This excerpt taken from the ABII 10-K filed Mar 31, 2008.
CONFLICTS OF INTEREST
A conflict of interest arises any time an individuals personal, social, financial or political interests or activities influence his or her ability to act in the best interests of the Company. Even the appearance of a conflict of interest may damage the Companys reputation. All individuals must discharge their responsibilities solely on the basis of what is in the best interest of the Company and independent of personal consideration or relationships. Officers, directors and
employees must disclose any potential conflicts of interest to the Chief Compliance Officer, who will advise as to whether or not the Company believes a conflict of interest exists. In addition, all transactions between the Company, on the one hand, and its directors or executive officers (or their immediate family members), on the other hand, are subject to approval or ratification in accordance with the Companys Related Person Transaction Policy and Procedures.
The following are several examples of potential conflicts of interest:
Personal Investments or Transactions
The Company respects an individuals right to manage his or her investments and does not wish to interfere with his or her personal life. At the same time, an individual is responsible for avoiding situations that present (or create the appearance of) a potential conflict between his or her interests and those of the Company. To be too specific involves the risk of restricting the application of this policy. However, there are obvious situations that can result in a conflict of interest, such as an individual or his or her family member:
To avoid conflicts of interest, the Company discourages hiring close relatives in the same business unit. The actions of family members and close personal friends outside the workplace can also create a conflict of interest if an individual loses objectivity when making business decisions because of those actions.
A conflict of interest may exist if an individuals outside business or other interests can affect his or her motivation or performance as a Company employee. A second job or affiliation with a Company competitor is not allowed. A second job or affiliation with a customer, supplier or provider of goods or services is discouraged, but may be allowed with proper management approval. Even when outside employment is allowed, employees are still bound by all confidentiality agreements with the Company.
Acceptance of Gifts, Entertainment, Loans or Other Favors
Conflicts of interest are not always obvious, and many may arise despite an individuals best intentions. While business courtesies are encouraged, the Company prohibits an individual (or someone from his or her immediate family) from receiving gifts, services, perks, entertainment or other items of more than token or nominal monetary value from the Companys suppliers or customers (nominal value shall not exceed $25). Moreover, such gifts are permitted only if they are not made or received on a regular or frequent basis.
In some countries outside of the United States, the non-acceptance of a gift may damage the business relationship with the vendor. In that case, the individual should consult with his or her manager or the Companys Legal Department.