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.
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.
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
You may give gifts, favors, and entertainment to
others at Company expense, only if they meet all of the following criteria:
- Your Vice President approves the gift;
- They are of limited value and will not be construed as a bribe or payoff;
- They 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:
- Employment 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. If in doubt, contact your manager for current clarification.
- Volunteer 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
- Employment 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.
- Subcontracting, 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
- Act 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.
- Conduct the company’s business with integrity
and in a manner that excludes any personal advantage or gain.
- While 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.
- Maintain transparent, arms’ length business
- Respect segregation of duties, including
removing yourself from any business transactions involving relatives as
defined or implied by this policy.
- Employees may, with their vice president’s
knowledge and approval, exchange gifts as customary in some foreign countries.
- Tell 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.
- Tell management immediately if you become
aware of any situation that may involve a conflict of interest for yourself or
- Please 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:
- Do not seek gifts, favors, or entertainment
for yourself or for others.
- It is never permissible to accept a gift of
cash or cash equivalent such as stocks or other forms of marketable securities
of any amount.
- ANY 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.
- Examples of gifts, favors, or entertainment
situations that commonly come up and are acceptable include, but are not
- Lunch and/or dinner with vendors, sometimes
- Gifts of small value from vendors such as
calendars, pens, pads, knives, etc.
- Tickets to events (such as sports, arts,
etc.), or participation in sponsored events
- 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.
- Social drinks are acceptable within moderate
limits; however receipt of gifts of alcoholic beverages is discouraged.
- 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.
- Day outings such as golf, fishing, and
hunting are acceptable if the vendor attends.
- 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
- Respond to employees’ concerns and provide
guidance regarding potential or actual conflict of interest issues.
- Investigate immediately if you become aware of
any situation that may involve a potential or actual conflict of interest and
take appropriate action.
- Take 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.
- Your 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.
- Assist employees to understand, be respectful
of, and participate in customs and unique operating conditions in foreign
- Do not accept gifts valued at more than $20
from those under your supervision.
Oct. 4, 2010
Mar. 8, 2004