Managing Conflicts of Interest

CODE PRINCIPLES

We respect the privacy of our employees, and their right to pursue outside activities and interests. A conflict of interest can arise, however, when employees have a personal interest in a transaction or situation that could affect their business judgment, loyalty to Albemarle or work performance. When potential conflicts of interest arise, we take appropriate steps to manage the risks arising from them.
  • We make business decisions in the best interests of Albemarle, without bias or favoritism.
  • We avoid situations where personal activities, interests or relationships could affect, or be perceived to affect, our decision-making or work performance.
  • We do not engage in outside interests that compete with Albemarle.
  • We proactively disclose any potential conflict of interest, even if we think it will have no influence on our judgment or performance.

Our Code Principles in Action

  • Contact Global Ethics & Compliance if you have a question about a conflict involving you or a member of your team.
  • Discuss any actual or potential conflict of interest with your supervisor.
  • Register the conflict of interest, and include any action agreed with your supervisor to mitigate the conflict. You can register a conflict of interest by using the Conflicts Disclosure Tool.
  • Complete the annual conflicts of interest disclosure if you receive a request to do so.

Do You Have a Conflict of Interest?

You may have a conflict of interest if you answer yes to any of the following questions.

Business Dealings with Albemarle
  • Do you, your spouse, your partner or any relative own a significant interest in any entity that conducts business with Albemarle?
  • Are you, your spouse, your partner or any relative a director, officer, partner, employee, contractor, or agent of any entity that conducts business with Albemarle?
  • Do you, your spouse, your partner or any relative personally conduct any business with Albemarle?
Affiliation with a Competitor
  • Are you, your spouse, your partner or any relative a director, officer, partner, employee, contractor, or agent of any entity that competes with Albemarle?
  • Do you own a significant interest in any entity that competes with Albemarle?
Affiliation with a Government Official
Duty of Loyalty
  • Are you personally pursuing a business opportunity in which Albemarle might reasonably be interested?
  • Are you personally applying for intellectual property that is in any way associated with Albemarle’s business activity?
Restrictions or Limitations on Your Work Performance
  • Do you have alternate work or other outside activity obligations that potentially affect your ability to perform your job here at Albemarle?
  • Are you currently bound by a confidentiality agreement, non-competition agreement, or any other agreement that could prohibit or limit your work performance?
Other Conflicts That May Affect Your Judgment At Work
  • Are you intending to accept anything of value from a third-party above $150 in value that have not been disclosed or approved in accordance with this Code (Offering or Accepting Gifts & Hospitality)?
  • Are you intending to make a donation to a charity on behalf of Albemarle which you, your spouse, your partner or relative is personally involved in the management of the charity?
  • Are you having a personal relationship with any employee or job applicant in relation to whom you could influence their hiring, performance appraisal, salary, rating or promotion?
  • Are you engaging in any other activity that could be perceived to be a conflict of interest?

DEFINED TERMS

Government Official

Defined broadly, and can include:

  • an officer, employee or anyone acting on behalf of any government body including a department or agency at any level (national, regional, or local). Examples include a government minister, regulator, judge, city mayor, police officer, soldier, customs official or chemistry professor at a public university;
  • an employee of public international organizations such as the United Nations and World Bank;
  • an employee of state-owned or controlled enterprises, such as refineries;
  • a political party, party official or candidate for political office; and
  • a person holding an appointment, position or office created by custom or convention, such as, an indigenous community leader or member of a royal family.
Relative

An individual’s spouse or spousal equivalent; the individual’s and the spouse’s grandparents, parents, siblings, children, nieces, nephews, aunts, uncles, and the spouse or spousal equivalent of any of these people; or anyone who shares the same household.

Significant Interest

Generally, if you own less than 5% of an entity that conducts business with Albemarle, your interest will not be considered significant.  However, even if less than 5%, if your interest is sufficient such that it might appear, or in fact will, affect your business judgment and loyalty to Albemarle in your work performance then you should still consider the interest significant.  For example, if the interest represents a large percent of your personal net worth, though less than 5% of the entity, it should be considered significant.

Menu