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Q. I’m a supervisor and one of my employees
told me a co-worker has threatened to harm him. How do I handle
reports of violence?
A. The Company takes ALL threat reports seriously. Employees
who engage in workplace violence almost always precede their
actions by making threats. For this reason, you shouldn’t
attempt to second guess the seriousness of threats or assume
there is a lack of intent to follow through on them. Contact
your manager and your Human Resources representative immediately
for advice. The possibilities of preventing a potential tragedy
should outweigh any other considerations.
Q. I accidentally spilled a five-gallon can of gasoline in the
company garage. The spill was properly contained. Should I report
this?
A. Federal and State governmental regulations and Company environmental
policy require you to properly report petroleum spills. To report
a spill, call the Company emergency number for your location.
Q. I’m going to be selecting several consultants to provide
services in connection with a long-term systems project. My
brother is a computer consultant and I consider him highly qualified
for the type of work I need. Can I hire him?
A. No. Although he may be qualified, hiring him would create
the appearance of a conflict in interest. This doesn’t
mean that your relative can’t consult for the Company.
However, you may never supervise him, not can you be involved
in the decision to hire him.
Q. I currently have stock in a company that I have recently
learned will be a customer of ours. I have been asked by my
supervisor to work on the account for this company. Can I do
this?
A. More than likely, no. As a Company employee, you are obligated
to advise the Company of any investments you may have in the
business of customer companies.
Q. I recently met with one of our customers. This customer mentioned
he had an all expenses-paid trip coming up, but was unable to
go because of company business. He then offered the trip to
me. Can I accept?
A. No. This gift could be seen as an attempt at improperly influencing
our business. If the customer continues to make offers like
this, you can seek advice from the Company Ethics Office or
Legal Department.
Q. A supplier just personally offered me a 15% discount. Is
this appropriate?
A. You cannot accept a personal discount unless the supplier
offers the discount to the general public or to all Company
employees.
Q. Do all government agencies have the same regulations concerning
the acceptance of meals and entertainment?
A. No. Regulations differ among federal, state, local and foreign
government agencies. Before offering any gifts, meals or entertainment,
make sure you know the applicable regulations. Contact the Company
Legal Department for guidance in this area. Gratuities offered
to foreign government officials are also regulated by the Foreign
Corrupt Practices Act. All gifts to, or entertainment
of, foreign officials must comply with the Company’s Foreign
Corrupt Practices Act Compliance Policy and Foreign
Official Hospitality Guidelines.
Q. I was recently assigned to a Company office in a foreign
capital and I attempted to get a driver’s license immediately
after arriving. The government licensing official told me that
it could take three months to obtain a license, however, for
a fee of $5,000, instead of the normal $75, he could expedite
the process for me. Can I pay the $5,000 to expedite the processing
of my driver’s license?
A. No. While the Foreign
Corrupt Practices Act allows for the payment of small
amounts of money to obtain routine, non-discretionary, government
services, a payment of $5,000 would likely be categorized as
a bribe, and impermissible under the Foreign
Corrupt Practices Act. All facilitating payments
must comply with the Company’s Foreign
Corrupt Practices Act Compliance Policy and must
be approved in writing by the Company’s Legal Department
prior to payment.
Q. One of our competitors asked me to agree to alternate contracts
with him. One time our Company would bid the lower price, and
the next time we would let his company bid the lower price.
Is it proper to discuss pricing patterns with him?
A. No. You should never discuss pricing plans with a competitor,
nor should you have access to competitor’s pricing plans
unless they are publicly available.
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