Ethics and Conflict-of-Interest Policy for Employees
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SummaryAll EPE employees are expected to exhibit and promote the highest standards of honest and ethical conduct in all dealings relating to the business of the organization. That means that, in working for EPE, employees are expected to act solely in the interest of EPE and not in their personal interests or in the interests of others. In other words, EPE employees are expected to use good judgment, adhere to high ethical standards, and avoid situations that create an actual or perceived conflict between their personal interests and those of the organization. EPE expects that the transactions employees participate in are ethical and within the law, both in letter and in spirit.
EPE recognizes and respects the individual employee’s right to engage in activities outside of his or her employment that are private in nature and do not in any way conflict with or reflect poorly on the organization. Management reserves the right, however, to determine when an employee’s activities represent a conflict with the company’s interests and to take whatever action is necessary to resolve the situation, including terminating the employee.
What Constitutes a Conflict of Interest?
There is no way to develop a comprehensive, detailed set of rules to cover every business situation. The tenets in this policy outline some basic guidelines for ethical behavior at EPE. Whenever you are in doubt, you should consult your manager.
Conflicts of interest or unethical behavior may take many forms such as:
• Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, or any education or publishing concern that may stand to gain from influencing information in our publications regardless of the nature of the employment
• Hiring or supervising family members or closely related persons
• Serving as a board member for a competitor or potential competitor, supplier, or contractor
• Owning or having a substantial interest in a competitor, supplier, or contractor
• Having a financial interest or potential gain in any EPE transaction
• Placing company business with a firm owned or controlled by an EPE employee or his or her family
• Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier, unless
- it can be and is shared by EPE employees or
- the gift, discount, favor or service has a nominal retail value (less than $25)
• Using EPE resources to provide gifts, favors or services to a customer/potential customer, competitor or supplier, unless
- the gift, discount, favor or service has a nominal value or
- you have management approval
• Using proprietary and/or confidential information for personal gain or to the organization’s detriment
• Unauthorized use of EPE resources for your personal benefit or for the benefit of any other person or organization
EPE hired you based in great part on the strength of your prior experience, which may include education or awards, your credentials, and your representations about your ability and such credentials or prior experience. It is a violation of this policy if you made misrepresentations regarding your ability, credentials, or prior experience.
Confidential or Proprietary Information
All employees are expected to maintain the confidentiality of confidential information belonging to EPE, except when disclosure is authorized or legally required. Confidential information may include, for example, non-public information that might be of use to a competitor of EPE, if disclosed. Confidential information obtained in the course of employment with EPE may not be used for personal gain during or after the term of employment. EPE complies with laws and other legal requirements governing rights to and protection of patents, copyrights, trademarks, trade secrets and other forms of intellectual property owned by EPE and third parties. In addition, EPE uses software and information only in accordance with applicable licenses or other rights of use.
No Insider Trading: In the course of employment, employees may come into possession of nonpublic information regarding companies (including clients) such as proposed transactions or internal decisions. All employees of EPE are prohibited from trading in the publicly traded securities of any company while in the possession of material nonpublic information regarding that company.
Protection and Proper Use of EPE’s AssetsEPE employees are expected to protect the organization’s assets and use their best efforts to ensure their proper and efficient use. EPE’s assets should be used for legitimate business purposes, except (when properly authorized) for limited personal use that does not interfere with EPE’s business.
All EPE employees are required to complete the attached Disclosure Form and return to the HR Department.
At any time during your employment when you believe that your conduct or activities may conflict with these guidelines, may appear to conflict with these guidelines, or may otherwise create a conflict of interest, you should discuss the details of your situation with your manager, the Controller, the Publisher, or the President. Most concerns about conflicts of interest can be resolved and appropriately addressed through prompt and complete disclosure.
The issuance of these guidelines does not preclude individual departments of EPE from establishing additional guidelines specific to their own activities or circumstances. EPE reporters and editors, for example, should consult their managers or the President on matters of journalistic ethics and conflicts of interest not addressed in these guidelines.
Conflict-of-Interest Disclosure Statement For EPE Employees
Initial in the space at the end of Item A, or complete Item B, whichever is appropriate, sign and date the statement and return it to HR.
A. ______ I am not aware of any relationship or interest or situation involving me or a member of my family which might result in, or give the appearance of being, a conflict of interest between me or such family member on one hand and EPE on the other.
B. ______ The following are relationships, interests, or situations involving me or a member of my family that I consider might result in or appear to be an actual, apparent, or potential conflict of interest between me or such family member on the one hand and EPE on the other
- For-profit corporate directorships or employment:
- Non-profit trusteeships or employment:
- Memberships in the following organizations:
- Contracts, business activities, and investments with or in the following organizations:
- Other relationships and activities:
I have read and understand EPE’s conflict-of-interest policy and agree to be bound by it. I will promptly inform my manager, the Controller, Publisher or President of any material change that develops in the information contained in the foregoing statements.
____________________________ ______________________ __________________
Name and Title Signature Date