INTRODUCT ION TO
CONFLICTS OF INTEREST

Conflicts
of Interest

Acting with integrity as an employee means putting our company’s interests first. Any interest, relationship or activity that’s incompatible with the best interests of GATX is considered a “conflict of interest.”


Conflicts of interest arise when you take actions or have interests that may make it difficult for you to perform your job objectively and effectively. They also arise when you (or a member of your family) receive improper personal benefits as a result of your position in the company.

WHAT IS AN EXAMPLE OF
A CONFLICT OF INTEREST?

An example of conflict of interest:


If your brother is a Vice President of Marketing for a firm that is bidding on vessel maintenance contract for ACD, this may be a conflict of interest depending on your position with the company.

HOW ARE CONFLICTS OF
INTEREST RESOLVED?

How are conflicts of interest resolved?


Many conflicts can be quickly resolved. You should disclose any potential conflict of interest to your manager, who will work with the Law Department and others in the company to resolve the issue. You should also disclose any potential conflict once you're asked to certify your understand of, and adherence to, the Code.

Click on the traffic light
to explore potential
conflicts of interest.

what's approved?

Gifts and Entertainment
When you select and deal with current and prospective suppliers, customers and others, you must do so impartially and with the best interests of the company in mind. You may accept only modest gifts and reasonable entertainment from business associates of GATX. Doing so must also not affect your business judgment or conduct. Employees can accept only gifts and entertainment of modest value.

what's not
approved?

Corporate Opportunities
It is against policy for you to:

  • Take advantage of business opportunities that are discovered or made available through your position with GATX or through information you’ve gained through your position
  • Use company property, information or position for personal gain
  • Compete with GATX

what's if i'm unsure?

Conflicts of interest aren’t always clear-cut. Here are some examples of situations that you’ll want to talk with your manager about. If you:

  • Serve as a director, officer, employee, partner or consultant of a present or potential supplier, customer, competitor or other GATX business partner (unless you made full disclosure and, where necessary, obtained appropriate prior approval)
  • Own stock or other interests in a business listed above unless it is a publicly held and actively traded company
  • Have any other significant direct or indirect personal interest in a transaction involving GATX
  • Accept any form of compensation or payment from a third party