Conflicts of Interest

Conflicts of interest arise when there is opportunity for personal gain beyond the usual rewards of employment or when an employee’s interests collide with ICD’s interests. Each employee must avoid doing anything that compromises or appears to compromise his judgment or that places or appears to place his personal interests and ICD’s interests at odds.

Conflicts of interest can arise whenever you hold a significant interest in, engage in outside work for, or receive any personal benefit or gift from any of our vendors, suppliers, contractors, customers, or competitors. Conflicts also arise when you compete with ICD or when you are presented with a business opportunity that is received due to your position with ICD and in which ICD may be interested.

It is impractical to list every activity that might constitute a “conflict of interest.” There are also many borderline situations that need evaluation based on all relevant information. When in doubt, ask your supervisor. The following are typical conflict of interest situations and ICD’s policy with respect to each:

CORPORATE OPPORTUNITIES: All employees are prohibited from taking for themselves opportunities that are discovered using corporate property, information, or position. No employee may use corporate property, information, or position for improper personal gain, and no employee may compete with ICD directly or indirectly. Each employee owes a duty of loyalty to ICD to advance ICD’s legitimate interests when the opportunity to do so arises.

OUTSIDE WORK: Employees must not work for, or conduct any outside business with, a competitor. Employees may not be engaged in any manner by a competitor of ICD.

GIFT AND BUSINESS ENTERTAINMENT: Accepting gifts or entertainment from those ICD does business with could be perceived to influence decisions or create a sense of obligation. In addition, offering gifts and entertainment can raise similar issues. To ensure the highest level of objectivity in dealing with ICD’s vendors, suppliers, contractors, customers, competitors and representatives, and to avoid the appearance of impropriety, you should not accept or offer any gift or entertainment unless it:

  • is unsolicited and offered infrequently;
  • is reasonable in its value and scope;
  • is customary and part of your normal business practice to accept or offer the item;
  • does not impose or create the appearance of imposing a sense of obligation on either the giver or the recipient, and
  • does not create the appearance that your business judgment can be influenced.

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