Financial Conflict of Interest Policy

Process Owner

Senior Executive Human Resources

Purpose

To establish guidelines for avoiding apparent, potential and actual conflicts of interest and to define procedures for management of conflicts of interest.

Definitions

Immediate Family - Refers to any of the following familial relationships (whether genetic or legal): husband, wife, father, mother, son, daughter, brother, sister, grandmother, grandfather, grandson, granddaughter, aunt or uncle, niece or nephew.

Policy

Employees must not engage in any activity or practice that conflicts with the interests of the corporation or its customers, and must avoid actions or inaction's that create even the appearance of a conflict of interest (whether potential or actual).

Requirements

1. GovC employees and agents should not offer gifts to government employees in the course of doing business or seeking to do business with a government agency.

2. GovC employees who communicate with, evaluate for hire, and hire current Federal government employees or former Federal government employees must recognize that there are laws that can restrict GovC’s ability to consider, offer and/or employ persons who are or have been Federal government employees.

3. Employees shall not accept concurrent, full-time, part-time, or temporary employment in any organization that does business with GovC or is a competitor of GovC.

4. If a GovC employee or a member of their Immediate Family has a financial interest in a firm that does business with GovC or is a competitor of GovC, that employee shall:

(i) should promptly disclose the connection in accordance with GovC’s Standards of Ethics and Business Conduct; and

(ii) Shall not represent GovC in transactions with such a firm.

(iii) Ensure no business information is shared (offered or accepted) that could result in a competitive advantage for either company.

5. Employees shall directly or indirectly hire, fire, discipline, promote, compensate or evaluate an Immediate Family member.

Responsibilities

All Employees

It is the responsibility of all employees to abide by the guidelines set forth in this Personal Conflict of Interest policy.

Hiring Managers

Hiring managers shall ensure new existing and new employees have been communicated the requirements of this policy and are in compliance with it.

The failure of an employee to abide by the guidelines set forth in this Personal Conflict of Interest policy may result in disciplinary action, up to and including dismissal.