We report actions that may involve a conflict of interest to the Compliance Officer. Senior executive officers and directors must disclose to the Chief Legal Counsel any material transaction or relationship that reasonably could be expected to give rise to such a conflict, and the Chief Legal Counsel should notify the Ethics Committee of these disclosures. Conflicts of interests involving the Chief Legal Counsel and directors should be disclosed to the Ethics Committee. Any exception using company resources for something not concerning Vesta must be authorized in writing by the Chief Human Resources Officer.
We Value Integrity
Conflicts of Interest
A conflict of interest is when our personal interest conflicts, or appears to conflict, with the interests of Vesta.
The decisions that we make on behalf of Vesta must be for the benefit of Vesta. These decisions often involve suppliers, clients or contractors, as well as purchasing or supply matters. If one of your own interests or the interest of someone close to you, such as a friend or family member, may interfere with Vesta’s interests, that is a problem. And we:
- Avoid financial or familial ties to a business that competes with Vesta.
- Do not take for our personal benefit any business opportunities that are discovered through Vesta’s corporate property or information or our positions at Vesta.
- Do not use company resources, including our time at work and company facilities and supplies, for anything unrelated to Vesta.
We avoid and manage conflicts of interest in all situations, including when hiring suppliers, by disclosing the potential or actual conflict. We make disclosures throughout the year, as the risks of conflicts arise. Plus, annually as a written declaration on a conflict of interest disclosure form. Disclosures of any activity, relationship, financial or other interest that may conflict with those of Vesta may necessitate changes in job duties.
Conflicts of Interest Q&A
Disclose your relationship immediately to your manager and other appropriate personnel. That is the first best step. The fact that you have this tie to one of the suppliers would probably compromise your judgment. Once you disclose the connection, you can manage the conflict by removing yourself from the panel. You should also not comment on the selection process or have any influence over it.
A: Other examples include:
- Working, in any capacity, for a competitor, customer or supplier while employed by Vesta
- Competing with Vesta, including actions such as engaging in the same line of business as Vesta or taking service and product opportunities from Vesta
- Receiving a loan or other guarantee as a result of your role at Vesta
- Directing Vesta business to a customer that employs a relative or friend
Personal Relationships Within the Company
Employees must disclose their personal relationships, such as family or romantic relationships, with other employees. Such working relationships generally signal a conflict of interest. As such, they may require changes to job duties. When in doubt about the appropriateness of a relationship, consult with the Human Resources Department for guidance. Vesta will act with discretion in such matters.
Personal Relationships Q&A
Yes. The relationship signals a conflict of interest. It may interfere with your work or the working relationship you have with each other. The best move is to disclose your relationship with your manager and other team members. Managing the conflict may involve changing work duties. We may want to ensure that you neither work closely together nor make work decisions that affect each other. We may assign one of you to another team.