How we do business the right way

Avoid Conflicts of Interest

We do not let even the appearance of conflicts of interest tarnish our reputation or relationships.

What is a conflict of interest?

A conflict of interest is when a personal interest can interfere, or appears to interfere, with our professional responsibility to Howard Hughes.

We want our customers, investors, partners, and communities to feel confident that we:  

  • Make our decisions in the best interest of our organization and stakeholders.
  • Do not abuse our positions to enrich ourselves, other companies, or those close to us.
  • Use Company assets for the good of the Company rather than for the personal interests of our directors, officers, employees, business partners, or those close to them.

The need to maintain our partners’ trust is why even the appearance of a conflict of interest is a problem.  

What are some examples of conflicts of interest?

Personal interests that can cause a conflict include:

Having relatives, close friends, or romantic partners involved in our jobs or business dealings.

Having a financial stake in an organization that competes or does business with Howard Hughes.

Using a business opportunity that arose through Howard Hughes for personal, rather than the Company’s, advantage.

Having any additional employment, board service, position, or involvement with organizations that may interfere with our jobs at Howard Hughes in some way.

How We Avoid Conflicts of Interest

  • Disclose close personal relationships or financial holdings that could affect our responsibilities and judgment toward Howard Hughes so that we can get help in managing or avoiding any potential conflicts
  • Avoid receiving loans or other financial benefits as a result of your position that otherwise might not be available
  • Avoid manager-subordinate relationships with close relatives, close friends, or romantic partners, and never make hiring decisions involving them
  • Avoid having financial interests or business dealings with competitors. 
  • Reach out to Culture + People to update your conflict-of-interest form if you believe you have a new, potential conflict to disclose

Follow the Blueprint

A: Romantic relationships between coworkers can potentially create conflicts of interest, especially if one person is in a position of authority over the other or if the relationship could affect decision-making or impartiality. It’s important to disclose the relationship to the Chief People Officer so they can assess the situation and determine if any adjustments need to be made to avoid conflicts of interest. Transparency is key to maintaining professionalism and fairness in the workplace.

A: Disclose the situation to your department head, as well as to Culture + People. We will need to assess the size of your father-in-law’s stake and whether you should have a role in this decision. It is likely you will need to recuse yourself and avoid having any influence over the decision.

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