INC-52082

Why report a potential conflict of interest? Transparency is a foundational component of avoiding conflicts of interest. When a potential conflict is shared, it can be discussed and addressed. Plus it is the right thing to do. It also helps address any misperceptions and provides an opportunity to develop an effective plan of action.

• During the application or interview process or at the start of employment


• During the annual conflict of interest attestation process


• When a situation arises in which there is a potential, perceived, or actual conflict of interest

Share the potential conflict of interest with your manager, HR, or a member of the Integrity & Compliance team. After a Disclosure, here's what happens next:

• Review: HR will consider the potential conflict and its impact. Your HRBP may consult with I&C and/or Legal


• Recommendation: the team suggests a path forward


• Actions: the outcome could range from approval or acknowledgement (with no action), to a management plan, with steps to address the conflict