Conflicts of Interest
We believe in making impartial decisions that deliver the best results for our company. A “conflict of interest” arises when you could use your position at CoorsTek for personal gain or you have a personal relationship or interest that could influence your ability to objectively perform your job.
For example, a conflict may arise when you are:
- Supervising or conducting company business with a family member or someone with whom you have a close personal relationship
- Allowing a second job or commitment take away the loyalty, time, energy, or talent you bring to your position at CoorsTek
- Taking for yourself a business opportunity that is meant for CoorsTek
- Owning, investing in, working for, or advising a company that competes, does business with, or wants to do business with CoorsTek
- Using the CoorsTek name, property, or information without approval to support a charitable, professional, or community organization.
Even the appearance of a conflict of interest can put you and our company at risk. If you find yourself in a potential or actual conflict of interest, you must immediately Share Your Concern.
A conflict of interest is not necessarily a problem but could become a problem if it is not disclosed and properly managed. Many times, conflicts can be resolved by an open and honest discussion and by working together to find an appropriate solution.
GIFTS AND ENTERTAINMENT
Conflicts of interest may also arise if you give or accept gifts, entertainment, or other items of value to or from suppliers, customers, competitors or others doing or seeking to do business with CoorsTek.
Giving or accepting an occasional gift, entertainment, or other item of value is often viewed as a normal and important part of developing business relationships. However, giving or accepting them will become inappropriate when they create a sense of obligation or compromise your professional judgment.
When dealing with non-government parties, you should only give and accept gifts, entertainment, or other items of value when they are:
- Modest or of nominal value,
- Not cash, loans, or cash equivalents,
- Not going to influence business decisions, and
- Consistent with cultural norms and local laws and regulations.
Gifts, entertainment, or other items of value are of modest or of nominal value if their value is less than US$250 (or the local currency equivalent). You should not offer or accept a gift, entertainment, or other item of value in excess of $250 (or the local currency equivalent), unless you have first disclosed the item and its value to your supervisor and the CoorsTek HR Department and received their written approval.
When dealing with government parties, you should never give or accept any gifts, entertainment, or other items of value whatsoever, unless you have permission from a member of the CoorsTek Executive Leadership Team or the CoorsTek Legal Department.
RELATIONSHIPS WITH VENDORS
We also avoid conflicts of interest by managing our vendor relationships in a fair, equitable, and transparent manner. We make decisions to engage a vendor based on objective criteria, such as quality, reliability, technical excellence, price, reputation, integrity, and compliance with contractual requirements, laws, and our policies.
When making a purchasing decision on behalf of CoorsTek, you must:
- Choose the vendor based on objective criteria
- Follow all purchasing processes and systems of CoorsTek
- Practice appropriate vendor due diligence
- Never accept gifts or entertainment beyond what is permitted under the Gifts and Entertainment portion of our Global Standards
- Never base your decision on personal relationships or the opportunity for personal financial gain