Policy
Conflicts of Interest
Identification, disclosure, and management of actual and potential conflicts of interest at ChocoJava.
Framework
Key principles
DisclosureEmployees, officers, and directors are required to disclose any interest that may conflict with ChocoJava’s interests.
Related-Party TransactionsRelated-party transactions require prior approval by an independent committee where applicable.
Gifts & EntertainmentGifts and entertainment above modest thresholds must be pre-approved and logged.
Outside ActivitiesOutside business activities are subject to prior review and approval.
MonitoringCompliance monitors conflicts through periodic certifications and reviews.
Contact
Questions about this policy
Direct questions to [email protected].