CONFLICTS OF INTEREST Avoid any actions that are at odds, or could appear to be at odds, with the interests of Nike Nike respects the rights of its employees to partake in activities – financial, business or otherwise – outside of work, as long as that activity does not interfere with Nike’s interests or the parameters of your employment. But conflicts with Nike must be avoided. If you use your position at Nike for personal gain, that’s a conflict. And if your personal activity could compromise – or even appear to compromise – your ability to make the best business decisions for Nike, that’s a conflict. Learning to recognize potential conflicts of interest can help you avoid one. A conflict can happen when you supervise or conduct business with someone with whom you have a close personal relationship. And it can also happen when you own, invest in or do work for a company that competes, does business or wants to do business with Nike. A conflict can even happen if you simply accept, give or offer gifts, hospitality or favors from or to parties doing business with Nike. Potential conflicts can often be resolved with an open and honest discussion. Remember: having a conflict of interest is not necessarily a violation of our Code, but failing to disclose it is. I’m a store athlete, and my Head Coach goes out to lunch every day with another store athlete. They also golf together almost every weekend. I think this is unfair, but does it violate the Code of Conduct? It depends. Of course it is fine to go to lunch with Nike teammates. Having said that, given the reporting relationship, the frequency of the lunches and weekend golfing, it could be a conflict or perceived as favoritism. All managers must avoid even the appear- ance of conflict or special treatment. If you have any concerns, please contact Human Resources or use the Speak Up Portal . WHAT IF...? I just learned that my manager has a romantic relationship with someone in their line of reporting. Is that OK? No, it is not OK and Nike discourages such relationships. While Nike respects the privacy and personal life of its employees, we should avoid any misunderstandings, complaints or perceptions of favoritism – anything that might disrupt the workplace – that can result from romantic relationships between a manager and an employee that the manager supervises. Managers who are entering into a relationship with an employee in their line of reporting must disclose the relationship to Human Resources , who will then recommend steps to help resolve the matter appropriately. Always keep in mind that regardless of reporting structure, romantic relationships between employees should not cause disruption or have a negative effect on the work environment or create a conflict of interest for either employee involved. LEARN MORE Policy on Conflicts of Interest Policy on Gifts, Hospitality and Other Payments 13
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