The company expects all employees to perform their duties, honestly, fairly, transparently and to act in the best interests of the company in all situations avoiding interests, activities, investments, relationships and influences that might compromise their objectivity, effectiveness and the faithful performance of their duties.
Each employee must complete a conflicts of interest declaration at inception of employment and thereafter, once a year and also whenever an actual or potential conflict arises in our individual circumstances.
Generally, conflicts of interest arise in the following situations:
Acting without prior approval as a director of a competitor or an entity that has a business relationship with the company, holding an outside employment such as a consultant or advisor to a competitor, supplier or contractor or participation in outside activities that conflict with your duties and reliability as an employee of the company;
Misusing your position in the company, corporate business opportunities, confidential information or proprietary information for personal benefit or for the benefit of the members of your close family or third parties;
Soliciting and acceptance of expensive gifts, cash, favors and sponsorships for the personal benefit or third parties;
Having a personal financial, partnership or profit-sharing interest in a competitor or in a company that is doing or seeking to do business with GNCC Capital, Inc. As regards a listed company, ownership of less than 5% of the securities of such company is permitted and not deemed contrary to the company's policy on conflicts of interest;
Being involved directly or indirectly in the engagement, management or supervision of business parties in which you have a financial interest or which are controlled by or for which close relatives work in high management positions;
Awarding, without disclosure, a contract to a close family member or a company controlled by a close associate, employing or influencing the employment of a family member or associate, working directly in the same reporting line with a close family member or someone with whom you have a close relationship, any of which could undermine or appear to undermine the company's internal controls;
Misusing company funds, property and business opportunities for personal gain or purposes unrelated to the business of the company; and
Soliciting and obtaining loans or guarantees of personal obligations for you or close family members and close associates from entities doing business with the company.
You must advise your manager or supervisor and promptly submit a declaration whenever you find yourself in a conflict of interest situation. If there is an actual conflict or potential for a conflict of interest arising, you must refrain from any discussion, negotiation, decision making or management of a contract or activity relating to the conflicted interest and also refrain from influencing others directly or indirectly regarding the interest in question. Conflicts of interest have implications for both the employee and the company. Personal implications include disciplinary action and loss of credibility. Corporate implications could range from financial sanctions and penalties, litigation, regulatory investigations and damage to reputation.
If you become aware of or suspect the existence of a conflict of interest (actual, potential or perceived), you must report to your manager or supervisor, the compliance unit or utilize the company's whistle blowing facility.
