Conflicts of Interest

CDL expects all employees to conduct themselves and company business in a manner that reflects the highest standards of ethical conduct, and in accordance with all federal, state, and local laws and regulations. This includes avoiding real and potential conflicts of interest.

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Exactly what constitutes a conflict of interest or unethical business practice is both a moral and a legal question. CDL recognizes and respects the individual employee’s right to engage in activities outside of employment which are private in nature and do not in any way conflict with

or reflect poorly on the company.

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It is not possible to define all the circumstances and relationships that might create a conflict of interest. If a situation arises where there is a potential conflict of interest, the employee should discuss this with a manager for advice and guidance on how to proceed. The list below suggests some of the types of activity that indicate improper behavior, unacceptable personal integrity, or unacceptable ethics:

1. Simultaneous employment by another firm that is a competitor of or   

     supplier to CDL.

2. Carrying on company business with a firm in which the employee, or a

     close relative of the employee, has substantial ownership or interest.

3. Holding a substantial interest in, or participating in the management of, a

    firm to which the company makes sales or from which it makes purchases. 

4. Borrowing money from customers or firms, other than recognized loan

    institutions, from which our company buys services, materials, equipment,

    or supplies.

5. Accept gifts valued over $25 or excessive entertainment from an outside

    organization or agency.

6. Speculating or dealing in materials, equipment, supplies, services, or

    property purchased by the company.

7. Participating in civic or professional organization activities in a manner that

    divulges confidential company information.

8. Misusing privileged information or revealing confidential data to

    outsiders.

9. Using one’s position in the company or knowledge of its affairs for

    personal gains.

10. Engaging in practices or procedures that violate antitrust laws,

      commercial bribery laws, copyright laws, discrimination laws, campaign

      contribution laws, or other laws regulating the conduct of company

      business.

11. Wearing CDL labeled apparel and participating in political, religious or

      other activities that CDL customers may find offensive.

Confidential Information

The protection of confidential business information and trade secrets is vital to the interests and success of CDL. Confidential information is any and all information disclosed to or known by you because of employment with the company that is not generally known to people outside the company about its business.

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An employee who improperly uses or discloses trade secrets or confidential business information will be subject to disciplinary action up to and including termination of employment and legal action, even if he or she does not actually benefit from the disclosed information.

• All ideas, discoveries, business practices that may be revealed during

   employment will remain confidential.

• All personnel information will be kept confidential and properly

   administered within the HR department.

• Any policies, procedures and other sensitive information will not be

   disclosed outside of CDL Electric Company and affiliates.

• Any information that may potentially be damaging to customer and their

   competitors will not be disclosed.

• Any information received under an express or implied secrecy obligation

   will remain confidential.

• Any information received from third parties outside CDL Electric Company,

   Inc. will not be disclosed.

• All inquiries from the media must be referred to the CDL Marketing team.