OUR COMPANY
Conflicts of Interest
At Qnity, we must ensure that our personal interests and activities do not interfere with our responsibilities to the company. This includes avoiding even the appearance of a conflict of interest. If a potential conflict arises, it is our responsibility to disclose it so management can review and address the situation.
Recognizing Conflicts
Conflicts of interest may include:
- Outside work or activities that interfere with company duties.
- Use of insider information for personal gain.
- Financial interests in companies that do business with or compete against Qnity.
- Family or personal relationships that could affect decisions.
Family Members and Relationships
Managers must not oversee family members or have romantic relationships with persons they supervise. Report such situations immediately so management or HR can address them.
Family members include close relatives like parents, children, siblings, in-laws, and others living in the same household. Other relationships may also create conflicts. Managers should assess these situations on a case-by-case basis.
External Employment, Work, or Activities
To avoid conflicts with outside activities, you must not:
Take roles such as director, officer, partner, consultant, or other key positions with organizations that do business with or compete against Qnity.
Act as an intermediary in transactions involving Qnity.
Take outside jobs or start businesses that interfere with Qnity responsibilities.
Serve in government roles that conflict with company duties.
Use Qnity property, information, or time for personal gain.
Use your Qnity title or position in ways that imply company support for outside activities.
Use Qnity supplies or facilities for outside activities without manager approval.
Before engaging in activities such as publishing, speaking, or consulting, check with your manager to ensure they don’t conflict with your role at Qnity.
Examples of Corporate Opportunities
Using a Discovery for Personal Gain
You identify a compound from a research project that could have market value outside of Qnity and, without authorization, share this information with an external party to pursue the opportunity independently.
Taking a Real Estate Opportunity
You learn that Qnity may want to purchase local property, so you buy it first to sell back at a profit.
Commercializing a Qnity Innovation
Your team creates a process that reduces pollutants, and you try to sell it to other companies independently.
Taking personal advantage of these opportunities violates our policies and values.
Disclosing and Addressing Conflicts
Disclose any potential conflicts promptly to your manager, a Corporate Compliance Officer, or Legal. These disclosures should also be included in the annual Business Ethics Certification. Management will review and resolve conflicts confidentially, consulting Ethics & Compliance Central as needed.
Significant Financial Interests
A “significant financial interest” is defined as any one of the following:
- More than 1% ownership in a public company.
- More than 10% ownership in a private company.
- More than 5% of your total assets or income.
Consult your manager or Legal if you are unsure about financial interests that could create conflicts.
Q&A
I’ve been asked to speak at an event related to my job skills. Can I accept?
Maybe. First, check with your manager. If the event is connected to your work or industry, you need approval to make sure it doesn’t create a conflict or appear to represent Qnity without permission.
Learn More
- Qnity Employee Access