Page 12 - TMCF 2025 HR Team Manual

CONFLICT OF INTEREST
An actual or potential conflict of interest occurs when a team member is
in a position to influence a decision that may result in a personal gain for that team member or for a relative, as a result of TMCF’s business dealings. For the purpose of this policy, a relative is defined as any person who is related by blood, marriage or other legally recognized means (e.g., adoption, guardianship, etc.), or whose relationship with the team member is similar to that of persons who are related by blood or marriage.
TMCF welcomes the opportunity to hire prospective team members
who are relatives of existing team members, as previously defined. However, it is the policy of TMCF that any team member of TMCF who is a relative of another team member, shall not be in any direct administrative or operational authority over his or her relative. Furthermore, relatives should not be employed within the same department.
In simpler terms, this means that a relative cannot be a direct supervisor in his or her relation’s chain of command. In addition, it shall not be appropriate to make employment decisions based on a given prospective candidate’s family relationship (e.g., relatives), whether internal or external to the workplace.
Personal gain, defined as a personal tangible or intangible benefit or advantage, may result in cases where a team member or a team member’s relative has an ownership interest in a business or other organization with which TMCF does business, as well as when a team member or their relative receives any undue benefit, kickback, bribe, substantial gift or special consideration as a result of any transaction or business dealings involving TMCF. No presumption of guilt is created by the mere existence of a potential conflict of interest. However, if team members have any potential to influence transactions involving, for example, purchases, contracts or leases, it is imperative that they disclose the existence of that actual or potential conflict of interest to their supervisor or the human resources department as soon as possible, so that appropriate safeguards can be instituted to protect all parties involved.
The exchange of tokens of appreciation is commonplace in today’s business world. However, to ensure that
any such gifts are not viewed as conflicts of interest in accordance with TMCF’s policy or a contract or grant as it relates to gifts, favors, entertainment and/or payments, team members should contact their supervisor before accepting any gift when the estimated fair market value is more than $50, except the accepted business practice of being treated to meals.
In general, it is TMCF’s policy that all business be conducted in such a manner that TMCF and each team member would be willing to make full disclosure of all such activities if called upon to do so. Team members have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which TMCF operates. The purpose of these guidelines is to provide general direction so that team members can seek further clarification on issues related to the subject of acceptable standards of operation. Team members can contact their supervisor or the human resources department for more information or questions about conflicts of interest.
TMCF TEAM MANUAL | 11