Podcast
Questions and Answers
Who should a conflict be disclosed to if the employee is not comfortable reporting it to HR?
Who should a conflict be disclosed to if the employee is not comfortable reporting it to HR?
What is the maximum time frame for the CEO to be informed of a disclosure?
What is the maximum time frame for the CEO to be informed of a disclosure?
What action can the CEO take if HR finds a breach of policy after an investigation?
What action can the CEO take if HR finds a breach of policy after an investigation?
If a conflict of interest complaint is made but the details are undisclosed, who is responsible for handling the matter?
If a conflict of interest complaint is made but the details are undisclosed, who is responsible for handling the matter?
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In the event of a suspected violation of law, what action is advised?
In the event of a suspected violation of law, what action is advised?
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What is the primary responsibility of employees regarding conflicts of interest?
What is the primary responsibility of employees regarding conflicts of interest?
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What is the Credit Union's policy regarding retaliation for reporting conflicts of interest?
What is the Credit Union's policy regarding retaliation for reporting conflicts of interest?
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Who is considered an insider according to the policy?
Who is considered an insider according to the policy?
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What should an employee do upon discovering a potential conflict of interest?
What should an employee do upon discovering a potential conflict of interest?
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What consequence does the Credit Union impose on individuals making false allegations?
What consequence does the Credit Union impose on individuals making false allegations?
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What format is required for the annual conflicts declaration by employees?
What format is required for the annual conflicts declaration by employees?
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How is information disclosed about conflicts of interest treated?
How is information disclosed about conflicts of interest treated?
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What must be done immediately upon becoming aware of a potential conflict of interest?
What must be done immediately upon becoming aware of a potential conflict of interest?
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Study Notes
Duty to Disclose
- Employees are required to disclose potential conflicts of interest immediately upon awareness.
- Conflicts may arise from personal gain or relationships influencing Credit Union decisions.
- Protection against retaliation is ensured for employees reporting in good faith about potential violations.
Insiders
- Insiders are individuals who exploit non-public information, resulting in unfair advantages.
- Obvious insiders include management and employees, along with auditors, attorneys, appraisers, brokers, consultants, and vendors.
Declaration Requirement
- Annual conflicts declaration is mandatory for all employees, recording perceived or actual conflicts as outlined in Appendix 1 of the policy.
- A conflict-of-interest register is maintained by Human Resources (HR) to track disclosures.
Conflict of Interest Procedures
- Employees must complete a Conflict-of-Interest Disclosure Form to report conflicts, detailing nature and extent of the concern.
- If conflicts involve HR or the CEO, disclosure should be directed to the Chairman of the Board.
- All disclosures must be communicated to the CEO within five working days.
Investigative Process
- The CEO consults relevant parties after receiving disclosures and assigns undisclosed complaints to HR.
- HR investigates any identified breaches of policy and recommends actions to the CEO.
- Disciplinary measures may include termination or other actions based on HR’s findings.
Legal Violations
- Any suspected legal violations may be referred to external legal counsel for further action.
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Description
Test your knowledge on the Duty to Disclose policy and the importance of reporting potential conflicts of interest. Learn how to recognize situations that may influence Credit Union decisions and the protections in place for employees who report concerns. This quiz is essential for ensuring a transparent and ethical workplace.