A conflict of interest occurs when your private interests interfere – or appear to interfere – with the best interests of CenterPoint Energy. A conflict of interest may also arise when your personal interests adversely impact your business judgment or job performance. Conflicts of interest can cause serious problems for you and damage our reputation. You should avoid actual conflicts of interest as well as the appearance of a conflict of interest. You should base business decisions on CNP’s needs rather than your own personal interests or the interests of your friends or family.
If you have any doubt about whether a conflict of interest exists, take these steps:
- Explain the situation promptly and fully to your manager, the Legal Department, or the Corporate Compliance Officer.
- Get advice and – when necessary – remove yourself from decision-making about the situation.
Personal Business Relationships
You must obtain prior approval from the head of your division business unit for any significant financial interests you or your immediate family have with our suppliers, partners, subcontractors, or competitors. You should not pursue business on behalf of CenterPoint Energy with any entity in which you or your immediate family has a significant financial interest. Do no let your personal business relationships influence the decisions you make on our behalf.
QUESTION: I am considering taking a second job to make some money. Is this OK?
ANSWER: Yes. But remember, your first responsibility is to our company. You must be able to fulfill all of your responsibilities, including mandatory overtime.
QUESTION: Can we keep a gift of cookies that our department received from a vendor?
ANSWER: Yes. You may keep unsolicited gifts of food provided that they are shared with everyone in your work area. You may also choose to donate gifts of food to a local charity. You should follow up with the vendor with a note of appreciation and a reminder about our policies on gifts.
Organizational Relationships
You must obtain prior approval from the head of your business unit for any membership on a board of directors, committee, or similar body of any outside company or professional organization. When you disclose your organizational relationships, we can determine whether you could unduly influence either the decisions of the outside organization or CNP. We can provide advice on how to resolve the situation fairly.
Political Office
If you seek or hold political office, you must do so on your own time, whether through vacation, unpaid leave, after work hours, or on weekends. You must obtain advance approval from the CEO prior to running for political office to ensure that there are no real or potential conflicts of interest. Also, you cannot use company resources for these purposes.
Business Opportunities
Business opportunities are company assets. We are expected to advance CNP’s legitimate interests whenever we can. Do not take personal advantage of business opportunities you discover while using company resources or enable third parties to do so. You should not compete against our company.
Outside Employment
Before you accept outside employment (including consulting, second jobs, or moonlighting) consider carefully whether this will create a conflict of interest with your CNP work. Outside or second jobs should not harm our company’s reputation.
Nepotism
You should not make employment decisions of any kind about individuals who are related to you by blood or marriage. This includes decisions about job assignments, overtime, compensation, merit increases, and performance reviews. When possible, CenterPoint Energy will reassign employees so that individuals who have close personal or family ties are not in a direct reporting relationship.
QUESTION: A consultant offered me tickets to a major sporting event. Can I accept them, or should I give them to my staff instead?
ANSWER: Our policy does not prohibit you from going to the game or giving the tickets to your staff. But, these are the kinds of situations that require some reasonable judgment. Attendance at the game could leave the impression that you and CNP are obligated to continue using this consultant’s services. You should always discuss these kinds of situations with your manager or the Ethics and Compliance Department.
Gifts and Entertainment
A gift can be anything of value, including goods, services, favors, meals, trips, hospitality, and sports or entertainment tickets. Appropriate gift giving can be a part of conducting business. However, giving and accepting gifts may – or may appear to – compromise your independence and objectivity. This perception can damage your good name and our standing in the community.
We follow these primary rules when it comes to giving or receiving gifts:
- A gift, favor, or entertainment should not be given or accepted if it will obligate or appear to obligate CenterPoint Energy or you.
- No gifts should be exchanged if they could harm our reputation.
Giving Gifts
We compete solely on the merits of our products and services. You should not give any gift if, under the circumstances, this raises questions about its propriety. We may provide gifts, meals, and entertainment of reasonable value in the course of doing business with our customers, provided this practice does not conflict with our standards or the standards of the recipient’s organization.
Gifts may be given if:
- There is a sound business purpose
- The gift supports our corporate strategy
- Your supervisor agrees that the gift is appropriate – before it is given.
- The gift is within your approved budget and is accurately recorded at the company.
Receiving Gifts
Ask if a gift that you are offered looks like an attempt to sway your judgment. You should not accept a gift from someone doing – or wanting to do – business with CNP if they are trying to influence your decision. You may accept promotional items, such as pens, or coffee mugs. It is never acceptable to receive cash, gift certificates or other cash equivalents.
Gifts to Government Officials
Government agencies have strict regulations prohibiting their employees from accepting items of value from contractors or suppliers. We carefully follow their regulations and policies. It is generally not acceptable to offer any kind of gift – including meals – to a government official.
QUESTION: The contract for janitorial services is up for renewal. We want to ask more companies to submit bids. My brother-in-law owns a cleaning company. Can he submit a bid?
ANSWER: We welcome all qualified bidders. If your brother-in-law’s company meets our expectations, he is welcome to submit a bid. However, you should disqualify yourself from reviewing any of the submitted bids and from participating in the selection decision. You must also disclose the relationship to the appropriate company personnel.
