Puget Consumers Co-op strives to conduct its business ethically and in accordance with its co-op purposes and values. To ensure that PCC has internal transparency into all aspects of business decisions and practices, PCC has established the following policy covering circumstances that impact how business decisions are made at PCC.
For purposes of this policy, a “Related Party” includes a spouse or domestic partner, parents, grandparents, children, siblings, relatives by marriage (brother or sister-in-law, father or mother-in-law, son or daughter-in-law) or anyone who shares your home (including a tenant), or anyone with whom you have a significant personal relationship.
Sometimes, our personal, family or business relationships impact how we make business decisions, or can appear to influence those decisions. To ensure the decisions made on behalf of PCC are made ethically, free from bias or improper influence, or the appearance of bias or improper influence, no one should make business decisions involving (1) Related Parties (as defined above) or (2) any entity or person with whom they have a business relationship or interest outside of PCC.
- An example of a conflict of interest would be if you were in charge of purchasing first aid supplies for the stores, and your sister happened to be the owner of a large first aid supply company. If you were to choose your sister’s company to sell first aid supplies to the stores over other, lower bidders who could meet the stores’ demands because of your family relationship, that is a direct conflict of interest.
- If you were to choose your sister’s company over other bidders because she was the lowest bidder and her company can meet the stores’ demands, even though you did not choose her because of your family relationship, some people may assume that the choice was made because of that relationship. That is an appearance of conflict of interest.
All staff members who have the ability to commit PCC to financial obligations (which includes directors (including store directors), Vice Presidents, the CEO, the CFO and all members of the Merchandising team), and all members of our Board of Trustees (each a “COI Person”), will be required to complete an annual questionnaire to identify any potential conflicts of interest that may arise as a result of personal, family member or business relationships. Those who are required to answer the questionnaire are expected to do so honestly and completely – there are no wrong answers.
Any disclosures provided in the questionnaire that may give rise to a conflict of interest will be reviewed by PCC’s CEO and General Counsel to determine if changes in the decision-making process should be made to avoid any potential conflict of interest. Where appropriate based on the level of conflict of interest or the position of the COI Person, conflicts of interest will be disclosed to the Governance and Membership Committee of the Board of Trustees. All potential conflicts of interest with Board members or with the CEO or General Counsel will be referred to the Governance and Membership Committee for resolution.
If you are a COI Person and you have a change in circumstances that may give rise to a conflict of interest or the appearance of a conflict of interest, you must contact the General Counsel as soon as the change of circumstance occurs to discuss the situation. Please email firstname.lastname@example.org
Failure to fully and honestly answer the annual questionnaire, or failure to report a change in circumstances that could give rise to a conflict of interest, may result in disciplinary action, up to and including termination. This policy may be revised from time to time.