THE ASSOCIATED PRESS CONFLICT OF INTEREST POLICY
Last Updated: March 21, 2008
This conflict of interest policy (this “policy”) is part of The Associated Press Code of Business Conduct
and Ethics (the “code”).
As a person employed or engaged by The Associated Press (with its subsidiaries, the “company”), you
are expected to work in the best interests of the company at all times, as a disinterested and reasonable
observer would view that interest in the circumstances.
If you have questions about this policy or any matter pertaining to this policy, please contact your
supervisor or any of the conflict of interest policy coordinators identified at the end of this policy (the “policy
coordinators”).
I.
CONFLICTS OF INTEREST
A conflict of interest exists when you take any action that is contrary to or interferes with the interests of
the company or have any relationship that creates an interest contrary to the company’s interests. Accordingly,
you must avoid or disclose as specified herein all conflicts between the best interest of the company and your
own personal interests or personal relationships.
A conflict of interest also exists when you exercise your authority over any matter concerning the
company that also involves or affects any of your personal or business relationships, dealings or investments.
Accordingly, you may not use your position at the company to obtain any improper benefit for yourself or convey
any benefit to any person with whom you have personal or business relationships or dealings.
II. OBLIGATION TO DISCLOSE CONFLICTS OF INTEREST
This policy requires disclosure and review of potential conflicts of interest and prohibits actual conflicts
of interest. The existence of a potential conflict of interest does not necessarily constitute a violation of the
policy, as long as it is disclosed in accordance with this policy.
You must disclose all actual and potential conflicts of interest promptly. Your disclosure must be in
writing – electronic mail is acceptable – to your supervisor or any of the policy coordinators.
It is your
responsibility to comply with this requirement each time you become aware of a new conflict of interest or if any
initial disclosure no longer accurately reflects the nature of the conflict of interest.
In some cases, disclosure may be all that is required. If the company determines that an actual conflict
of interest exists, it will determine what additional actions are required by you or by the company to remedy that
conflict and instruct you accordingly. If the company determines that a particular situation does not constitute an
actual conflict, this policy will remain applicable to that situation and the company determination may change if
the circumstances of the situation change.
III. EXAMPLES OF CONFLICTS OF INTEREST
It is impossible to describe every potential conflict of interest. However, to assist you in understanding
and complying with this policy, an illustrative list of actual conflicts of interest follows.
•
You may not accept on account of your work for the company any gift, third-party promotional
item or entertainment, travel or favors that go beyond normal and proper business courtesies,
create an appearance of impropriety, impose a sense of obligation or result in favored
treatment for the giver or any other third party.
•
You may not lend personal funds to or borrow personal funds from any employee, supplier to
the company (other than a financial institution in the ordinary course of its business), customer
of the company or any person who controls a supplier or customer. This does not include
occasional lending or borrowing of nominal amounts to or from a colleague (for example, to
provide cash for lunch, commuting, etc.)
•
You may not personally sell or lease anything to or from the company or otherwise personally
do business with the company.
•
You may not engage in any commercial transaction on behalf of the company with any family
member, household member or personal acquaintance as an employee, freelancer, stringer,
contractor, customer, or supplier of the company. In business transactions involving the
company where a family member, household member or personal acquaintance is also
involved as a commercially interested party, you must disqualify yourself from any decision
making or other direct or indirect participation in the transaction.
•
If your work for the company will benefit or does benefit a third party or person, you may not
(1) have any personal financial interest in that party or receive any financial benefit from that
party or person or (2) serve as a consultant, director, officer or employee of that third party.
The exception is stock ownership in a publicly traded company, provided such ownership is
5% or less of the public company’s stock.
•
You may not disclose any confidential information of the company or confidential information of
a member, partner, customer or supplier of the company to anyone outside the company,
except as authorized for the company’s business purposes, or use such information for
personal profit or gain.
The company expects you to seek guidance from your supervisor or the policy coordinators when
necessary, but expects you to comply with this policy at all times.
Subject to applicable law, no member of your household or immediate family may do any thing, own any
interest or serve in any position if you cannot undertake such activity under this policy. For example, you would
need to disclose the fact that a member of your household or immediate family, such as your child, owned 10%
of the stock of a supplier if you have authority over the selection of the supplier or over the amount of business
conducted with that supplier. Similarly, you would need to disclose the fact that a member of your household or
immediate family was doing business with the company as a stringer, customer, or supplier.
The company expects you to avoid any conduct or activity – whether or not listed above – that is likely
to affect your business judgment on behalf of the company. Such conduct or activity would constitute an actual
conflict of interest that you must avoid.
IV. SUPERVISOR/SUBORDINATE RELATIONSHIPS
The company recognizes that a close personal relationship may develop between a supervisor and a
subordinate, or that a personal relationship between peers may become a supervisor/subordinate relationship as
a result of the promotion of one party to the relationship.
Such relationships can lead to complications and significant difficulties for the supervisor, the
subordinate, others in the workplace and the company.
You must disclose your participation in any close personal relationship involving a supervisor and his or
her subordinate to the HR representative designated as a policy coordinator. This disclosure is to ensure there
are no issues of actual or apparent favoritism, conflict of interest, sexual harassment or any other negative
impact on others in the work environment.
If the company is informed or learns of such a relationship, it may take steps it deems appropriate to
protect the work environment.
V. CORPORATE OPPORTUNITIES
You may not take for your personal benefit any opportunity that you discover or develop through use of
any company property (which includes information that is proprietary to the company, such as corporate strategy,
business plans, product information and customer lists).
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VI. CONFLICT OF POLICY COORDINATORS
The following company officers are solely authorized to hear, review and take action on any matter that
arises under this policy:
•
Head of Internal Audit;
•
General Counsel;
•
Head of Human Resources; and
•
Chief Financial Officer.
The company's chief executive officer, under the oversight of the company board of directors, will be the
final arbiter on all matters arising under this policy.
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