4. Conflicts of Interest
4.1 General GraceKennedy respects the privacy and the rights of individual employees and directors in the conduct of their personal affairs. However, you should avoid engaging in any outside business interest or other activity which creates or which may create a conflict of interest, or a perception or impression of impropriety, wrongdoing or abuse of your position, or harm the company's integrity or reputation. You should also declare any conflict of interest which interest that may arise during the course of your activities, and follow the guidelines and procedures applicable.
A conflict of interest exists if your personal interest interferes with or even appears to interfere with your ability to objectively and independently discharge your duties or responsibilities to the Company or to act in the best interest of the Company. A conflict may also exist between the Company and a customer or other third party where the Company's obligations to one customer or business associate could conflict with its obligations to another.
If a conflict exists you must immediately declare this to your supervisor or manager or, in the case of directors, to the Chairman of the Board or Boards on which you sit so that appropriate action can be taken to resolve the situation. If the conflict arises during a meeting or in the course of your making a decision on any matter , then you should declare your interest and take no part in the discussion or the decision. You should also withdraw from the meeting unless the Chairman indicates that you should do otherwise.
For purposes of conflict of interest, the activities actions of Immediate Family Members are considered to be the actions of the employee or director.
Employees are required to disclose, at the beginning of employment, the business interests which they have outside the Company and to promptly update this information as necessary so that any conflicts or potential conflicts may be determined and appropriate action taken.
Directors are required to disclose to the Chairman of the Board of the company in which he or she acts as a director, any other directorships or business or other interests or associations which may be, , or appear to be in conflict with his or her position as a director, in general or in specific circumstances , and the conflict should be resolved if necessary in consultation with the Group Chairman.
4.2 Directorships
Employees must obtain prior approval before acceptance of a directorship in any company or entity other than those excepted below :
You will not need to obtain permission to serve as a director of
- A non-profit, public service corporation such as a religious, educational, cultural, social, welfare, or charitable institution
- A private, family - owned company (50% interest or greater) established for the administration of the personal or financial affairs of an employee, or the Immediate Family Member of the employee.
4.3 Other Employment or Outside Business Interest:
Employees are expected to be fully engaged in their employment activities in keeping with their contract of employment.
Prior approval must be sought before making any commitment towards possible part-time employment or involvement in any outside business interest.
Approval will normally be given where the involvement in the business interest is not considered a conflict of interest with GraceKennedy's business or the interest of major customers.
Employees and their Immediate Family Members are not encouraged to have any financial interest in or with a supplier save and except where the supplier is a publicly listed company. The prior approval of the Chairman & CEO of the Group is to be obtained before any such financial interest is established. Approval may be given in exceptional cases where the conflict is not considered to be significant or where it is considered in the best interest of the Company to grant such approval. If approval is granted then any conditions associated with the approval must be strictly observed.
Table of Contents | 5. Confidentiality |