DuPont Code of Conduct

OUR COMPANY

Conflicts of Interest

At DuPont, we must ensure that our personal interests and activities do not interfere with our responsibilities to the company. This includes avoiding even the appearance of a conflict of interest. If a potential conflict arises, it is our responsibility to disclose it so management can review and address the situation.

Recognizing Conflicts

Conflicts of interest may include:

Family Members and Relationships

Managers must not oversee family members or have romantic relationships with persons they supervise. Report such situations immediately so management or HR can address them.

Family members include close relatives like parents, children, siblings, in-laws, and others living in the same household. Other relationships may also create conflicts. Managers should assess these situations on a case-by-case basis.

External Employment, Work, or Activities

To avoid conflicts with outside activities, you must not:

Take roles such as director, officer, partner, consultant, or other key positions with organizations that do business with or compete against DuPont.

Act as an intermediary in transactions involving DuPont.

Take outside jobs or start businesses that interfere with DuPont responsibilities.

Serve in government roles that conflict with company duties.

Use DuPont property, information, or time for personal gain.

Use your DuPont title or position in ways that imply company support for outside activities.

Use DuPont supplies or facilities for outside activities without manager approval.

Before engaging in activities such as publishing, speaking, or consulting, check with your manager to ensure they don’t conflict with your role at DuPont.

Examples of Corporate Opportunities

Using a Discovery for Personal Gain

You identify a compound from a research project that could have market value outside of DuPont and, without authorization, share this information with an external party to pursue the opportunity independently.

You learn that DuPont may want to purchase local property, so you buy it first to sell back at a profit.

Your team creates a process that reduces pollutants, and you try to sell it to other companies independently.

Taking personal advantage of these opportunities violates our policies and values.

Disclosing and Addressing Conflicts

Disclose any potential conflicts promptly to your manager, a Corporate Compliance Officer, or Legal. These disclosures should also be included in the annual Business Ethics Certification. Management will review and resolve conflicts confidentially, consulting Ethics & Compliance Central as needed.

Significant Financial Interests
A “significant financial interest” is defined as any one of the following:

  • More than 1% ownership in a public company.
  • More than 10% ownership in a private company.
  • More than 5% of your total assets or income.

Consult your manager or Legal if you are unsure about financial interests that could create conflicts.

Q&A

I’ve been asked to speak at an event related to my job skills. Can I accept?

Maybe. First, check with your manager. If the event is connected to your work or industry, you need approval to make sure it doesn’t create a conflict or appear to represent DuPont without permission.

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