Conflict of Interest

All employees are under obligation to avoid conflicts between their personal interests and the interests of ABC Group or its clients and must not promote / disclose any commercial relations or existing interests that may have potential conflict or commitment.

You must not get involved in any operation, negotiation or agreement representing ABC Group before a client or any entity in which you or a relative of yours have a direct or indirect interest, or which is under conditions to compete with ABC Group, unless you have:

a) made a full statement of facts in writing;

b) obtained written authorization from the head of your Department, as well as from the Executive Board of the Company.

Except the permissions set forth in your employment agreement with ABC Group, you must nor participate or engage in any other commercial enterprise.

You must decline secondary jobs, invitation to provide advisory or to be a Director or partner, except as permitted by your employment agreement or expressly approved in writing by the Vice Presidency and Human Resources.

A conflict of interest may occur between an operating unit and its client or between clients or prospective clients. In this case, there must be greater concern to ensure equal treatment for the involved parties. Guidance may be obtained from your manager or Human Resources.

Guidance or authorization to Heads of Department will be given by the immediate superior or by the Executive Board or by Human Resources.