<aside> 👉 All employees must ensure that they notify the Company in the event of an actual, potential or perceived conflict between the Company’s interests, their own interests, or another party’s interests.

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Conflicts may arise when two or more competing interests are involved which are inconsistent with, or diverge from the interests of another party, such as those of the Company or of the Company’s customers. Such conflicts may occur between an employee and the Company, between an employee and a customer, as well as between employees.

Any employee who breaches this policy or who coerces, encourages or assists another person to breach this policy may be subject to disciplinary action.

Types of Conflicts

A conflict may be actual, potential or perceived:

  1. Actual conflicts refer to an activity, transaction or interest that is currently causing a conflict of interest;
  2. Potential conflicts refer to an activity, transaction or interest that could give rise to an actual or perceived interest, either at the time it occurred or at some time in the future; and/or
  3. A perceived conflict occurs when an activity, transaction or interest could reasonably allow a third party to form the view that a conflict currently exists or may exist at some time in the future.

The above types of conflicts are not mutually exclusive and several different types of conflicts may exist at once. A conflict may still exist even when you or another party believes or strives not to be influenced by the conflicting interest or duty.

Some examples of where an actual, potential or perceived conflict may arise includes when:

  1. A manager hires an applicant who is a family member or friend;

  2. An employee enters into a purchasing, supply or another contract on behalf of the

    Company with another entity in which the employee holds a financial interest;

  3. A person is required to represent or serve the interests of 2 or more parties whose

    interests are in conflict;

  4. A person may be a shareholder or have a financial interest in a competing company;

  5. A board member has a duty to a company that conflicts with a duty to another company; or

  6. A person takes on an additional project or role that may lead to them breaching the obligations of their original project or role, such as confidentiality.

Identifying, declaring and reporting conflicts

Employees are required to actively consider whether any actual, potential or perceived conflict of interest arises in the course of your employment.

You must declare any conflicts that may affect you or another party that you are aware of to the Director and provide an update as soon as reasonable if any relevant circumstances affecting a declared conflict change.

In the event that you feel uncomfortable disclosing an actual, potential or perceived conflict to the Director, or where the disclosure relates to this person, please contact @James Cooke