Conflict of Interest Policy
Revised Oct. 4, 2010 - Printable version
 
Overview

ABX Air is proud of those who work for us, and you can be proud of the position of trust you hold. The reputation of our company in the community and business world depends on the actions of those who work here.

Employees are to act at all times with integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.

Purpose

This policy outlines ABX’s expectations with regard to actually or potentially allowing personal interests or relationships to influence objective decision making on the company’s behalf. This policy governs business relationships, including award of business, receiving or giving gifts, favors, or entertainment, along with other potential conflicts of interest to or from any person or business where an actual or potential conflict of interest may be present.

Definitions

Conflict of Interest: situations in which personal considerations or financial gain may compromise, or have the appearance of compromising, your professional judgment and result in actions or choices that conflict with the best interest of the company.

Relatives/member of family: parents, siblings, children, spouses, grandparents, aunts, uncles, nieces, nephews, first cousins, in-laws, or step-relations, or close personal relationship otherwise not formally defined as a relative.

Gifts, Favors, And Entertainment Offered By Employees

You may give gifts, favors, and entertainment to others at Company expense, only if they meet all of the following criteria:

bulletYour Vice President approves the gift;
bulletThey are of limited value and will not be construed as a bribe or payoff;
bulletThey are not in violation of applicable law and generally accepted ethical standards; and public disclosure of the facts will not embarrass the company.

Other Potential Employment Conflicts

Other potential conflicts of interest include, but are not limited to the following:

bulletEmployment outside ABX - If you are employed outside ABX, it should not interfere, compete, or conflict with the company’s best interests or hinder your ability to meet your responsibilities at ABX.
bulletVolunteer Activities/Community Involvement -You are encouraged to be involved in community, industry, and charitable activities, including directorships in non-profit community organizations, as long as they do not compete with or create demands that interfere with your job.
bulletEmployment of Relatives - ABX permits the employment and promotions of qualified relatives of employees as long as such employment does not, in the opinion of ABX, create actual or perceived conflicts of interest.
bulletSubcontracting, Contracting, or Approval of payment for services of any kind - No person with a close personal friendship or Relative as defined in this policy, shall award or approve payments to anyone with an actual or perceived conflict of interest.

Access To Confidential Information

Revealing or using any confidential, personal information; trade secrets; product information; information used to make decisions or future plans; or any other information that might be contrary to the best interests of the Company without prior authorization is forbidden. The misuse, unauthorized access to, or mishandling of confidential information, particularly personal information, is strictly prohibited and will subject an employee to disciplinary action up to and including termination. Use of Confidential information for personal gain is strictly prohibited. Revealing confidential information to Relatives is likewise prohibited, regardless of potential for personal gain.

Employee Role & Responsibilities

bulletAct in the best interest of the company when dealing with customers, suppliers, contractors, competitors, or any person doing or seeking to do business with ABX Air.
bulletConduct the company’s business with integrity and in a manner that excludes any personal advantage or gain.
bulletWhile interacting with others on behalf of the company, conduct yourself in a strictly professional, business-like manner to avoid any potential or actual conflict of interest or favoritism.
bulletMaintain transparent, arms’ length business relationships.
bulletRespect segregation of duties, including removing yourself from any business transactions involving relatives as defined or implied by this policy.
bulletEmployees may, with their vice president’s knowledge and approval, exchange gifts as customary in some foreign countries.
bulletTell management immediately if you own or have significant interest in, or any member of your family owns or has significant interest in, any outside company which does business or seeks to do business with ABX or is a competitor.
bulletTell management immediately if you become aware of any situation that may involve a conflict of interest for yourself or others.
bulletPlease direct any questions related to this policy to your management or the Sr. VP Corporate General Counsel and Secretary, or Assistant General Counsel.

With regard to gifts, favors, and entertainment:

bulletDo not seek gifts, favors, or entertainment for yourself or for others.
bulletIt is never permissible to accept a gift of cash or cash equivalent such as stocks or other forms of marketable securities of any amount.
bulletANY gifts, favors, or entertainment offered MUST be approved in advance by the next level of management who will assist in deciding how the offers should be handled. In most cases, gifts that can be shared with co-workers should be shared.
bulletExamples of gifts, favors, or entertainment situations that commonly come up and are acceptable include, but are not limited to:
    1. Lunch and/or dinner with vendors, sometimes including spouses.
    2. Gifts of small value from vendors such as calendars, pens, pads, knives, etc.
    3. Tickets to events (such as sports, arts, etc.), or participation in sponsored events
    4. Overnight outings are acceptable under the condition that either individuals from other companies or the vendor also attend, and there is a potential business benefit to the event.
    5. Social drinks are acceptable within moderate limits; however receipt of gifts of alcoholic beverages is discouraged.
    6. Gifts of perishable items usually given during the holidays such as hams, cookies, nuts, etc., are acceptable. You are encouraged to share with co-workers if you receive them.
    7. Day outings such as golf, fishing, and hunting are acceptable if the vendor attends.
    8. Attendance of events at vendor facilities is acceptable, but use of vendor’s facilities (vacation homes, etc.) by employees or families for personal use is prohibited.

Management Role & Responsibilities; Beyond Those As Employees
bulletRespond to employees’ concerns and provide guidance regarding potential or actual conflict of interest issues.
bulletInvestigate immediately if you become aware of any situation that may involve a potential or actual conflict of interest and take appropriate action.
bulletTake time to examine situations involving an employee's relative(s) to see if the potential for conflict of interest exists and, if so, how it may affect the productivity of the employee and/or department. If a potential for conflict of interest exists, discuss the situation with your management, the business unit leaders, and/or Human Resources to evaluate the appropriate steps to take.
bulletYour department may establish procedures to provide additional guidance to you if business conditions routinely place you in a position to make financial decisions for ABX Air.
bulletAssist employees to understand, be respectful of, and participate in customs and unique operating conditions in foreign countries.
bulletDo not accept gifts valued at more than $20 from those under your supervision.

 

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Revision History:
Oct. 4, 2010
Mar. 8, 2004