Conflict of Interest

Globe's Conflict of Interest policy is applied to all regular employees, officers and directors of Globe and Subsidiaries, including consultants/project hires seconded to or engaged on a full-time basis by Globe. The said policy is included in the Company's Code of Conduct under Article 18:

"ART. 18. Conflict of Interest – It is the obligation of every employee to declare and divulge in writing to the Company his own involvement in any conflict of interest with the Company. Failure on the part of an employee to divulge the same to the Company shall be penalized with DISMISSAL.

In general, conflict of interest will be deemed to exist where an employee has or may possibly have a financial or personal interest divergent with or in conflict with his professional obligations, or where financial or other personal considerations may compromise, or have the appearance of compromising the employee's judgment in the administration, management, decision-making and discharge of his official functions. Personal interest is not confined to the personal involvement of the employee himself -- it may also arise from the employee's family or close personal relationship with a contractor, sub- contractor, customer, competitor, creditor or any other entity that does business with the Company.

While the following list of conflict of interest situations is not exhaustive, it illustrates the types of situations that fall within the purview of this Code:

  1. Being in an official capacity to negotiate, procure, endorse or approve a transaction for and behalf of the Company, either by himself or through a middlemen or agent, with:
    1. a person, or entity where the controlling D is held by the spouse of the employee or his relative within the fourth degree of consanguinity or affinity; or
    2. the former employer of the employee within two (2) years prior to the date of the transaction in question.
  2. Directly or indirectly having financial or pecuniary interest in any business, contract or transaction over which the employee has the occasion to intervene or take part in his official capacity, or which will require his endorsement or approval;
  3. Outside employment, directorship, officership, partnership, consultancy, distributorship, or agency in any company or enterprise which adversely affects the employee's working efficiency and productivity;
  4. Access to sensitive information which may be of value to a person or entity where the controlling interest is held by:
    1. the spouse of the employee or his relatives within the fourth degree of consanguinity or affinity; or
    2. the former employer of the employee within two (2) years prior to the date of the transaction in question.
  5. Having a spouse or relative within the fourth degree of consanguinity or affinity with individuals in the employ of a competitor or business partner;
  6. Investments or other pecuniary or material interest, directorship, officership, partnership, employment, consultancy, distributorship, or agency or sub-agency in a contractor; sub- contractor; customer; competitor; creditor; or any other entity that does business with the Company or which is in competition with the business of the Company;
  7. Borrowing money or property from, or otherwise incurring any debt to, any of the individuals, companies or enterprises mentioned above;
  8. Solicitation or acceptance, whether directly or indirectly, of payments, commissions, rebates, services or gifts of more than nominal value, excessive entertainment, or improper or excessive favors from a contractor; sub-contractor; customer; competitor; creditor; or any other entity that does business with the Company or which is in competition with the business of the Company;
    1. Pre-empting the Company in the purchase of any asset which the Company is interested in acquiring;
    2. Taking for oneself, or passing on to a relative or associate a business opportunity which became known to the employee because of his position in the Company."

To read more on our Conflict of Interest Policy, refer to pp. 77-81 of our Employee Handbook on Code of Conduct.

 

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