Employees should never develop a personal relationship with vendors, contractors, and/or competitors that might impair their judgment when conducting business on behalf of the company. Don’t let the influence of others weaken your decision-making skills.
ONE Gas must avoid organizational conflicts of interest when working with government entities.
Additional conflict of interest requirements apply when ONE Gas does business with government entities. In these instances, ONE Gas may be prevented or limited from doing business with the government on particular projects or contracts based upon the company’s existing contractual or other business relationships. These situations are known as organizational conflicts of interest or COIs.
ONE Gas and its employees must identify and try to avoid situations in which the company’s existing relationships might (i) give ONE Gas an unfair advantage (actual or apparent) in being awarded business opportunities with the government; or (ii) make ONE Gas unable (either actually or apparently) to perform its role objectively or in a manner that serves the best interest of the government. Additionally, any subcontractors with potential or actual organizational conflicts of interest must be identified.
As with traditional conflicts of interests, it is difficult to define or provide examples of each situation in which an COI might arise. Employees should, however, be especially aware of the potential for a COI in situations in which ONE Gas is retained by a government entity to develop a scope of work for a particular project and then seeks (either itself or through an affiliate) to perform the work. Projects of this type could lead to a situation in which ONE Gas or its affiliates would be viewed as having unfair competitive advantage. It is particularly important that employees be aware of COI situations, in part, because loss of a project or business opportunity can sometimes be avoided or limited by full advanced disclosure of ONE Gas’ relevant existing contractual or other business relationship(s).
Additionally, it is important to remember that actual or apparent conflicts of interest that violate government contracts or regulations are the most problematic and involve the most serious potential consequences for ONE Gas and involved employees, up to and including civil and criminal fines and employment termination.
To review the policy and specific employee reporting procedures, employees should refer to the ONE Gas Statement of Policy Regarding Conflict of Interest posted on the ONE Gas Hub. When in doubt contact the Compliance and Ethics Department or complete a Request for Determination – Conflict of Interest form.