Employees of ABC who are members of
professions with established standards of conduct shall, in addition to any
obligations and responsibilities imposed by ABC policies, be bound by all
applicable professional standards of conduct.
Employees ABC have an obligation to
adhere to the provisions of this policy.
"Administrative Officer" – An
employee with duties directly related to the business operation of ABC,
specifically employees who can affect decisions regarding the purchase or
disposal of property or services, settlement of claims, or other business
"Business Transaction" – Any
sale, purchase, contract, lease, settlement, loan, or agreement in which ABC is
a party or beneficiary.
"Conflict of Interest" – An
employee could affect significantly the business transactions of ABC with the
organization in which the employee has an interest.An employee has an interest in an
·the employee or his immediate family
owns more than percent of the equity; or
·the organization employs, has employed
within the last months, plans to employ, hires as a
consultant, or pays a commission to the employee or his immediate family; or
·the organization has hired as a
consultant or paid a commission to that person or his immediate family; or
organization has provided the employee or his or her immediate family a
gratuity or gift in the previous months, with a total in excess of $enter amount.
"Employee" – Any person on
payroll, retained as a consultant, or paid a commission.
Family" – Spouse or minor children.
– A trust or corporation (including any subsidiary or parent), partnership,
association, or sole proprietorship.
Executive Office/Senior Leadership
All members of the Senior Leadership
Team will disclose any known conflict of interest and will not participate in
any decision or advocate any subject matter the member has a conflict of
interest.When a member learns that a
business transaction presents a conflict of interest, that member must make an
immediate, full disclosure to the CEO of his or her interest in the
subject.The member shall not
participate in any discussion of or decision on the issue.Failure to make a disclosure shall void any
resulting agreement at the option of ABC.
This policy shall not prohibit an
organization in which a member has financial interest from pursuing a contract
through competitive bidding.However,
such member must first inform the other members of his or her intent to
participate in bidding.
Legal Counsel shall inform each member
of the Senior Leadership Team in writing of the statutory requirements relating
to conflict of interest and of this policy.Legal Counsel shall inform each new members of the Senior Leadership
Team in writing of the statutory requirements relating to conflict of interest
and of this policy.
Employees shall immediately disclose
any business transaction(s) which present a known conflict of interest.
Business transactions that violate this
policy are voided at the option of the CEO.
Legal Counsel is available for
employees to advise on matters of conflict of
interest.Advice given any employee
regarding an interpretation of this policy shall be in writing.In any case of conflict of interest involving
the Legal Counsel or Assistant Counsels, the CEO shall refer the matter to
independent legal counsel.
Any Vice-President receiving a
disclosure of conflict of interest shall notify Legal Counsel, who shall report
as soon as possible to the CEO.Legal
Counsel and the CEO will determine if the business transaction should be
voided.The CEO shall inform the Senior
Leadership Team of any potential or actual conflict of interest that makes a
particular organization ineligible to do business with ABC and the organization
involved shall be so advised.