Sample Employee Handbook Policies:

The Conflict of Interest Statement

Writing an employee handbook is a challenge; use a sample employee handbook; or employee handbook templates. For example, provided below is a sample conflict of interest statement. Note: follow the conflict of interest policy guidelines for your region or country as there are specific laws for each jurisdiction.

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Sample Employee Handbook: Conflict of Interest Statement

First, why is a conflict of interest statement necessary or desirable? Because there are times when an employee may find themselves in a potential conflict.

For example, if your employee's spouse or a family member works in the same industry that you operate in, they may share confidential information without realizing it.

Another, more common, example is when an employee holds two jobs in the same industry - where does the employee's loyalty rest? How would the employee face a conflict in the interests between the two jobs?

To protect both employees and you as the employer, it is necessary to define clearly what your expectations are; developing a conflict of interest statement will achieve that goal.

This sample conflict of interest policy was written for a North American jurisdiction or region. On a global basis, there may be different requirements, rules or regulations. Find out what the rules are in your area before using, and/or adapting, this policy.

The policy needs to have a date of issue, and any revision dates, and needs to also have the author’s name on it (for further reference - for example: John Smith, Human Resources Manager, XYZ Company, Issued November 1, 2009; Revised November 12, 2009 (the best position for this information is either in the page header or footer – so that it appears on all pages).

Sample Conflict of Interest Statement or Policy

Policy Statement

All persons employed by __________ (the "Company") owe a duty of fidelity to the Company. Employees must never place themselves in a position where their self-interest may conflict with this duty.

Any employee who breaches this policy is subject to disciplinary action, up to and including discharge.

Code of Conduct

All employees of the Company are expected to comply with the following Code of Conduct:

  • Duty of Fidelity

    Employees owe a duty of loyalty and fidelity to the Company. Employees are expected to perform their duties on behalf of the Company faithfully, diligently and to the best of their abilities.

  • Conflict of Interest

    Employees must never allow themselves to be placed in a position where their personal interests are in conflict (or could be in conflict) with the interests or business of the Company.

    Employees must avoid any situation or activity that compromises, or may compromise, their judgement or ability to act in the best interest of the Company.

  • Disclosure of Potential Conflicts

    Employees must promptly disclose to the Company material information regarding any relationship, ownership or business interest (other than non-controlling investments in publicly-traded corporations), whether direct or indirect, that the employee or a member of his/her immediate family has with any person, or in any business or enterprise, that:

    1. competes with the Company; or
    2. purchases or sells, or seeks to purchase or sell, goods or services to or from the Company.

  • Protective Steps

    Upon disclosure of the information described above, the Company will take appropriate steps to protect against any actual or potential conflict of interest. Such steps may include:

    1. requiring the employee to refrain from being involved in any decisions made by the Company regarding its dealings with such person, business or enterprise; or
    2. requiring the employee to refrain from being involved in any dealings on behalf of the Company with such person, business or enterprise; or
    3. requiring the employee to dispose of his/her interest in such business or enterprise if he/she wishes to remain in the Company’s employ.

  • Harm to Business or Reputation

    Employees must refrain from engaging in conduct that could adversely affect the Company’s business or reputation. Such conduct includes, but is not limited to:

    1. publicly criticizing the Company, its management or its employees; or
    2. engaging in criminal conduct or other behavior that could harm the Company’s business or reputation.

  • Gifts or 'Kickbacks'

    Employees must never accept any 'kickbacks', loans, gifts of other than nominal value (less than $50), or personal payments of any kind, from any person or business enterprise that:

    1. competes with the Company; or
    2. purchases or sells, or seeks to purchase or sell, goods or services to, or from, the Company.

  • Company Funds and Property

    Employees must be conscientious and scrupulous in their handling of funds and property belonging to the Company, and must always avoid any form of financial impropriety.

    Employees must not use, or permit the use of, Company property or resources for anything other than approved Company business or activities. Examples of unauthorized use would include using Company computers or photocopiers for personal purposes.

  • Confidential Information

    Confidential information (printed, electronic or otherwise) relating to the Company’s past, present, future and contemplated assets, operations, products or services, industrial designs, inventions, production methods, marketing strategies and objectives, personnel, facilities, equipment, finances, pricing, interest rates, sales, customers, routines, policies, and business procedures must never be disclosed to anyone outside the Company’s organization, without the Company’s express written authorization.

  • Outside Employment or Business Activity

    During working hours, employees are expected to devote their full time and attention to the business and the affairs of the Company.

    If an employee wishes to engage in employment or business activity outside his/her employment with the Company, the employee must first disclose to the Company the nature and extent of the proposed employment or business activity, and obtain the Company’s written approval. Approval will only be withheld if the Company reasonably determines that the employee’s proposed outside employment or business activity could conflict or compete with the interests of the Company, or could negatively affect the employee's job performance or attendance.

By signing this policy, I acknowledge understanding of the above policy and acceptance of the policy guidelines and constraints.


Employee Signature and Date

Sample Employee Handbook:

What are the Most Important Parts of the Conflict of Interest Policy?

The most relevant parts of a conflict of interest statement are:

  1. to ensure that the employee clearly understands what conflict of interest is;
  2. that conflict statement meets the legal requirements of your region/country;
  3. that it has a requirement for the employee to sign, date and indicate acceptance and agreement;
  4. and that it clearly identifies to the employee the sanctions or consequences of failure to comply with the policy.

The best time to require an employee to read and acknowledge understanding and acceptance of the policy is prior to the first date of employment; in other words this policy would be part of the employment letter offer. However, if that is not possible, then as soon as you develop your policy, have a meeting with employees (either individually or in a group), explain the purpose of the policy, and have the employees review and acknowledge their understanding and acceptance of the policy (by signing and dating a copy).

Each employee needs to be given one copy of the signed policy for their records; and if you build other policies for your business, keep this policy in the employee handbook (which needs to contain a complete set of all company policies and practices).

This sample conflict of interest statement is just one of the policies that need to be part of your employee handbook. Sample employee handbook templates can be developed for all policies; create with a similar ‘look and feel’ to keep the style easily readable and recognizable. This is an excellent project to outsource: there are many human resource professionals who can produce good quality policies: ask to see sample employee handbook policies before you engage them to do your policy writing.

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