MWF Employee Handbook

2.7 Conflict of Interest & Outside Employment General

Background and reference checks may include verification of any information on the applicant’s resume or application form. All background checks are conducted in conformity with the Federal Fair Credit Reporting Act, the Americans with Disabilities Act, and state and federal privacy and antidiscrimination laws. Reports are kept confidential and are only viewed by individuals involved in the hiring process. Additional checks such as a driving record or credit report may be made on applicants for particular job categories if appropriate and job related.

Midwest Fastener Corp. expects its employees to conduct business according to the highest ethical standards of conduct. Employees are expected to devote their best efforts to the interests of the Company. Business dealings appearing to create a conflict between the interests of the Company and an employee are unacceptable. The Company recognizes the right of employees to engage in activities outside of their employment that are of a private nature and unrelated to the business. However, the employee must disclose any possible conflicts so that the Company may assess and prevent potential conflicts of interest from arising. A potential or actual conflict of interest occurs whenever an employee can influence a decision that may result in personal gain for the employee or an immediate family member (i.e., spouse or significant other, children, parents, siblings) as a result of the Company’s business dealings. Employees must refrain from any activity or have a financial interest inconsistent with the Company’s best interest and from activities, investments, or associations that compete with the Company or interfere with one’s judgment concerning the Company’s best interest. Although it is not possible to specify every action that might create a conflict of interest, this policy sets forth the ones that most frequently present problems. If an employee has any question whether an action or proposed course of conduct would create a conflict of interest, they should immediately contact the Human Resources Department to obtain advice on the issue before engaging in any such activity. The purpose of this policy is to protect employees from any conflict of interest that may arise. Nothing in this policy is intended to or shall be construed to prohibit employees from engaging in lawful, concerted protected activity within the meaning of the National Labor Relations Act. A violation of this policy will result in

2.6 Fraud, Dishonesty & Misrepresentation

No employee or candidate may ever falsify any application, medical history record, paperwork, investigative questionnaires, or any other document. Any employee found to have engaged in resume fraud or who made material representations or omissions on any Company documents will be subject to disciplinary action, including immediate termination of employment. If you observe any such violations, please report them to your supervisor or the Human Resources Department.

immediate and appropriate discipline up to and including immediate termination.

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800-444-7313 •

800-388-9798 •

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