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Conflicts of Interest

We always act in the best interests of our company.

Gifts and Entertainment  •  Relationship with Vendors

OUR COMMITMENT

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.

 

OUR EXPECTATIONS

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.

 

What If?
Q:: We require a financial consultant to advise on an important project. My uncle has the perfect skill set for the job and is one of only a few consultants with the required technical expertise for this job. His fees are reasonable. Can I appoint him?

A: Although your uncle meets the requirements for the job, the perception of a conflict of interest may be an issue. Raise this with your supervisor who will make an impartial decision bearing in mind all the circumstances.

GIFTS AND ENTERTAINMENT

OUR COMMITMENT

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.

 

OUR EXPECTATIONS

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,
  • Infrequent,
  • 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.

 

What If?
Q: At trade shows and face-to-face customer meetings, I frequently give notepads, pens, and other items that have CoorsTek’s logo on them. Is this ok?

A: Yes. You may give culturally appropriate gifts that are promotional in nature and have a nominal value.

RELATIONSHIPS WITH VENDORS

OUR COMMITMENT

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.

 

OUR EXPECTATIONS

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

 

What If?
Q: I am responsible for selecting a new supplier, and one supplier I am considering offered me expensive luxury box tickets to a sold-out major sporting event. May I accept this?

A: In this situation, your personal interest in receiving the tickets conflicts – or at least appears to conflict – with your responsibility to select the best vendor for CoorsTek. You should consult with your supervisor, the CoorsTek HR Department, or the CoorsTek Legal Department before accepting the tickets. It may be okay to accept these tickets if they are offered infrequently, their cost is not overly lavish, the supplier will be joining you, and the supplier is not expecting favorable treatment in return.

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