Conflict of Interest Policy

Conflict Of Interest Policy

The Company is committed to provide an encouraging work environment to its employees, and be an engaging business partner to its clients and service providers. It is the policy of CPGI to promote discipline in the organization by taking corrective action as may be needed for the protection of all employees and clients, CPGI’s properties and interests. These rules were prepared to ensure fair and consistent treatment and constructive actions of any employee who has made a mistake.

 

The responsibility of ensuring that discipline exists in CPGI is jointly vested upon HRD, Department Heads and Supervisors. All supervisors and Department Heads should encourage the development of an environment where positive discipline comes naturally.

 

Our company’s  Conflict of Interest Policy refers to any case where an employee’s personal interest might contradict the interest of the company they work for. This is an unwanted circumstance as it may have heavy implications on the employee’s judgement and commitment to the company, and by extension to the realization of its goals.

This policy outlines the rules regarding conflict of interest and the responsibilities of employees and the company in resolving any such discrepancies.

Scope

This company conflict of interest policy applies to all prospective or current employees of the company, as well as independent contractors and persons acting on behalf of the company.

Policy elements

The relationship of the company with its employees should be based on mutual trust. As the company is committed to preserve the interests of people under its employment, it expects them to act only towards its own fundamental interests.

Conflict of interest may occur whenever an employee’s interest in a particular subject may lead them to actions, activities or relationships that undermine the company and may place it to disadvantage.

The possibility that a conflict of interest may occur can be addressed and resolved before any actual damage is done. Therefore, when an employee understands or suspects that a conflict of interest exists, they should bring this matter to the attention of management so corrective actions may be taken. Supervisors must also keep an eye on potential conflict of interests of their subordinates.

The responsibility of resolving a conflict of interest starts from the immediate supervisor and may reach senior management. All conflicts of interest will be resolved as fairly as possible. Senior management has the responsibility of the final decision when a solution cannot be found.

In general, employees are advised to refrain from letting personal and/or financial interests and external activities come into opposition with the company’s fundamental interests.

Disciplinary Consequences

In cases when a conflict of interest is deliberately concealed or when a solution can not be found, disciplinary action may be invoked up to and including termination

 

Policy measures have been promulgated and will be continuously promulgated, as the need arises to supplement, implement and amend any of the provisions contained herein.

 

Business Conduct & Ethics Directors Senior Management Employees
(a)      Conflict of Interest Does not vote on activities in which there is a conflict of interest Are not allowed to be involved in the decision making process if conflict of interest is present Are not allowed to be involved in the decision making process if conflict of interest is present
(b)      Conduct of Business and Fair Dealings Should follow best practices and company policies Should follow best practices and company policies Should follow best practices and company policies
(c)     Receipt of gifts from third parties  

Based on The Code of Conduct & Discipline, and Offenses & Corresponding Penalties

 

 

Based on The Code of Conduct & Discipline, and Offenses & Corresponding Penalties

 

 

Based on The Code of Conduct & Discipline, and Offenses & Corresponding Penalties

 

(d)     Compliance with Laws & Regulations Monitored by the compliance officer and other officers Monitored by the compliance officer and other officers Monitored by the compliance officer and other officers
(e)     Respect for Trade Secrets/Use of Non-public Information Policy on non-disclosure in place. Discouraged from using such information Policy on non-disclosure in place. Discouraged from using such information Policy on non-disclosure in place. Discouraged from using such information
(f)      Use of Company Funds, Assets and Information Regulated through Manual on Corporate Governance Regulated through Manual on Corporate Governance Regulated through Manual on Corporate Governance
(g)     Employment & Labor Laws & Policies Meet at least the minimum criteria set by the labor authorities Meet at least the minimum criteria set by the labor authorities Meet at least the minimum criteria set by the labor authorities
(h)     Disciplinary action Based on Manual of Corporate Governance Based on Manual of Corporate Governance and Company policy Based on Manual of Corporate Governance and Company policy
(i)       Conflict Resolution  

Based on The Code of Conduct & Discipline, and Offenses & Corresponding Penalties

 

 

Based on The Code of Conduct & Discipline, and Offenses & Corresponding Penalties

 

 

Based on The Code of Conduct & Discipline, and Offenses & Corresponding Penalties