II. Conflicts of Interest
All of our business partners (those organizations we work with and for) maintain separate codes of ethics and business conduct which include, among other things, dealing with issues that may arise in their relationships with us. These issues are often called conflicts of interest. They relate to situations where your personal interests or activities may impact your duties to the company and our partners. It is the responsibility of each employee who has direct relationships with our business partners to be familiar with the business partners’ policies concerning conflicts of interest. At panies, all conflicts of interest are strictly prohibited. Gifts are a special area of concern. The giving or receiving of gifts is strictly prohibited. The giving or receiving of gift cards, cash, checks, money orders, coupons, loans or another type of money or money equivalent items including discounts are strictly prohibited. Providing or receiving modest food/beverage at a business meeting or occasional modest meals or a “cup of coffee” are allowed with approval of your supervisor. Other examples of conflicts of interest that are prohibited include, but are not limited to: unusual or excessive business entertainment, any business entertainment that could embarrass or harm the reputation of Danella or our customers and partners, giving or receiving of services at a discount, having a financial interest in a business relationship with a business partner, employment of or doing related or conflicting business with family members, excessive socializing with the purpose of obtaining financial gain, maintaining a personal relationship which gives the appearance of impropriety or which may lead to a conflict of interest, receiving or performing of favors that could appear to influence business decisions, receiving or giving of kickbacks, or, in general, any conduct which may lead to even the appearance of influencing or attempting to influence decisions dealing with business relationships. Your obligation is to avoid at all times even the appearance of any impropriety. These actions, and others like them, are strictly prohibited. If you ever have any questions about whether any particular activity or conduct is a conflict of interest or if you believe someone is attempting to influence you, you should immediately report it as outlined in Article 10. You should always err on the side of caution and report anything you think comes close to any prohibited conduct or activity.