A Conflict of Interest exists when an employee’s personal interests are inconsistent with the interests of the Company.

This policy is to prevent employee making or participating in the making of a governmental decision if a financial conflict of interest exists.

Here are examples of how an employee can impact a decision:

– You make a decision by authorizing a purchase, voting as part of a committee action, or by making an appointment.

– You participate in making a decision by giving advice or making recommendations to the decision-maker.

– You influence a decision by communicating with the decision-maker.

Employee: Any individual is currently employed by SGS.

Immediate Family Member: includes an employee’s spouse, domestic partner, child or stepchild, parents, parents-in-law, siblings, and anyone sharing the employee’s household (other than a tenant)/

Relative: includes an employee’s grandparents, spouse’s grandparents, grandchildren, great- grandchildren, step siblings, half-siblings, uncles, aunts, nephews, nieces, and cousins.

Employee – Vendor relationship: a relationship in which an employee, or near relative, acts as an independent contractor for the purpose of renting or selling goods or providing services to the company.

Full disclosure of the employee – vendor relationship must be made as soon as possible practicable in this form

Step 1: Employee provides Direct Manager with detailed information as below

– Name of vendor:

– What products/ services that they are providing:

– The proposed vendor is an immediate family member or relative:

Step 2: Direct Manager informs Chairman for his further actions if necessary