A conflict of interest occurs when outside activities influence, or appear to influence, the ability to make objective decisions in the course of performing your job. A conflict of interest also exists if the demands of any outside activity considerably or significantly hinders or distracts you from the performance of your job or causes you to use Blue Shield resources for other than Blue Shield purposes. Employees need to be responsive to both actual conflicts and the appearance of conflicts. Not all conflicts are prohibited but all must be disclosed and assessed. It is your obligation to ensure that you remain free of conflicts of interest in the performance of your responsibilities at Blue Shield or obtain approval for any minimal conflict from your supervisor or manager. If you come across a situation where a possible conflict of interest may be involved, disclose it promptly to your supervisor or one of your Compliance Resources, so that the situation may be assessed and a determination made as to whether action is required. The following are examples of the types of activities that can cause a conflict of interest:


. Placing business with any firm in which an employee or employee's immediate family members may have a direct or indirect Substantial Interest.

. Involvement in personal, family or other enterprises that conduct business with, or compete with, Blue Shield. "Involvement" includes serving as a paid employee, consultant or board member, or having a Substantial Interest in the enterprise.

. Hiring or supervising an immediate family member;

. Choosing one vendor over another based on personal preferences and not objective criteria.

. Exerting or appearing to exert influence on behalf of those with whom Blue Shield does business or may do business because of friendship or any other non-objective basis.

. Using Blue Shield's Confidential or Proprietary Information for the personal profit or advantage of an employee or someone else.

. Conducting outside activities that adversely affect your working time or duties, are unlawful, that present Blue Shield in a way that harms its reputation or otherwise undermines your duty of loyalty as an employee.

. Conducting Blue Shield's Business

. Dealing with Customers, Suppliers and Vendors

The offer, receipt or solicitation of something of value to or from a current or potential customer, supplier or vendor, may give rise to illegal conflicts of interest. What do we mean by "something of value?" We mean all kinds of tangible and intangible benefits and favors, including cash, gifts, prizes, tickets, supplies, food, entertainment, transportation, lodging, personal services and special opportunities (like discounts or passes).

When is the offer, receipt or solicitation of these things acceptable and when is it unacceptable? It is always unacceptable to offer, receive or solicit something of value if doing so would infringe applicable laws or regulations. For example, the law strictly prohibits giving gifts or entertainment to government employees. It is always undesirable to offer, receive or solicit cash or cash equivalents (like gift certificates). When cash or cash equivalents are not involved, and no applicable law or regulation would be violated, you must apply the guidelines below.