Team members have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Centerspace wishes the business to operate. The purpose of these guidelines is to provide general direction so that team members can seek further clarification on issues related to the subject of acceptable standards of operation. Contact the Talent & Culture Department for more information or questions about conflicts of interest.
Transactions with outside firms must be conducted within a framework established and controlled by the executive level of Centerspace. Business dealings with outside firms should not result in unusual gains for those firms. Unusual gain refers to bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, the team member, or both. Promotional plans that could be interpreted to involve unusual gain require specific executive-level approval.
An actual or potential conflict of interest occurs when a team member is in a position to influence a decision that may result in a personal gain for that team member or for a relative as a result of Centerspace’s business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the team member is similar to that of persons who are related by blood or marriage.
No presumption of guilt is created by the mere existence of a relationship with outside firms. However, if team members have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to an officer of Centerspace as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.
Personal gain may result not only in cases where a team member or relative has a significant ownership in a firm with which Centerspace does business, but also when a team member or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Centerspace.
Gifts, favors, and payments may be given to others at Centerspace’s expense, if they meet ALL of the following criteria: 1) they are consistent with accepted business practices, including being a budgeted item, 2) they are of sufficiently limited value and in a form that will not be construed as a bribe or payoff, 3) they are not in violation of applicable law and generally accepted ethical standards; and 4) public disclosure of the facts will not embarrass the company. Payments, commissions, or other compensation to or for the benefit of associates of customers (or their family members or associates) not required by written contract are contrary to company policy.
Team members shall not seek or accept, for themselves or others, any gifts, favors, entertainment, or payments without a legitimate business purpose, nor shall they seek or accept personal loans (other than conventional loans at market rate from lending institutions) from any persons or business organizations that do or seek to do business with or is a competitor of Centerspace.
Team members may accept common courtesies usually associated with customary business practices. Any gift with a value of $50 or more must be disclosed to your manager as soon as reasonably possible after receiving the gift. Examples of acceptable gifts may include, but are not limited to: 1) lunch and/or dinner with vendors sometimes including spouses as long as the invitation is extended by the vendor, 2) gifts of small value from vendors such as calendars, pens, pads, knives, gift certificates, etc., 3) the receipt of alcoholic beverages is discouraged, 4) gifts of perishable items usually given during the holidays such as hams, cookies, nuts, etc. are acceptable, and 4) tickets to events (such as sports, arts, etc.) are acceptable if offered by the vendor. These are not to be solicited by the team member. A strict standard is expected with respect to gifts, services, discounts, entertainment, or considerations of any kind from suppliers. Day outings such as golf, fishing and hunting may be acceptable, with prior approval from the appropriate company officer. The vendor must be in attendance and participation by the team member’s family members is not acceptable. More than four gifts from any source in a 12-month period must be disclosed as well, no matter what the dollar amount of any individual gift. It is never permissible, and is grounds for immediate termination, to accept a gift in cash or cash equivalent such as stocks or other forms of marketable securities of any amount.
Policy Owned By: Talent & Culture
Also found in the Centerspace Policy Manual.