dealing with customers,
suppliers, contractors, competitors, or any person doing or seeking to do
business with ABX. |
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Tell management immediately if you own or have significant interest in, or
any member of your family owns or has significant interest in, any outside
company which does business or seeks to do business with ABX or is a
competitor. |
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Tell management immediately if you become aware of any situation that may
involve a conflict of interest for yourself or others. |
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Please direct any questions related to this policy to your management or
the Vice President, Corporate Secretary & General Counsel. |
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EMPLOYEE ROLE & RESPONSIBILITIES
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You are expected to conduct the company’s business with integrity and in a
manner that excludes any personal advantage or gain. |
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Your conduct with all outside parties should be in a strictly
professional, business-like manner to avoid any potential or actual conflict
of interest or favoritism. |
With regard to gifts, favors, and entertainment you are offered:
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Do not seek gifts, favors, or entertainment for yourself or for others.
|
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It is never permissible to accept a gift of cash or cash equivalent such
as stocks or other forms of marketable securities of any amount. |
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ANY gifts, favors, or entertainment offered MUST be reported to the next
level of management who will assist in deciding how the offers should be
handled. In most cases, gifts that can be shared with co-workers should be
shared. |
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Examples of gifts, favors, or entertainment situations that commonly come
up and are acceptable include, but are not limited to: |
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Lunch and/or dinner with vendors, sometimes including spouses.
-
Gifts of small value from vendors such as calendars, pens, pads, knives,
etc.
-
Tickets to events (such as sports, arts, etc.).
-
Overnight outings are acceptable under the condition that either
individuals from other companies or the vendor also attends.
-
Receipt of gifts of alcoholic beverages is discouraged.
-
Gifts of perishable items usually given during the holidays such as
hams, cookies, nuts, etc., are acceptable. You are encouraged to share with
co-workers if you receive them.
-
Day outings such as golf, fishing, and hunting are acceptable if the
vendor attends.
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Use of vendor’s facilities (vacation homes, etc.) by employees or
families for personal use is prohibited.
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Management should not accept gifts of more than limited value from those
under their supervision. |
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GIFTS, FAVORS, AND ENTERTAINMENT OFFERED
BY EMPLOYEES
You may give gifts, favors, and entertainment to others at Company expense,
only if they meet all of the following criteria:
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They are of limited value and will not be construed as a bribe or payoff;
|
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They are not in violation of applicable law and generally accepted ethical
standards; and public disclosure of the facts will not embarrass the company;
|
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Your Vice President approves the gift. |
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OTHER POTENTIAL EMPLOYMENT CONFLICTS
Other potential conflicts of interest include, but are not limited to the
following:
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Employment outside ABX - If you are employed outside
ABX, it should not
interfere, compete, or conflict with the company’s best interests or hinder
your ability to meet your responsibilities at ABX. |
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Volunteer Activities/Community Involvement -You are encouraged to be
involved in community, industry, and charitable activities, including
directorships in non-profit community organizations, as long as they do not
compete with or create demands that interfere with your job. |
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Employment of Relatives - ABX permits the employment and promotions of
qualified relatives of employees as long as such employment does not, in the
opinion of ABX, create actual or perceived conflicts of interest. |
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ACCESS TO CONFIDENTIAL INFORMATION
Revealing or using any confidential, personal information;
trade secrets; product information; information used to make decisions or future
plans; or any other information that might be contrary to the best interests of
the Company without prior authorization is forbidden. The misuse, unauthorized
access to, or mishandling of confidential information, particularly personnel
information, is strictly prohibited and will subject an employee to disciplinary
action up to and including termination.
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MANAGEMENT ROLE & RESPONSIBILITIES;
BEYOND THOSE AS EMPLOYEES
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Respond to employees’ concerns and provide guidance regarding potential or
actual conflict of interest issues. |
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Investigate immediately if you become aware of any situation that may
involve a potential or actual conflict of interest and take appropriate
action. |
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Take time to examine situations involving relatives to see if the
potential for conflict of interest does exist and, if so, how it will affect
the employee’s productivity in the job and the productivity of the department.
If a potential for conflict of interest does exist, discuss the situation with
your management and Human Resources to evaluate the appropriate steps to take.
|
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Your department may establish procedures to provide additional guidance to
you. |
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Updated March 8, 2004
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