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Conflict of Interest

You have a duty to avoid a conflict of interest or even the appearance of a conflict. A conflict of interest arises when you have a financial or personal interest that could interfere with your obligation to act in the best interests of the Company, or when you use your position with the Company for personal gain. If we don’t handle potential conflicts of interest properly, these situations can impact the decisions we make, create the appearance of a lack of fairness and integrity, and harm the Company’s reputation. Our Conflict of Interest Policy requires team members and Directors to disclose both actual and perceived conflicts of interest so that others do not question their integrity. 

Giving and Receiving Gifts

While giving and receiving business gifts and hospitality can build good working relationships and goodwill with customers and suppliers, it also can create a conflict of interest and an appearance of impropriety. We make business decisions based on the quality and value of the products and services offered.

All team members must:

  • Never exchange cash or cash equivalents (gift cards, checks or gift certificates) or loans.
  • Never exchange any gift or item of hospitality with a government official or commercial entity unless it’s expressly permitted by our policies.
  • Be sure to consult and follow any country-specific policies related to gift giving.
  • Always complete a Gift & Hospitality Approval and Disclosure Form for any exchange with a government official, regardless of value.
  • Give to a government official, in accordance with all policies, disclosure processes, and monetary limits.
  • Follow the gift and hospitality policies of our business partners and government officials. Not sure whether someone can accept a gift? Ask them about their policy and seek guidance from the Ethics & Compliance Department.
  • Follow all local laws, which may be more restrictive than U.S. law.

We exchange only reasonable gifts and hospitality with customers, suppliers, and other third parties and only for legitimate business purposes.

Political Activities

We follow the strict laws governing corporate political activities, lobbying and contributions. These laws vary around the globe. For this reason, only specific team members, who are authorized by the Government Affairs Department, may engage in efforts to discuss legislation or government policy with political officials on behalf of the Company or contact a government official on behalf of the Company for political purposes.

When you personally participate in the political process, you may only do so using your own money, time and resources.