Avoid conflicts of interest and refrain from any appearance of impropriety

A “conflict of interest” occurs whenever private or personal interests interfere with performance of duties or the best interests of the company as a whole. We should avoid conflicts of personal interests with GMCR interests and even situations that may appear to constitute a conflict of interest. Each of us is responsible for avoiding relationships that might impair loyalty to GMCR or affect personal judgment regarding what is in the company’s best interests.

Examples of conflicting arrangements include: loans or guarantees to employees, officers or directors; gifts to or from employees, officers or directors; and relationships with competitors or suppliers. Things to consider in evaluating whether a situation presents a conflict of interest: interference of one’s job; adverse or beneficial impact on business or GMCR relationships; enhancement of a competitor’s positioning; and the extent to which the action or relationship appears improper to an observer. Conflicts of interest are prohibited unless the Board of Directors gives specific authorization to a particular situation.