The Creative Way

6

Avoiding Conflicts of Interest

Doing What’s Right

What This Means

Why This Matters

Conflicts of interest can be avoided or ad- dressed if promptly disclosed and properly managed. If you are in a situation where there may be a real or perceived conflict of interest, you must: • Comply with our conflict of interest policy • Disclose your situation to your manager, Legal Department or Ethics & Compliance Department • Remove yourself from the decision- making process for how to resolve the situation • Support the subsequent decision

With every choice we make at Creative, it is important to make business decisions based on sound judgment consistent with our long-standing values.

At Creative, we thrive together. We make decisions and act in the best interests of Cre- ative rather than for personal gain.

What Would You Do?

Does this present a problem or conflict of interest?

SCENARIO:

ANSWER:

As a recruiter supporting new business pursuits, Ariana is always under pressure to hire top talent. During a recent proposal crunch, she recommended her brother-in-law for a key position, although she had no say in the final selection.

Yes, this certainly could be perceived as a conflict because of the personal relationship with her brother-in-law. Although he may be a viable candidate, Ariana’s recommendation of his can- didacy could also be at the exclusion of someone more qualified. This conflict should be disclosed prior to the recommendation.

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