Free Sample Conflict Of Interest Policy
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Sample Conflict Of Interest Policy

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Conflict of Interest


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 obligations.

"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 organization when:

·         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

·         the 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.

"Immediate Family" – Spouse or minor children.

"Organization" – 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.

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