Team Member Handbook Revised January 2023 | Page 11

EMPLOYMENT
Activities or relationships that conflict with our interests or adversely affect the company ’ s reputation should be avoided . We cannot describe every situation that may constitute a conflict of interest ; rather , the purpose of these guidelines is to provide general direction so that you can seek further clarification on issues related to conflicts of interest . Contact the General Manager / CEO if you have any questions about conflicts of interest .
A conflict of interest occurs when your loyalty is , or appears to be , divided between your selfinterest or the interests of a third-party and our interests . The types of conflicts of interest you must avoid include , but are not limited to :
• Accepting , agreeing to accept , or soliciting money or other tangible or intangible benefit in exchange for favorable decisions or actions in the performance of your job or that might appear to influence your decision-making or professional conduct ;
• Accepting employment or compensation or engaging in any business or professional activity that might require disclosure of confidential information or trade secrets ;
• Directly or indirectly engaging in activities that compete with our business interests , including engaging in , owning , managing , operating , joining , controlling , consulting with , participating in the ownership , operation or control of , being employed by , or being connected in any manner with any person or entity which solicits , offers , offers to provide , or provides any services or products similar to those which we offer to our members or prospective members ;
• Accepting employment or compensation that could reasonably be expected to impair your independent judgment in the performance of your duties ;
• Accepting a kickback , bribe , substantial gift , or special consideration as a result of any transaction or business dealings involving us ;
• Giving preferential treatment in business dealings to any person or company in which you , a relative or friend has a significant ownership interest or relationship .
You must disclose actual or potential conflicts or any relationships that may create the appearance of a conflict of interest to your supervisor as soon as you become aware of them so that safeguards can be established to protect all parties .
Whistleblower Protections 109
Effective Date : 04 / 01 / 2019
We strive to create an ethical and open work environment , to ensure we have a governance and accountability structure that supports our mission , and to encourage and enable you to raise legitimate concerns about the occurrence of illegal or unethical actions within our company instead of turning to outside parties for resolution .
We expect you to report activities you consider to be illegal , unethical , or dishonest internally . You are not responsible for formally investigating the activity or determining fault or corrective measures . Instead , as discussed below , appropriate management officials are charged with these responsibilities .
Interlachen Country Club 6