Conflict of Interest Policy Template

Purpose

The purpose of this policy is to ensure that all employees and agents of [Sender.Company] perform the duties of their position with the highest level of integrity and professionalism while prioritizing the interests of [Sender.Company]. In the normal course of business, employees and agents of [Sender.Company] may have the opportunity to advance their own personal or financial interests above the interests of [Sender.Company].

Any party who acts outside of [Sender.Company]’s best interest or uses their knowledge or position within [Sender.Company] to procure personal or financial benefits outside of their standard terms of employment are in violation of this policy. Failure to comply with this policy may result in disciplinary action up to and including termination.

Scope

This conflict of interest policy applies to all employees of [Sender.Company], either employed part-time or full-time, and it applies to all agents involved in the business of [Sender.Company], e.g., owner, director, contractor, stakeholders, or another third party. All of these parties are expected to follow the provisions of this policy where it applies to them.

Examples

A conflict of interest may take many different forms that include but are not limited to:

• Employees or agents participating in activities that render direct or indirect profit to a competitor

• Starting a business that provides services similar to [Sender.Company]​

• Employees’ or agents' ability to use their position with [Sender.Company] for their own personal or financial benefit

• Employees or agents using equipment supplied by the [Sender.Company] to support an external business

• Offering paid services during time off to a customer of [Sender.Company]

• Employees or agents using equipment supplied by the [Sender.Company] for personal use

• Employees or agents using connections obtained exclusively through [Sender.Company] for their own private purposes

• Employees or agents acting in ways that may compromise [Sender.Company]’s legal standing (e.g., taking bribes or sharing confidential information)

Generally, employees are advised to avoid situations where personal as well as financial interests and external activities could come into opposition with the company’s fundamental interests.

Procedure

• Duty to disclose

All employees and agents of [Sender.Company] are required to disclose any known, potential, or suspected conflicts of interest to their superior(s) as soon as said employees and agents become aware of them. Failure to disclose potential or actual conflicts could lead to a range of disciplinary actions up to and including termination of employment.

• Reviewing potential conflicts

When a possible conflict of interest becomes known or is suspected, the employee's supervisor will collect all of the relevant information and may question any involved parties. If the company determines that a conflict of interest exists or is likely to arise, steps will be taken to resolve the situation. If it is determined that no conflict exists, the inquiry may be documented, but no further action will be taken.

• Dealing with conflicts of interest

When a possible conflict of interest becomes known or is suspected, the employee's supervisor will collect all of the relevant information and may question any involved parties. If the company determines that a conflict of interest exists or is likely to arise, steps will be taken to resolve the situation. If it is determined that no conflict exists, the inquiry may be documented, but no further action will be taken.

If the conflict in question involves a member or members of the team responsible for investigating or dealing with conflicts of interest, that member or those members will be excused from the process.

• Disciplinary action

All conflicts of interest will be reviewed on a case-by-case basis to determine the appropriate course of action. A review may result in no actions being taken, or it may result in disciplinary action. [Sender.Company] has full discretion to deem what disciplinary action is both fitting and necessary, including potential suspension and/or termination of employment.

Acknowledgment

The party named below understands [Sender.Company]'s policy for conflicts of interest as it's been laid out here, including their duty to disclose any known or potential conflicts immediately.

Furthermore, the signing party agrees to abide by the procedures outlined in this policy for the full length of their professional relationship with [Sender.Company].

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​[Employee.FirstName][Employee.LastName]​