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We Protect Others

Navigating Conflicts of Interest

At CDM Smith, our work is our passion. But we also recognize that we all have personal lives, commitments and pursuits outside of work that are equally meaningful. In addition, some of our clients have multiple pursuits where we may be engaged in one of many roles, which can sometimes compromise our ability to keep organizational interests separate. Our goal is to make sure these competing interests never compromise or interfere with our professional duties.

Roadmap for Success

  • Learn to recognize the kinds of activities that might conflict with CDM Smith's interest. They are not always easy to spot but often include:
    • Personal relationships: Supervising a friend, family member or partner, or directing business to them.
    • External engagements: Allowing a second job or other outside pursuit to interfere with your responsibilities and commitment to CDM Smith.
    • Financial interests: Investing directly in any company that competes or does business with us.
    • Business opportunities: Taking personal advantage of opportunities you learned about through work that could have benefited the firm.
    • One client and multiple projects: Two different business units working for the same client may result in an unfair advantage unless the opportunity is vetted.
    • Gifts: Accepting or giving lavish, frequent or improper gifts or other business courtesies.
  • Promptly disclose any known or suspected conflicts of interest. Simply discovering you have a conflict is likely not a violation of our Code, but deliberate failure to disclose one might be.
  • Follow all relevant conflict of interest policies outlined in the Federal Acquisition Regulation guidelines (FAR Subpart 9.5) when doing business with the U.S. Federal Government.
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A: No. CDM Smith's conflict of interest policy prohibits employees from working for, creating or maintaining a business that does similar work to what they do at CDM Smith, or work that CDM Smith provides as part of its business offerings. Additionally, any outside employment or side business must be formally disclosed to your manager and to the Compliance team using our Conflict of Interest disclosure form. It is not up to individual employees to determine that their work does not create a conflict with the company's work. The Compliance team will determine whether or not a conflict exists, and if one does, whether it can be mitigated.

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Putting It Together

CP.0300.07 Conflicts of Interest - Personal