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Anti-Corruption Training II

Conflict of Interest

© SII Group | SII Internal Use

8 rue des Pirogues de Bercy, CS 42112 75580 PARIS CEDEX 12

Document exclusive property of SII, communication, reproduction and use are prohibited without prior written authorization of SII

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What is a conflict of interest ?

Definitions

Examples

SII Group Policy

Prevention

© SII Group | SII Internal Use

Definition

Conflict of Interest

A person is in a conflict of interest situation when their private interests may influence their professional decisions, thereby compromising their ability to act impartially and objectively.

It can arise when a personal interest conflicts with your professional duties and the interests of the SII Group, creating a potential bias in your decisions.

I must follow a fair recruitment process based solely on the candidates’ skills.

I will propose a relative as a candidate.

A risk situation that can foster an act of corruption.

Not illegal in itself.

Recruitment Manager

© SII Group | SII Internal Use

Prevention

Why implement prevention measures?

Risk of corruption.

Increased risk of prioritising personal interest over professional interest.

© SII Group | SII Internal Use

Prevention

Behaviour expected by the SII Group

Identify the conflict of interest

Declare the conflict of interest

Refrain from taking part in the decision

In case of doubt, you can contact the Ethics Committee or the Ethics Officers.

© SII Group | SII Internal Use

SII Group Policy

Avoid any biased decision-making

To avoid any biased decision-making, you must refrain from taking part in the decision when you are in a conflict of interest.

Inform your line manager of any potential conflict of interest

« All employees should avoid being confronted with situations in which their personal interests, or those of individuals or legal entities to which they are linked, conflict with the interests of the entities of the group.If he/she is unable to avoid such a situation, the employee in question shall act honestly and fairly towards SII Group."- Ethics Charter-

© SII Group | SII Internal Use

Example (1)

You are the Purchasing Manager of the SII Group.

Your role is to select suppliers. A tender is launched for the purchase of IT equipment. Among the candidate companies is Numerix, a company managed by your cousin. The quotation from this company is competitive, but other suppliers are also offering attractive proposals.

© SII Group | SII Internal Use

Example (1)

What behaviour should be adopted?

Declare to your manager that you have a family connection with one of the suppliers and refrain from taking part in the decision related to this tender.

© SII Group | SII Internal Use

Example (2)

You are a member of the company’s Board of Directors.

You also hold shares in a competing start-up that is rapidly growing. During board meetings, you influence strategic decisions in a way that slows down investment in certain innovative projects, knowing that your competing start-up is working on similar solutions and could gain a market advantage.

© SII Group | SII Internal Use

Example (2)

What behaviour should be adopted?

Declare your personal investments.

Do not take part in decisions concerning companies in which you have a personal interest.

© SII Group | SII Internal Use

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Be careful, it's not over yet!
The next module is a Quiz

To access the next course, click on exit the course and then on continue.

To access the next course, click on exit the course and then on continue.

100%

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

Imagine that you are the Purchasing Manager of the SII Group. Your role is to select suppliers. A tender is launched for the purchase of IT equipment. Among the candidate companies is Numerix, a company managed by your cousin. The quotation from this company is competitive, but other suppliers are also offering attractive proposals. Is this a conflict of interest?

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

The SII Group policy states that anyone in a conflict of interest situation must inform their line manager and refrain from taking part in the decision. More specifically, the Ethics Charter provides that: « All employees should avoid being confronted with situations in which their personal interests, or those of individuals or legal entities to which they are linked, conflict with the interests of the entities of the group.If he/she is unable to avoid such a situation, the employee in question shall act honestly and fairly towards SII Group."

The proper behaviour when facing a conflict of interest situation is to: - Identify the conflict of interest - Declare the conflict of interest - Refrain from taking part in the decision In case of doubt, you can contact the Ethics Committee or the Ethics Officers. You may also refer to the Anti-Corruption Code of Conduct, the Gifts and Invitations Policy, or the Whistleblowing System User Guide.

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

1. Definitions

2. Prevention

3. SII Group Policy

4. Examples

Imagine that you are a member of a company’s Board of Directors. During board meetings, you influence strategic decisions in a way that slows down investment in certain innovative projects, knowing that your competing start-up is working on similar solutions and could gain a market advantage. Is this a conflict of interest?

A person is in a conflict of interest situation when their private interests may influence their professional decisions, thereby compromising their ability to act impartially and objectively. Example: An HR Manager at SII is responsible for recruiting an employee for a key position. If one of the candidates is a close friend or a family member, there is a risk that this personal connection could influence their decision. ⚠️ A conflict of interest is not an offence in itself, but it creates a risk that could foster an act of corruption if it is not identified and managed properly.

Managing conflicts of interest is essential to safeguarding integrity, transparency, and trust within an organisation. When an employee is in a situation where their personal interests conflict with their professional responsibilities, this creates a risk of biased decision-making. They may be tempted to prioritise their personal interest over the company’s interest or the integrity of their role. Such circumstances can foster passive corruption, where someone accepts or offers to carry out an act related to their duties in exchange for a personal benefit. This is why it is crucial to implement clear mechanisms to identify, declare, and manage conflicts of interest, in order to prevent any ethical or legal misconduct and to protect the company and its employees from corruption risks.