Conflict of Interest

Conflicts of interest can arise in various business and personal contexts. Proactively managing these conflicts is essential to mitigate legal and regulatory risks while upholding our integrity, brand, and reputation. Conflicts of interest can be managed effectively by:

• Understanding what constitutes a conflict of interest; if you have questions, please consult with your manager or the People and Compliance team.

• Acting with integrity in all business activities.

• Considering potential conflicts of interest in all aspects of your work.

• Avoiding any activities, situations, or relationships that could compromise—or appear to compromise—your professional judgment.

• Seeking approval before engaging in any outside business, financial, or personal relationships that may pose a risk of conflict.

 

To help identify actual, perceived, or potential conflicts of interest, consider the following questions:

• Could I gain personal benefits, now or in the future, that might influence my objectivity?

• Do I hold any personal or professional views that could lead others to reasonably question my impartiality on a specific matter?

• Have I received a gift, benefit, or hospitality from someone who could be affected by my decisions?

• Is there a significant personal, professional, or financial relationship involved?

• Would I, or someone close to me, gain or suffer as a result of my decision or action?

• Could the company’s reputation be positively or negatively impacted by my decision or action?

• Proactively considering these questions helps ensure transparency and ethical decision-making across all aspects of our business.