4.5 | Conflict of Interest

Entrepreneurs are expected to avoid situations that might cause their personal interests to conflict with, or appear to conflict with, the interests of CTC or which might compromise, or appear to compromise, CTC’s reputation or integrity.  A conflict of interest arises when an Entrepreneur’s activities or interests conflict with CTC’s interests.  The following examples are illustrations only and are not intended to be an all-inclusive list. 

For example, conflicts of interest may occur when an Entrepreneur: (1) uses confidential information for an his or her personal gain; (2) accepts gifts, favors, money, or services from which could seem to influence a work-related decision; (3) has a financial interest or investment, personal association, or business relationship with a customer, supplier or competitor that interferes with the Entrepreneur’s ability to exercise independent judgment on CTC’s behalf is prohibited; or (4) when the Entrepreneur or a member of the Entrepreneur’s immediate family uses the Entrepreneur’s position for personal benefit or for personal gain. 

“Immediate family” includes an entrepreneur’s spouse or partner, siblings, parents and grandparents, children and grandchildren, nieces and nephews, and people living in the same household in a relationship substantially comparable to any of the above.  If you have any doubt at all about whether a particular activity may create an actual or apparent conflict, you should consult with the Human Resources in the Differentiation Department and receive written approval before you engage in the activity.