Stormtech Associate Handbook California

CONFLICT OF INTEREST

1. PURPOSE Stormtech is committed to conducting business in a manner that ensures business judgment and decision making is not influenced by undue personal interests. When personal interests either influence, have the potential to influence, or are perceived to influence decision making at Stormtech, a conflict-of-interest situation result. This policy explains which conflicts of interest may arise in the workplace and guidelines to follow when facing an actual, potential, or perceived conflict of interest. 2. SCOPE This policy applies to all Stormtech associates working in the State of California. 3. DEFINITIONS Stormtech defines conflicts of interest broadly: • Actual conflicts of interest: the Associate faces a real, existing conflict. • Potential conflicts of interest: the Associate is in or could be in a situation that may result in a conflict. • Perceived conflicts of interest: the Associate is in or could be in a situation that may appear to be a conflict, even if this is not the case. Common examples of conflict of interest situations include, but are not limited to: personal workplace relationships (hiring or supervising a closely related person), external mandates (serving on the board of directors or advisory board of a Stormtech competitor), outside employment (having a second job with a Stormtech customer, supplier, or competitor), promoting personal financial interests (owning a substantial share of a Stormtech supplier while in a position to steer Stormtech business towards it), and receiving fees, commissions, discounts, gifts, entertainment, or services (receiving lavish gifts of a substantial value or cash from a Stormtech business partner). 4. POLICY • It is Stormtech’s policy that all associates must avoid any situation that creates or may create a conflict between their personal interests and the interests of Stormtech. • Associates must immediately disclose any conflicts of interest (actual, potential or perceived conflicts of interest) or any situation that involves or may involve a conflict between the associate’s personal interests and the Company’s personal interests, to their Manager or People & Culture as soon as it becomes known. Having a conflict of interest may not necessarily be wrong and may be difficult to avoid in some cases; however, it can become a problem or a legal matter. As such, transparency in the form of disclosure is critical to protecting the integrity and reputation of Stormtech and Associates. • Each situation will be evaluated case by case to determine appropriate recourse. • Associates must disclose secondary employment to their respective manager to validate a conflict of interest does not exist. • Associates may engage in outside business activities, provided such activities are disclosed to their manager and do not adversely affect Stormtech or the associate’s job performance. Associates are prohibited from engaging in financial participation, outside employment or any business undertaking that is competitive with or prejudicial to the best interests of Stormtech.

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