Integrity Standard
- Conflict of Interest
Policy
We must avoid situations where our personal
interests could conflict, or reasonably appear to conflict,
with the interests of the Company. We must be free of actual,
apparent or potential conflicts of interest when dealing with
persons or business entities on behalf of the Company. We
must award business solely on merit, getting the best value
for the Company, and wherever practical, on a competitive
basis. A conflict of interest occurs whenever an employee
permits the prospect of direct or indirect personal gain to
influence his or her judgment or actions in making decisions
regarding Company business.
Nepotism and other Forms of Favoritism
We may not conduct Company business with any entity in which
we or our family have 5 percent or greater ownership or controlling
interest. A family member, as defined by Company policy, generally
includes an employee’s:
- Current spouse, domestic partner
- Parent/Stepparent
- Children (includes biological, adopted, foster,
or other legally placed children)
- Siblings (includes biological, step or half)
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- Grandparent
- Grandchild
- In-laws
- Corresponding immediate family members of any
employee’s spouse or domestic partner
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We may not use information that comes to us in the course
of employment for personal investment or gain, nor can we
provide this type of information to family members or others.
We must avoid direct or indirect responsibility for the hiring
or supervision of a family member. Even the appearance of
favoritism can have a degrading effect on employee morale
and perception of the Company’s fairness to all employees.
Employment of family members is permitted so long as employees
are not reporting directly or indirectly to each other.
We must also avoid romantic and other close personal relationships
with another employee where one individual supervises, directly
or indirectly, the other’s performance, salary, schedule,
or other working conditions.
Someone Close to You Working in the Industry
We may find ourselves in a situation where someone close to
us, whether a family member or a close friend, works for a
competitor, vendor, provider, customer or producer. In such
cases, we must be especially sensitive to security, confidentiality
and conflicts of interest. We should review our specific situation
with our Supervisor to assess the nature and the extent of
any potential conflict of interest and how it can be resolved.
Competing Against the Company
We may not, either directly or indirectly, compete against
the Company in any of the products or lines of business that
the Company currently sells or anticipates selling or developing.
This includes, but is not limited to, taking for ourselves
any opportunity that we discover because of our position or
employment with the Company.
Outside Employment and other Activities
A conflict of interest may also exist if the demands of any
outside activity hinder or distract us from the performance
of our job or even appear to influence our judgment or performance
for the Company. We may not engage in any outside activity
that negatively impacts our job performance.
Generally, any outside employment with a competitor, provider
or entity which does or seeks to do business with the Company
is not permitted. If you have any doubts regarding an outside
job or activity, contact your Supervisor.
It is not possible for the Code of Business Ethics
and Conduct to list every type of potential conflict of interest.
When in doubt, we should share the facts of the situation
with our Supervisor or another Corporate Resource.
Questions & Answers
Q. My spouse is employed by a Company that believes
it can supply higher quality and less expensive supplies
to our Company than the current vendor. Can we deal with
that Company?
A. In this case, so long as you stay out
of the purchasing decision, the Company will be able to
reach an independent judgment. Always notify your Supervisor
or another Corporate Resource of any close relationship
you have with any of our vendors or other business partners.
Q. I have an outside business selling fitness products.
Can I use Company bulletin boards, E-mail or inter-office
mail to advertise these products to other Company employees?
A. No. You are free to engage in an outside
business (provided there is no actual or potential conflict
of interest) on your own time and off Company premises.
Products or services associated with your outside business
should not be solicited or promoted during Company work
hours or on Company property. Also, in accordance with Company
policies and procedures, you should not use the Company’s
name, its facilities or resources (e.g., time, telephones,
copy machines) to engage in any personal business activity.
Q. I am a claims examiner and have an opportunity
to moonlight in the billing department of a large physician
group. Can I take the job?
A. Generally, Company employees may not
have outside employment with any provider, competitor or
any entity which does or seeks to do business with the Company.
It would be inappropriate for you to work for any physician
group that files claims with or otherwise does business
with the Company. If you have questions on any type of outside
employment, contact your Supervisor.
Remember, if you do not understand, or if you have any
questions concerning, this Integrity Standard or any other
part of the Code, contact your Supervisor, a higher level
Supervisor, any of the Corporate Resources or call the Corporate
Integrity HOTLINE
(1 800 838-2552).
Return to the Code of Conduct
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