Family Relationships

Q: An Olin supplier is looking to hire a management trainee. My son has the right qualifications. How far can I go in recommending my son for the job?

A: You can introduce your son to your business associate and let them take it from there. This could become a conflict of interest if you make any statements to the vendor that implies future business or preferential treatment if your son is hired.

Q: I am responsible for negotiating a service contract with a new supplier. An employee who reports to me recommended a company that is owned by her cousin. The company's reputation is stellar and I would like to include them for consideration. Can I ask the company for a bid even though an employee who reports to me is related to the owner?

A: You may ask the company to compete for the bid as long as the employee who is related does not participate in the bidding or selection process and will not be involved in the management of the supplier should the company be chosen. It is also important to ensure that the employee does not share any confidential information about Olin with the company that could help the company be selected.

Q: Several years ago, I recommended my sister-in-law for a job at Olin and she accepted. Neither she nor I disclosed that we were related by marriage. Recently she was moved to my department where I will have supervisory responsibilities for her. I know that I can handle it impartially, but I'm afraid it would give the wrong impression if others knew of our relationship. She doesn't want to disclose our relationship as she is worried she might be moved to another department. What should I do?

A: It is never a good idea to keep family relationships a secret, even if you do not perceive an immediate need to report them, because ultimately, if job assignments change, you may find yourself in a situation that presents a real or perceived conflict of interest. You should report this relationship promptly to your supervisor or manager so that the situation can be evaluated fully and a decision reached as to whether a reassignment of your sister-in-law is required to prevent a conflict of interest. To do otherwise, would risk your own position as well as that of your sister-in-law's.

Q: Can my niece apply for a job in a department at Olin that I manage?

A: Olin does not allow a direct reporting relationship between family members, however, a family member may be allowed to work in the same department or on the same shift as long as the relationship is fully disclosed and processes are in place to ensure that all job duties and overtime assignments are based on objective criteria. In addition, all pay decisions and job performance evaluations must be handled by an independent person and monitored on an ongoing basis to ensure objectivity and fairness.

Q: I recently learned that an employee who works in my department is negotiating a contract with my wife’s company. Could this create a conflict of interest for me?

A: A conflict of interest, or at least the appearance of a conflict of interest, could arise in this situation because of your supervisory position and the fact that there could be a perception that you have a personal bias in favor of your wife’s company. You should notify your manager of your wife’s employment with the company and remove yourself from any influence, discussions, negotiations or management of the relationship with this company. It is also important to ensure that you do not share any confidential information about Olin with your wife that could help the company in their negotiations with Olin.

Q: What should I do if I'm unsure whether a relationship, activity or opportunity represents a conflict of interest?

A: It is not possible to define every situation that might conflict with your employment at Olin, but you can begin by reviewing Olin's policy and asking yourself several questions:

• Does the activity or opportunity interfere (or appear to interfere) with your ability to do your job at Olin in an objective manner?
• Would you or a member of your family receive any personal benefits because of your position with Olin?
• Would the activity or opportunity put you or a member of your family in competition with the interests of Olin?

If you have answered "yes" to any of these questions, you should disclose the situation to your supervisor or a higher level of management and ask for a conflict of interest review. If a conflict exists, management will work with you to resolve the situation.

For additional Q&As on conflict of interest situations, please refer to the Advice & Guidance page on Olin's Business Practices website.

Policy details, including disclosure responsibilities, are available in Corporate Policy 3.2.

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