Conflicts of Interest

NCG Medical has guidelines to avoid actual or potential conflicts of interest. It is your duty as an employee of NCG Medical to follow the following guidelines about conflicts of interest. If this is not clear to you or if you have questions about conflicts of interest, Human Resources.

Whenever you conduct business with another company, you must work within the guidelines set up and controlled by the executive management of NCG Medical. Business dealings with other companies should not result in unusual gains for those companies. "Unusual gains" means bribes, product bonuses, unique fringe benefits, unusual price breaks, and other windfalls that will benefit the other company or an employee at that company. NCG Medical executive management must first approve any NCG Medical promotional plan resulting in unusual gains for another company.

What is a conflict of interest? An actual or potential conflict of interest is when you are in a position to influence a decision or have business dealings on behalf of NCG Medical that might result in a personal gain for you or one of your relatives. For conflicts of interest, a relative is any person who is related to you by blood or marriage or whose relationship with you is similar to being a relative even though they are not related by blood or marriage.

We do not automatically assume a conflict of interest if you have a relationship with another company. However, if you have any influence on transactions involving purchases, contracts, or leases, you must tell an officer of NCG Medical as soon as possible. By telling us that there is the possibility of an actual or potential conflict of interest, we can set up safeguards to protect everyone involved.

The possibility for personal gain is not limited to situations where you or your relative has significant ownership in a firm with which NCG Medical does business. Personal gains can also result from cases where you or your relative receives a kickback, bribe, substantial gift, or special consideration due to a transaction or business dealing involving NCG.

Policy No.  108