Appendix 2: Conflict of Interest Policy

Policy Statement

VMS is committed to ensuring that its decision-making processes are not influenced by undue personal interests. VMS understands that the presence of a conflict of interest does not itself necessarily result in improper behaviour. In fact, there may be legitimate business reasons for engaging in activities or transactions which result in such conflicts. VMS is committed to ensuring that where there are any conflicts of interest, these are disclosed and recorded, thereby improving transparency and helping to safeguard the integrity of VMS and our employees. Employees are always required to act in the best interests of VMS. Any conflict of interest should be discussed with and approved by the employee’s direct manager.

Definition of conflict of interest

A conflict of interest arises where an employee’s personal or financial interests, or the interests of a Closely Related Person, conflict or potentially conflict with the interests of VMS, or where such interests unduly influence their business judgments, decisions or actions.

A Closely Related Person is:

i. a close family member of an employee, being a spouse or partner, a dependent child, a sibling and the spouse or partner of that sibling, a parent or parent-in-law, and any other relative with whom the employee shares the same household (“Family Member”); or ii. a company or other entity (including a trust or partnership), which is owned, managed, influenced or controlled by an employee or Family Member, including those entities in which the employee or Family Member holds a key position. Common examples of conflicts of interest include:

• purchasing goods or services in the name of VMS from a Closely Related Person;
• hiring or supervising a Closely Related Person;
• becoming a contractor, consultant or supplier to VMS while being employed at VMS; and
• having another job with one of VMS’s customers or competitors.

A conflict of interest may also arise where an employee’s actions or recommendations are influenced by bribes or gifts and hospitality. Please see the restrictions and recommendations set out in the Anti-Bribery Policy (Appendix 4) and Gifts and Hospitality Policy (Appendix 5).