Conflicts of Interest
From time to time, a situation may develop where personal family relationships with a supplier or customer, or in respect of a particular transaction, give rise to questions or appearances of impropriety. To the extent that any such relationship presently exists, it should be brought to the immediate attention of the President with an appropriate explanation. Undisclosed conflicts of interest may be grounds for termination of employment. The following guidelines have been established to define "conflicts of interest":
- No employee should become involved in business activities that give rise to a conflict of interest. If one exists, or should one arise in the future, it should be discussed and cleared with the President.
- As a general rule, a conflict of interest exists whenever an employee or a member of his or her family has a direct or indirect financial interest in, or connection with, a company that does business with Huron Inc, with any subsidiary or affiliate of Huron Inc. The employee may then be in a position to influence a decision so as to cause a transaction with such other company to be on terms other than the most favorable obtainable to the subsidiary or affiliate of Huron Inc.
The following are some specific guidelines:
- No officer or employee may serve as an officer or employee of any concern which does business with, or is competitive with, Huron Inc or with any subsidiary or affiliate of Huron Inc. While there is no absolute prohibition against an officer or employee serving as a director of a concern with which Huron Inc or any subsidiary or affiliate of Huron Inc does business, in order to make certain that any such appointment is in the best interest of the company, it is to be referred to the President before it becomes effective.
- No employee or family member may have any financial interest in any concern doing business with any subsidiary or affiliate of Huron Inc. In particular, participation in companies engaged in selling or leasing facilities, equipment, services or products is prohibited without the prior written approval of the President. This does not apply to holding of actively traded listed securities unless the holding is substantial.
- No officer or employee may accept from any concern which does business with Huron Inc or with any subsidiary or affiliate of Huron Inc, any gift or gratuity, favor of service, other than promotional or advertising material marked with the donor's name, and the customary business lunch. The spirit of this policy dictates that officers and employees should refuse offers of entertainment, gifts, or gratuities which might make it difficult to retain independence of judgment.
Annually, a copy of the "Conflicts of Interest Policy" and a certification sheet will be distributed to key company managers. Each recipient of the Conflicts of Interest Policy must complete a copy of the certification sheet. A copy of the returned certification will be retained for company records.
Reference: Huron Policy Manual - Policy 004