Conflicts of Interest
We make smart, objective choices that put the company and our customers ahead of personal benefit.
We work together to win for our customers, and we don’t allow personal interests or relationships to get in the way. We make decisions openly, thoughtfully and with integrity; this benefits our business and shows everyone that we can be trusted to do the right thing.
We act in the best interests of the company by:
A conflict of interest exists whenever social or family relationships, activities outside of work, financial investments or other personal interests are at risk of interfering with our ability to make unbiased decisions on behalf of the company. We must be careful to avoid even the appearance of a conflict of interest, since it could make others think we’re acting improperly.
Could my proposed decision or action:
If the answer to any of these questions is “yes” or “maybe,” it’s important to seek advice using the resources listed here. If you think you may have a conflict of interest, you should disclose it at Clarios Ethics & Compliance.
Conflicts of interest can take many forms. The following guidance covers some of the more common situations. See also our Conflict of Interest Policy.
We don’t allow the desire to help friends and family influence our decisions at work. We avoid the risk of personal relationships affecting our objectivity by:
Our decisions are not influenced by the prospect of financial gain for ourselves or our family members. We keep personal financial considerations out of business decisions by:
* For guidance on whether a financial interest is significant, see the Conflict of Interest Policy. If you still have questions, please consult the Ethics & Compliance Department.
We win business and build relationships based on trust and mutual value — never through inappropriate gifts or hospitality. We avoid potential conflicts involving the giving of gifts and hospitality by:
We avoid potential conflicts involving the receiving of gifts and hospitality by:
QUESTION: Our team is submitting a quote for a new vehicle program, and we’re expecting to learn the outcome very soon. I’m attending a conference where I’ll see a key decision-maker from the OE. Can I invite him to dinner to make a final pitch for Clarios?
ANSWER: This is not recommended; it could be perceived as attempting to improperly influence the customer. Doing the right thing means encouraging customers to choose us because of the quality of our products and customer service, not because we have given them a valuable gift or provided generous hospitality. Since the timing is so close to the customer’s procurement decision, this could easily be interpreted as an attempt to inappropriately influence the business decision — which is strictly prohibited. It is particularly important to be cautious during the bid process. As long as your contact is not a government official, it would be appropriate to invite him or her to meet over coffee or tea as a way to build the relationship and to answer any questions the prospective customer might have about Clarios.
We use the knowledge gained in the course of our work, and the company’s resources and assets, so that we can better help our customers win. We avoid conflicts of interest or damage to our business by not:
We give our best effort every day at Clarios, not allowing outside jobs or other activities to hinder our contributions to the company’s business. We strive to lead full and productive lives outside of work while not:
QUESTION: A family friend owns and operates an electrical contracting firm, and his firm is one of the best in the local area. I’ve been asked to get bids for some electrical work that needs to be done at the plant. Can I invite my friend’s firm to submit a bid?
ANSWER: Even though this situation is an inherent conflict of interest, that does not mean your friend’s firm cannot bid on the work. However, a number of actions will need to be put in place in order to address the conflict. You must first disclose and document the conflict at the Clarios Ethics & Compliance Forms site. In addition, to ensure transparency and independence, neither you nor anyone who reports directly to you can manage or influence the bid process — you cannot be involved in or influence the decision about which vendor to select. Be sure to review the Conflict of Interest Policy, disclose the conflict, and adhere to the recommended mitigation actions.