Conflict of Interest Policy
Appendix 2: Conflict of Interest Policy
Policy Statement
Andiamo is committed to ensuring that its decision-making processes are not influenced by undue personal interests. Andiamo understands that the presence of a conflict of interest does not itself necessarily result in improper behaviour. In fact, there may be legitimate business reasons for engaging in activities or transactions which result in such conflicts. Andiamo is committed to ensuring that where there are any conflicts of interest, these are disclosed and recorded, thereby improving transparency and helping to safeguard the integrity of Andiamo and our employees. Employees are always required to act in the best interests of Andiamo. Any conflict of interest should be discussed with and approved by the employee’s direct manager.
Definition of conflict of interest
A conflict of interest arises where an employee’s personal or financial interests, or the interests of a Closely Related Person, conflict or potentially conflict with the interests of Andiamo, or where such interests unduly influence their business judgments, decisions or actions.
A Closely Related Person is:
- a close family member of an employee, being a spouse or partner, a dependent child, a sibling and the spouse or partner of that sibling, a parent or parent-in-law, and any other relative with whom the employee shares the same household (“Family Member”); or ii. a company or other entity (including a trust or partnership), which is owned, managed, influenced or controlled by an employee or Family Member, including those entities in
which the employee or Family Member holds a key position. Common examples of conflicts of interest include:
- purchasing goods or services in the name of Andiamo from a Closely Related Person;
- hiring or supervising a Closely Related Person;
- becoming a contractor, consultant or supplier to Andiamo while being employed at Andiamo; and
- having another job with one of Andiamo’s customers or competitors.
A conflict of interest may also arise where an employee’s actions or recommendations are influenced by bribes or gifts and hospitality. Please see the restrictions and recommendations set out in the Anti-Bribery Policy (Appendix 4) and Gifts and Hospitality Policy (Appendix 5).
Contact
Andiamo Group Pty Ltd
ABN: 32 138 556 975
Melbourne: 26/50 Bourke Street, Melbourne, VIC 3000
Sydney: Suite 149, 117 Old Pittwater Road, Brookvale, NSW 2100
Brisbane: Level 10, 15 Green Square Close, Fortitude Valley, QLD 4006
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Phil Obst: 0409 363 970 (Sydney)
Carl Xie: 0409 363 978 (Brisbane)
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