Conflict of Interest Policy
Guidelines and procedures for identifying, disclosing and managing conflicts of interest to maintain objectivity and ethical decision-making.
OBJECTIVITY
Identify • Disclose • Evaluate • Manage
Policy Purpose
3DMoose is committed to maintaining the highest standards of integrity and objectivity in all business decisions. This policy establishes clear guidelines for identifying, disclosing, and managing conflicts of interest that could compromise our ability to act in the best interests of the company and its stakeholders.
All employees, directors, officers, and representatives must avoid situations where personal interests could conflict with their professional duties or the company's interests.
Types of Conflicts of Interest
Financial Conflicts
Personal financial interests that could influence business decisions or create unfair advantage
Personal Relationships
Family, romantic or close personal relationships that could affect professional judgment
Outside Activities
External employment, board positions, or business interests that compete with company duties
Gifts and Benefits
Receiving or offering valuable gifts, entertainment or benefits that could influence decisions
Disclosure Process
Identify
Recognize potential conflicts of interest in your personal or professional activities
Disclose
Report the conflict immediately to your supervisor or compliance officer
Evaluate
Management assesses the conflict and determines appropriate management strategies
Manage
Implement agreed-upon measures to eliminate or mitigate the conflict
Important: Disclosure must be made immediately upon becoming aware of a potential conflict. Failure to disclose conflicts of interest may result in disciplinary action.
Common Conflict Scenarios
Financial Interests
- • Owning shares in competing companies or suppliers
- • Having financial interests in companies we do business with
- • Receiving loans or financial benefits from business partners
- • Investing in opportunities discovered through company information
Personal Relationships
- • Supervising family members or romantic partners
- • Making hiring decisions involving relatives
- • Negotiating contracts with companies owned by friends or family
- • Participating in decisions that benefit personal relationships
Outside Activities
- • Working for competitors or suppliers during off-hours
- • Serving on boards of competing organizations
- • Operating personal businesses that compete with company services
- • Using company time or resources for personal ventures
Conflict Management Strategies
Recusal
Remove yourself from decisions or discussions where you have a conflict
Divestiture
Sell or dispose of conflicting financial interests or business relationships
Disclosure
Transparent communication of the conflict to all relevant parties
Monitoring
Ongoing oversight to ensure conflicts are properly managed
Annual Disclosure Requirements
Mandatory Annual Certification
All employees must complete an annual conflict of interest disclosure form that includes:
- Financial interests and investments
- Outside employment and board positions
- Family relationships with business partners
- Gifts and benefits received
- Personal business relationships
- Any other potential conflicts
Consequences of Non-Compliance
Disciplinary Actions
Failure to comply with this policy may result in disciplinary action, including:
- • Written warning and mandatory training
- • Suspension from duties pending investigation
- • Termination of employment or business relationship
- • Legal action to recover damages or benefits
- • Reporting to relevant regulatory authorities
Reporting and Support
Get Help and Guidance
If you have questions about potential conflicts of interest or need guidance on disclosure requirements, contact us through these channels:
Confidential Consultation: We encourage open discussion about potential conflicts. Early consultation helps prevent problems and demonstrates good faith compliance.
Last Updated: December 19, 2024
This conflict of interest policy has been approved by the 3DMoose Board of Directors and is binding for all employees and business partners.
3DMoose is a brand of ENSTITÜ OÜ (Registration: 14850305, VAT: EE102444771)
When in Doubt, Ask
If you're unsure whether a situation constitutes a conflict of interest, it's always better to disclose and seek guidance. We're here to help you navigate these situations while maintaining the highest ethical standards.