Policy

The Proprietary Interest Disclosure Policy outlines the guidelines and procedures for employees and individuals associated with Skidmore Training to disclose any proprietary interests they hold that may present a potential conflict of interest. This policy is designed to promote transparency and maintain the integrity of our business operations. 

Definitions 

  • 1) Proprietary Interest: Any financial interest, ownership interest, intellectual property interest, or other interests in any entity, venture, or property that may be affected by or could influence the actions, decisions, or judgments of an individual associated with Skidmore Training.
  • 2) Conflict of Interest: A situation in which an individual's proprietary interest may compromise their ability to make impartial decisions in the best interests of Skidmore Training.


Disclosure Obligation 

All employees, contractors, consultants, and individuals associated with Skidmore Training have an obligation to disclose any proprietary interest that could give rise to a conflict of interest. Disclosure is mandatory, and failure to do so may result in disciplinary actions. 


Types of Proprietary Interests 

The following are examples of proprietary interests that should be disclosed, but are not limited to: 

  1. OwnershipInterests:Ownershiporfinancialinterestincompanies,partnerships, or sole proprietorships that do business or may potentially do business with Skidmore Training. 
  2. IntellectualProperty:Patents,copyrights,trademarks,orotherintellectual property rights that are related to Skidmore Training's business. 
  3. EmploymentorConsulting:Employment,consulting,oradvisoryroleswith entities that compete with or provide products/services similar to those of Skidmore Training. 
  4. Investments:Significantinvestmentsinsecuritiesorassetsofentitiesthathave business relationships with Skidmore Training.


Disclosure Process 

  1. Initial Disclosure: Upon joining Skidmore Training, or whenever a proprietary interest is acquired or changes, individuals are required to complete the initial proprietary interest disclosure form provided by the company. 
  2. Annual Disclosure: All individuals associated with Skidmore Training must complete an annual proprietary interest disclosure, even if no changes have occurred since the last disclosure. 
  3. Additional Disclosures: Individuals must promptly disclose any new proprietary interests acquired during the year that could pose a potential conflict of interest. 
  4. Confidentiality:The disclosed proprietary interest information will be treated as confidential and shared only with individuals who need to be aware of it to assess potential conflicts.

Evaluation and Mitigation 

Skidmore Training management will evaluate the disclosed proprietary interests to determine whether a conflict of interest exists. If a conflict is identified, measures to mitigate the conflict will be put in place. These measures may include recusal from certain decision-making processes, divestment of the proprietary interest, or other actions as deemed necessary. 


Reporting Violations 

If an individual becomes aware of a breach of this policy, they are required to report it to the appropriate personnel or through established reporting channels for further investigation. 

Consequences of Non-Disclosure 


Failure to comply with this policy and non-disclosure of proprietary interests may result in disciplinary actions, up to and including termination or legal action, as applicable. 


Policy Acknowledgment 

All individuals associated with Skidmore Training will be required to acknowledge their understanding and acceptance of this Proprietary Interest Disclosure Policy upon joining the company and on an annual basis thereafter. 


Review and Updates 

This policy will be periodically reviewed and updated to ensure its relevance and effectiveness. Skidmore Training reserves the right to modify this policy as needed. 

Skidmore Training encourages transparency and integrity in all its business dealings and expects all individuals associated with the company to comply with this policy to maintain its ethical standards and reputation.