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Handling Potential
Conflicts of Interest

You must act at all times solely in the best interests of P&G. In order to uphold P&G’s reputation, you must be alert to any situations that may create a conflict of interest, whether actual or potential. A “conflict of interest” arises when you have a personal relationship or a financial or other interest that could interfere with your obligation to act solely in the best interests of P&G, or when you use your position with P&G for personal gain.

If you are in a role where you provide P&G funds to a charity, or are involved in charity-related programs on behalf of our Company, see P&G’s Global Policy on Charitable / Community Relations Contributions at

You must act at all times solely in the best interests of P&G.

If you find yourself in a potential or actual conflict of interest situation, you must immediately report it to your manager through the Company’s COI process located at

  • This includes situations that may cause others to reasonably believe you have a conflict of interest, even if you yourself believe you can and will act solely in the best interests of P&G.

  • This way, the situation can be properly reviewed and assessed.

  • P&G will work with you to find an appropriate solution.

  • You are expected to take any remedial actions requested by P&G.

If you are aware of any other potential conflicts at P&G, you should report these to your manager or through the other available means of reporting (see “Where Can I Raise Questions and Concerns” section). Members of the Board of Directors must report potential or actual conflicts to the Chief Legal Officer.

You must be cautious when giving gifts or entertainment to, or accepting gifts or entertainment from, anyone who does or seeks to do business with P&G.

  • You must only participate in business entertainment when it is an integral part of business building activities.

  • Remember that accepting gifts or entertainment may represent a conflict of interest and / or appear to limit your ability to make an objective business decision.

  • In addition, offering such courtesies may be viewed as an attempt to influence a business decision.

  • You must always follow P&G’s policy on External Party Gifts, Meals and Entertainment and also respect and adhere to customer or supplier policies that may not permit the acceptance of gifts or entertainment.

If you are ever uncertain about the appropriateness of a gift or entertainment, you should talk to your manager, Legal or the Ethics & Compliance Office.

You must comply with P&G’s Anti-Bribery policy when giving gifts or business entertainment to Non-US government officials. Some countries prohibit this entirely, no matter the amount. For example, there are strict rules around offering gifts of any value, including meals or products, to members of the U.S. Congress or their staffs.

You must be cautious when giving or receiving gifts or entertainment from anyone who does business with P&G.