Policy

1. Introduction

[Company Name] is committed to upholding the utmost levels of integrity and transparency. This employee conflict of interest policy aims to assist employees in recognizing, disclosing, and managing any personal interests that could conflict with their professional responsibilities.

1.1. Core Principle

The Core Principles section highlights the essential values that direct the policy, ensuring a consistent and equitable application. These principles comprise:

• Transparency: Employees are required to reveal any possible conflicts of interest.
• Integrity: Employees should consistently prioritize the company's best interests in their actions.
• Accountability: Employees have a duty to address conflicts and seek advice when necessary.
• Fairness: Conflicts of interest will be assessed and handled in a just manner

1.2. Scope

This conflict of interest policy applies to all individuals associated with our company, including full-time, part-time, temporary, and contractual employees. Additionally, it encompasses independent contractors and representatives acting on behalf of the organization. Everyone involved with the company needs to understand and adhere to this policy to maintain integrity and transparency in our operations. By doing so, we ensure that personal interests do not interfere with professional responsibilities, thereby fostering a culture of trust and accountability.

1.3. Purpose

• Ensure employees prioritize the interests of [Company Name] over personal gains.
• Promote ethical behavior and integrity within the workplace.
• Prevent situations that may lead to conflicts of interest.
• Protect the company’s reputation and support fair business practices.
• Comply with relevant Indian regulations and foster transparency.

2. Objectives

• To help employees identify conflicts of interest
• To disseminate information regarding consequences and responsibilities with the company for issues of conflicts of interest.

3. Identification of Conflicts

Examples to identify conflict of interest and its types:

3.1. Personal Relationships

 An employee may have a spouse employed by a competitor, potentially impacting the employee's decisions at [Company Name].

Example: Say you are assigned to a new project that is working on launching a new product, and your wife works at a competitor company that is trying to launch a similar product. Due to your personal relationship, there could be a chance of a breach of confidentiality or bias in your decision-making. So once you have found out about this new assignment, which could lead to a conflict of interest, you inform HR or your supervisor and fill out the Conflict of Interest Disclosure form. HR will review the form and take actions such as a confidential agreement, monitoring, guidance, or reassigning to a different project.

3.2. Financial Interests

 An employee possesses shares in a company that supplies products or services to [Company Name].

Example: Imagine you are an employee who is in charge of selecting suppliers; you own shares in the company of the supplier. This could lead to you having a bias toward this supplier, as a contract with your company may increase the value of your shares. This leads to a conflict of interest between you and the interests of the company that you work for. In such a case, you are expected to inform HR of the potential conflict, where HR may assign a supplier to be evaluated by another.

3.3. Outside Employment

 An employee is engaged in part-time work for a vendor that collaborates with[Company Name].

Example: Say you are working as a software developer for a company and also work part-time for another company that is a vendor for software development solutions for the company you work for full time. This situation could lead to a conflict of interest, which could lead to a breach of confidentiality or biased decision-making.

4. Disclosure Requirements

• Employees are required to notify their manager or HR of any potential conflicts of interest by completing the Conflict of Interest Disclosure Form.
• Disclosures should occur promptly upon identifying a conflict and also be made annually during the performance review process.

Example: Say you are a new analyst in the marketing department. Recently, you found out that your cousin runs a business that has a contract with your company related to distribution. In such cases, there could be a conflict of interest, where there could be favoritism or bias for the cousin. In such a case, you inform HR or your supervisor and fill out the disclosure form, which entails the form of the relationship. HR will review the disclosure and reassign the employee's cousin to a different analyst. 

5. Evaluation And Management

• The disclosed conflict will be assessed by HR to gauge its effect on the company’s operations. 
• In cases where a conflict is confirmed, the employee might need to excuse themselves from specific decisions or activities associated with the conflict.

5.1. Example for the evaluation and management

Imagine you are, a senior procurement manager at [Company Name], revealing a significant financial interest in “SupplyCo Ltd.,” a frequent bidder for contracts. HR evaluates this conflict and concludes that it could bias procurement decisions. To manage the situation, the manager is reassigned away from all dealings with SupplyCo Ltd., while a temporary replacement oversees related matters. Additionally, HR implements regular reviews of procurement activities to ensure compliance with company policies. This proactive approach helps maintain the integrity of the procurement process and ensures fair contract decisions for [Company Name].

6. Responsibilities

6.1. Employee Duties

 Employees are required to disclose any conflicts of interest (for example: spouse working for a competing company, relative with a contract with the company, etc) and should steer clear of circumstances that may lead to such conflicts.

6.2. Managerial Duties

 Managers are tasked with overseeing their teams to identify potential conflicts and take immediate action to address those issues.

6.3. HR Duties

 The HR department is responsible for assessing disclosed conflicts and putting appropriate mitigation measures in place.

7. Reporting And Resolution

• Employees are encouraged to bring any potential conflicts of interest to the attention of their manager or the HR department.
• HR will conduct an investigation into the reported conflict and decide on the best course of action, which may involve the employee stepping back from specific decisions or activities.

7.1. Examples of conflict of interest:

• Hiring Decisions: A manager may exhibit favoritism toward a relative applying for a position, potentially undermining the fairness of the hiring process.
• Financial Interests: A politician with stock ownership in a company may promote policies that benefit their financial stake rather than serving public interests.
• Competing Businesses: An employee managing a side business that competes with their employer could face conflicting loyalties and risk misusing company resources.
• Gifts and Influence: A doctor receiving gifts from pharmaceutical companies might have their prescribing practices influenced, which could compromise patient care.
• Personal Relationships: A board member with a personal connection to a supplier might make biased decisions, favoring the supplier over more advantageous alternatives for the company.
• Religious or Political Bias: An employee's decisions, swayed by personal religious beliefs or political affiliations, may not align with the company's best interests.

8. Consequences Of Non-Compliance

• Neglecting to disclose a conflict of interest or adhering to this policy may lead to disciplinary measures, which could range up to and including termination of employment.
• Failure to comply with these guidelines compromises the company’s dedication to ethical conduct and can harm its reputation.

9. Review and Monitoring

• The HR department will conduct an annual review of the Conflict of Interest Policy to assess its effectiveness.
• Compliance will be ensured through regular audits and evaluations, with updates to the policy made as necessary to respond to new challenges or regulatory changes.

10. Contact Information

Name: [Name of the HR representative to contact]

Designation: [Role of the person to contact in the company]

Contact Number: [Contact number of person to contact in the HR department for questions regarding the policy]

Contact Email: [ Company Email of the representative to contact in the HR department]

Compliance

All employees are expected to comply with this policy and report any conflicts of interest proactively. Failure to do so may result in disciplinary action, as outlined above.

Acknowledgment

By signing this policy, employees acknowledge their understanding of the Employee Conflict of Interest Policy and their commitment to uphold the principles herein.