SBIC Code of Business Ethics and Conduct
| Conflicts of Interest | ||
| Keys to Compliance | We respect the right of all employees to manage your personal affairs and investments. However, care must be taken to avoid situations that might conflict with the employee's responsibilities to Insurance Services or with the interests of business partners or qualified member school entities with whom it does business. | |
| Avoid conflicts of interest, whether in appearance or in fact | We strive to do business without favoritism. Accordingly, neither you nor any member of your immediate family should have a direct interest in, or relationship with, any organization where such a relationship might affect the objectivity and independence of your judgment or conduct in carrying out your duties and responsibilities. You should not take additional employment with outside organizations if such employment will create an actual or perceived conflict of interest. |
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| Don't let community activities conflict with Company interests | We strongly encourage employees to participate in their communities. Such participation, however, carries with it the responsibility to avoid actual or apparent conflicts of interest. For example, using company time or assets for community activities should not be done without authorization from your Department Manager and Managing Director. |
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| Question: My husband works for a local vendor that supplies our facility. Sometimes I am responsible for purchasing supplies from them. What should I do? | Answer: Advise your manager of the circumstances. A competitor of your husband's company could claim that you are biased in his favor. Depending on the circumstances, another employee may be assigned to handle the transactions involving your husband's company. | |
| Question: May I hire my brother to do some contract work for SBIC and affiliates entities if his rates are the best rates available? | Answer: Regardless of your brother's rates, Insurance Services should not hire him to perform services under a contract if he will be working under your supervision or if you will have any influence over the decision to employ him. The hiring should be approved by a higher manager in writing and should be disclosed to that manager before the decision is made. false claim. |
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| Question: My wife works for another insurance company that sells insurance products to qualified member school entities. Is this a conflict of interest? | Answer: Not necessarily. However, you should discuss this relationship with the Manager of your department to assure that you are not given assignments that would create a conflict of interest. In no event should you disclose confidential information to your spouse or solicit confidential information from your spouse. |
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