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The Right Way I Every Day Question Martins brother owns a company that has supplied materials to our Company for many years. Martin was recently promoted and in his new position will have authority to contract with his brothers company. What must Martin do Answer Martin should disclose the conflict via the Conflict of Interest disclosure form to his supervisor with a copy to the Compliance department so that it can be resolved. Even though his brothers company is a longtime supplier of our Company an appearance of a conflict has now been created because Martin has the authority to contract with his brothers company. In this case Martin should be recused from making any decisions about using his brothers company and an independent decision maker such as Martins supervisor should be designated to make such decisions instead of Martin. The important thing for Martin is to recognize a potential or actual conflict of interest and make the required disclosure. 9 We Avoid Conflicts of Interest LyondellBasell is committed to maintaining our stakeholders trust through ethical and reliable performance. This begins with our commitment to integrity. We should be alert to anything that could create a conflict of interest or even an appearance of a conflict of interest. A conflict of interest arises when our personal interests are not aligned with those of our Company. We should always be free from any interests influence or relationship that might conflict with the best interests of LyondellBasell. We should also avoid conduct which may appear to raise a conflict of interest. Below are some common examples of situations in which conflicts of interest may occur. Financial Interests Some of us may have financial investments and interests in companies other than LyondellBasell. If we have a significant financial interest in a business or entity that transacts or seeks to transact any business or compete with LyondellBasell then the details of the significant financial interest should be disclosed to the Compliance department. A Significant Financial Interest is defined as a direct or indirect aggregate interest of more than 10 percent i of any class of the outstanding securities of a firm or a corporation ii interest in a partnership or association or iii of the total assets or gross income of such employee. Outside Employment Part of what makes LyondellBasell so successful is our commitment to the work we perform. In order to uphold this commitment we are strongly discouraged from accepting outside employment or outside business opportunities in entities doing business with or competing with LyondellBasell. Such opportunities are considered conflicts of interest and must be disclosed. Doing Business with Family and Friends A conflict of interest may exist if a family member works for a customer competitor or vendor of our Company and you are in a position to affect Company business with that customer competitor or vendor. Doing business on behalf of the Company with family members in such circumstances will likely lead to a conflict of interest situation and must be disclosed. Family member means an employees immediate family members such as his or her spouse children mother father sisters brothers and steps or in-laws of these types as well as domestic partners. In addition at no time may you directly supervise a family member. If you think you may already have a reporting relationship with a member of your family you should disclose it.