We are expected to place Winnebago Industries’ interest ahead of our own when conducting business on behalf of any member of the Winnebago Industries family of companies. This means we must avoid any actual or perceived conflict of interest, unless it has been properly disclosed and approved.
A conflict of interest occurs when your individual relationships or activities (or those of your family members) interfere with, or appear to interfere with, your ability to act in the best interest of Winnebago Industries.
Conflicts of interest can also arise when you receive a personal benefit due to your position with or connection to the company. The existence of a conflict of interest may not always be clear. If you have questions or need clarification about whether a proposed transaction or situation would lead to a conflict of interest, ask the legal department. If you believe you may have a conflict of interest, let your supervisor, your manager or the human resources department know immediately.
Here are a few examples of potential conflicts of interest:
Related-person transactions are transactions that involve the company and either you or a member of your family. These must be avoided and can only proceed if approved as described on the previous page. Executive officers and directors, as well as their family members, are also subject to additional restrictions.
Business opportunities that arise as a result of your position with the company or during the course of your work are business opportunities of Winnebago Industries. You may not, directly or indirectly, take advantage of any of these business opportunities unless Winnebago Industries is aware of the opportunity, rejects it and gives you approval to pursue it.
Having a substantial investment in our business partners and competitors can create a potential conflict of interest. Such investments should not affect the performance of your employment duties and should not impair your ability to act in the best interest of Winnebago Industries at all times.
If you encounter any of the situations described above, you must disclose the situation to the legal department. They may direct you to take steps to avoid a conflict of interest (or the appearance of one). The legal department may also indicate that the situation requires approval of your supervisor, manager, the legal department or, in the case of executive officers and members of the board of directors, the board or the audit committee.
