Conflict of Interest Policy

Jumpcode Genomics - Conflict of Interest Policy

Last updated: April 11, 2022

Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Jumpcode Genomics, Inc wishes the business to operate. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation.

 

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative as a result of Jumpcode Genomics, Inc’s business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage or whose relationship with the employee is similar to that of persons who are related by blood or marriage.

 

No “presumption of guilt” is created by the mere existence of a relationship with outside entities. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to the Chief Financial Officer (CFO) of Jumpcode Genomics, Inc as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.

 

Personal gain may result not only in cases where an employee or relative has ownership in an entity with which Jumpcode Genomics, Inc does business, but also when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Jumpcode Genomics, Inc.  A “substantial gift” is defined as any gift or remuneration over a 12-month period valued at $5,000 or more (outside of normal employment compensation).

 

The CFO will be responsible for investigating any disclosed or claims of a conflict of interest. Failure to disclose a conflict of interest may result in disciplinary action, up to and including termination.

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