We all must act in the best interest of HARMAN and our stakeholders.
Integrity
Avoiding Conflicts of Interest
Our Commitment
Why It Matters
By disclosing potential conflicts of interest, we build HARMAN’s corporate brand and reputation by doing what is right without compromise.
If you inform the Legal & Compliance Department or the HR Department of a conflict of interest, HARMAN will review the situation to evaluate what additional steps may be required. These range from granting a waiver to monitoring and other steps to remediate the situation.
Making Connections: What Is a Conflict of Interest?
A conflict situation can arise when an employee, officer or director:
- Takes actions or has interests that may make it difficult, or even appear to make it difficult, to work objectively and effectively.
- Receives improper personal benefits as a result of their position at HARMAN. This applies to family members as well.
Many conflicts of interest situations are obvious, but others are not. They can include the following:
- Corporate opportunities
- Competition and fair dealing
- Business entertainment and gifts
Making Connections: What Is a Corporate Opportunity?
A corporate opportunity is any business opportunity that may benefit a corporation such as:
- Investment
- Potential joint venture
- Intellectual property
How We Avoid Conflicts of Interest
- Promptly share corporate opportunities with HARMAN leadership.
- Don’t personally take opportunities that you discover through your work with HARMAN.
- Do not own, invest in, or work for our competitors, customers, suppliers, or other third-party stakeholders while also working as an employee of HARMAN.
- Notify your supervisor and the Legal & Compliance Department if you own or invest in any firm where HARMAN may do business. Small investments in publicly traded companies, such as through a mutual fund, do not represent a conflict of interest.
- Don’t withhold information about any substantial ownership interest, board seat or other potential conflict you may have.
- Contact the Legal & Compliance Department if you have questions about corporate opportunities.
- Disclose potential conflicts of interest to your supervisor and the Legal & Compliance Department.
- Promptly disclose familial or close personal relationships in direct reporting lines and/or before weighing in on hiring, termination or other actions that impact employment, compensation or benefits.
Connecting the Dots: Q&A
Yes. You should disclose your activities so the Company can determine whether any actual or potential conflict exists. It’s important that we’re all making objective, sound decisions that put our Company’s interests first.
Secondary employment can be considered a conflict of interest, especially when you are performing the same type of work for another company. As an employee, you have access to Company systems, customer information, Company and department policies and procedures and other sensitive information. We want to be certain that our Company information is protected. You should disclose the potential conflict of interest to the Legal & Compliance Department using the Conflicts of Interest Disclosure Tool or by contacting them directly. The Legal & Compliance Department will review the situation and determine the best course of action.
This situation could create a conflict. It may be necessary for you to remove yourself from the selection process. You should disclose it to your manager or supervisor immediately and disclose the potential conflict using the Conflicts of Interest Disclosure Tool. The Legal & Compliance Department will determine next steps.