Conflict of Interest Policy - Template, Sample Form

CONFLICT OF INTEREST POLICY

I. BACKGROUND

It is the policy of ________ (the "Company") to exercise fairness, impartiality, and transparency in all its transactions for the benefit of the Company and all its stakeholders. In this regard, the Company emphasizes the need to avoid any conflicts of interest by identifying and resolving any possible conflict of interest between the Company and its directors, officers, employees, and consultants.

II. SCOPE

This policy applies to the Company's current and potential members of the Board of Directors, Employees, and Consultants (collectively, "Covered Person(s)").

III. GENERAL POLICY

When the personal business interests of a Covered Person are or may potentially conflict with the best interest of the Company, the same must be properly disclosed by the affected Covered Person and reviewed and resolved as provided in this policy.

IV. CONFLICT OF INTEREST

There is a conflict of interest when a judgement, decision, and discretion of a Covered Person may be influenced or compromised, or may appear to be influenced or compromised, by their personal, private interest that is in conflict with their professional obligations.

Situations where conflict of interest may arise include, but are not limited to the following:

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2. When the Covered Person or their Relatives or Affiliates will benefit from their knowledge of the Company's confidential information, including its past, present, and future endeavors;

3. When a Covered Person has a Relative who is in the employ of competitors or business partners;

4. When a Covered Person engages in outside employment and/or has a personally held directorship outside of the Corporation of Covered Person;

5. When involvement in another organization by Covered Person takes a significant amount of their time or attention that it adversely affects the performance of their duties and obligations to the Company;

6. When Covered Persons receive Gifts (including non-monetary benefits) from third parties, other than their Relatives, which may in turn influence their behavior and the performance of their duties and obligations to the Company;

7. When Covered Persons use the Company's property and facilities to establish, develop, and promote their own business or business of their Relatives, Affiliates, or third parties.

8. When a Covered Person enters into, or causes the Company to enter into, any contract or transaction with themselves, their Relatives, or Affiliates, whether directly or indirectly, that may result in personal gain or advantage at the expense or to the detriment of the Company;

9. Other analogous situations.

For purposes of this policy, the following will be defined as:

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2. "Affiliates" shall include persons with past or current close personal or business relationship with a Covered Person in view of which the Covered Person's decisions or actions may be affected or compromised.

3. "Gifts" shall include items that are exceeds the amount of ________ (₱________). In all cases, Gifts or non-monetary benefits should not be extravagant, expensive, or costly or too frequent considering the customs of the industry or the business situation.

V. GUIDELINES FOR CONFLICT OF INTEREST

A. Disclosure of Conflict of Interest

Disclosure of Potential Covered Persons for Hire or Engagement

All potential Covered Persons are required to disclose any existing or potential conflict of interest as part of the hiring process. The following shall have the duty and responsibility of requiring the disclosure from potential Covered Persons:

________

The disclosures will be reviewed and resolved as provided in the Review and Resolution of Conflict of Interest below.

If the conflict of interest is found to be acceptable, the hiring or engagement of the Covered Person may be pursued.

Should at any point the conflict of interest is not found to be acceptable or is not approved, the hiring or engagement of the Covered Person should not be pursued.

Disclosure During the Course of Employment or Engagement

All Covered Persons shall report actual or potential instances or situations wherein they may have a conflict of interest using the ________ as soon as they become aware of such actual or potential instance or situation. The report shall be submitted as follows:

________

The Covered Person shall likewise inhibit themselves from any direct or indirect participation or involvement in the transaction that may be considered a conflict of interest.

B. Review and Resolution of Conflict of Interest

All reports of existing or potential situations where there may be a conflict of interest shall be reviewed by the following:

________

If the conflict is initially found to be acceptable, a recommendation shall be made and forwarded to the following for approval:

________

For clarity, only the following may waive or relax the rules on conflict of interest, except in cases where the waiver or relaxation will be a violation of existing laws, rules, and regulations, by finding a conflict of interest to be acceptable:

________

If the conflict of interest is found to be acceptable, the Covered Employee may continue in their current function. However, additional safeguards may be put in place as necessary.

In all situations, a conflict of interest may only be found acceptable if it is not significant in terms of financial or business impact to the company.

However, if the conflict of interest is found to be unacceptable, the Company may take any one or a combination of the following actions:

1. Request that the Covered Person terminate or refrain from acquiring any financial or business interest in another organization that may benefit from the knowledge, decisions, or actions of the Covered Person in the course of their employment;

2. Request that the Covered Person reduce the hours or time that they dedicate to an outside organization to enable them to focus on their duties and responsibilities to the Company;

3. If the conflict of interest pertains to a Relative or an Affiliate of a Covered Person, require the Covered Person to exert all reasonable efforts to remove the conflict of interest;

4. Modify the duties and responsibilities of the Covered Person to minimize or eliminate the conflict of interest;

5. Transfer or move the Covered Person to another position wherein the conflict of interest is minimized or eliminated;

6. If, despite all reasonable efforts, the conflict of interest is not or cannot be minimized or eliminated, dismiss employee from employment;

7. Require the Covered Person to divest, dispose of, or surrender any financial or business interest giving rise to the conflict of interest; and

Take such other appropriate action as the circumstances may warrant, consistent with applicable laws, rules, and regulations and the policies of the Company.

It shall be the duty of the following to ensure that the appropriate corrective action is taken: ________.

A conflict of interest must be resolved within thirty (30) days after it was found to be unacceptable.

C. Violations of this Policy

A violation of this policy shall be subject to penalties under the following: ________.

VI. INFORMATION DISSEMINATION

All new Directors, Employees, and Consultants shall receive a copy of this Policy upon the start of the performance of their duties.

If this Policy is amended or modified, all Directors, Employees, and Consultants will be informed of the amended or modified policy.

VII. EFFECTIVE DATE

This Policy shall become effective on ________.

Signed and approved:

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