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Bio-Rad iCode Introduction.mp4
Avoiding Conflicts of Interest
We lead with integrity and transparency and never let our own interests conflict with Bio-Rad’s interests. We can’t always avoid conflicts of interest, so we must know how to disclose and manage them properly.
We do not allow our personal interests to compete or conflict with our ability to perform our job objectively for Bio-Rad. We also carefully avoid situations where even the mere appearance could suggest to someone else there may be a conflict of interest.
We speak up right away and come forward to disclose any issues or potential conflicting situations either to our manager or to the Corporate Compliance Department. Conflicts can be confusing and difficult to navigate. We should seek help if we ever have any questions.
Some common conflicts that may arise and require us to seek guidance include:
Supplier and Customer Relationships – if you, your immediate family, or a close friend owns or operates a business partner or customer of Bio-Rad, that relationship could be a conflict of interest.
Financial Interests – if you, your immediate family, or a close friend invest in a company that partners or competes with Bio-Rad, you should disclose that investment, as it could be a conflict of interest.
Close Personal Relationships at Work – if you have direct decision-making authority over a friend, family member, or romantic partner, or that person has such authority over you, this could be a conflict of interest.
Corporate Opportunities – if you take personal advantage of business opportunities, or otherwise personally benefit from information you learn about due to your role at Bio-Rad, it could be a conflict of interest. You must notify Bio-Rad’s Legal Department before you pursue any business opportunity you learn of in your role.
Outside Leadership Activities – if your outside professional activities, for example, serving on boards or committees, interfere with your obligations to Bio-Rad, it could be a conflict of interest. You must obtain written approval from the Corporate Compliance Department before engaging in such outside activities.
Gifts – giving to or receiving gifts from a business partner could be a conflict of interest. You must obtain approval from the Corporate Compliance Department before giving or receiving gifts.
Expectations
- We never let our personal interests interfere with our duty to Bio-Rad.
- We quickly disclose any potential conflicts of interest to the Compliance Department.
- We understand that even the appearance of a conflict of interest can be damaging to Bio-Rad, and we seek guidance when we have questions.
- We avoid business relationships, investments, or other financial interests that might conflict with our role at Bio-Rad.
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Key Terms
A conflict of interest occurs when our personal interests, or the personal interests of our family, friends, or romantic partners, come into conflict with our duty and ability to perform our job for Bio-Rad.
An entity with whom Bio-Rad does transactions. Examples include Bio-Rad vendors, suppliers, distributors, sales agents, consultants, and end-customers.
Gifts include any item (branded or unbranded) that is capable of use by or of value to a third party (or his or her family members, office staff, or friends) for non-educational purposes, even if the item is of minimal value and related to the third party’s work or is for the benefit of patients.
FAQs
A: No. If your brother’s business is under consideration during the hiring process, you must disclose this conflict to your manager and the Corporate Compliance Department. Bio-Rad may choose to hire this cleaning service, but that decision will have to be made by someone at the company with no family connection to the business.
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A: No. You cannot be involved in hiring or supervising someone with whom you have a close personal relationship. Bio-Rad may hire her for a role, but you need to disclose the relationship to Human Resources.
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A: Maybe, but you have to disclose all outside employment to the Corporate Compliance Department. Even though the job is unrelated to Bio-Rad’s business, it still may affect your ability to perform your role and be a potential conflict.
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A: No, the invitation is considered a gift, which could give the appearance of a conflict of interest.
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A: You return the gift certificate to the customer and immediately notify your manager and the Corporate Compliance Department of the gift.
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A: It can be difficult to determine in some cases, but ask yourself the following questions if you think a situation might create a conflict:
- Would other employees or an outsider think it might affect how I do my job?
- Could it affect any decision I might make at Bio-Rad?
- Do I or my family stand to gain anything from my relationship with the third party doing business with Bio-Rad or vice versa?
- Do I feel under any obligation due to my relationship with the third party doing business with Bio-Rad?
- Would I be embarrassed if anyone inside Bio-Rad knew about the situation?
- How might the situation look to customers or suppliers; would they question whether they had been treated fairly?
If the answer to any of the above questions is “yes” or even “perhaps,” you may have a conflict of interest that you need to disclose.
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