Conflict of Interest Policy
Our Commitment to Business Operations
TCF-USA prohibits its employees from engaging in any activities that might constitute an actual or potential conflict of interest with respect to TCF-USA business standards.
Following is a general framework and guideline of acceptable standards of business operation; employees should seek further clarification for any issues not specified in the policy.
An actual or potential conflict of interest occurs when an employee is in a position to make or influence a business decision that may result in personal gain for that employee or for a relative as a result of TCF-USA business dealings. For the purpose of this policy a relative is any person who is related to the employee by blood or marriage or whose relationship with the employee is similar to that of persons who are related by blood or marriage.
Personal gain may result not only when an employee or relative has a significant ownership in a firm with which TCF-USA does business but also when an employee or relative receives any kickback, bribe, substantial gift or special consideration as a result of any transaction or dealings involving TCF-USA.
Business dealings with outside firms should not result in unusual gains for those firms. Unusual gain refers to bribe, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the outside firm or its employee(s) or both.
No presumption of guilt is created by mere existence of a relationship with outside firms. However, if employees have influence on transactions involving purchases, contracts or leases they must disclose the possibility of existence of any actual or potential conflict of interest to any officer of TCF-USA as soon as possible, so that safeguards can be established to protect all parties.