Test Your Ethics I.Q.

Consider this situation...

You're in a position to select a consultant for some work at Olin. Your friend Bob has experience in the field and you know he would do a good job at a fair price. Does it matter if you choose Bob for the job?

Hiring decisions should be based only on the qualifications of the applicants. Even if Bob is well qualified and the best candidate, the fact that Bob is your friend could create the perception of a conflict. If it appears to other candidates, your fellow employees, customers, or our vendors that Bob was hired because of your personal relationship, the integrity of our company's decisions are compromised.

Furthermore, once Bob is hired, are you sure you can supervise his work without letting your friendship influence your evaluation? Even if you think you can do that, it might still appear to others that you can't separate Bob, your friend, from Bob, your consultant -- and that can lead to misunderstandings, disagreements, or even litigation.

Would your answer be different if you had a financial interest in Bob's company?

In this case, even if you disclosed your financial relationship as well as your friendship with Bob, the situation not only appears that you are favoring a friend, but Bob's selection could also benefit you financially. This situation clearly involves a conflict of interest that would eliminate Bob and the company from consideration.

Do I need to disclose any financial interest in an outside company?

If you own a small amount of stock in a company that does business with Olin, for example through a mutual or stock fund, you need not disclose this information. However if you or a member of your immediate family are a significant shareholder in an Olin competitor, customer, supplier, subcontractor or other business partner, you should disclose this information to your manager as soon as you become aware of it. We define "significant" as a 5% or more ownership interest in or obligation to the company.

Would it ever be OK to recommend Bob for a job at our company?

Yes, as long as you are not involved in the hiring decision and would not be involved in supervising Bob while on the job. To avoid misunderstandings, you still need to make it clear from the start that Bob is a good friend.

To learn more about potential COIs and your responsibility to disclose them, refer to the following resources:

• Olin's Code of Conduct
• Our policy on Conflicts of Interest (CPS 3.2)
• Olin's new Conflict of Interest Brochure
• The Advice & Guidance page on Olin's Business Practices website

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