Code of Business Ethics

Gift Giving and Receiving

Developing good working relationships with our customers, suppliers and business partners is important to our growth. Reasonable gifts and entertainment are courtesies that are at times exchanged to foster these relationships and build goodwill. However, providing gifts and entertainment can also create the perception that business decisions were made based on factors other than fair and objective business criteria. It is for this reason that we must exercise caution and be thoughtful when giving or receiving business gifts and entertainment.

We have a responsibility to make sure that any gift, entertainment or other benefit we give or receive is appropriate and consistent with company policies. Avoid all gifts, entertainment or benefits that might compromise or appear to compromise the objectivity of all involved parties. Gifts, entertainment or other benefits should never influence or give the appearance of influencing impartial decision-making.

What is expected of you?

  • Do not solicit or accept any gift, entertainment or other benefit from anyone in exchange for doing business with our company.
  • Never offer or accept any cash gifts, cash gift equivalents (such as gift cards) or loans under any circumstances.
  • Seek the guidance of the Director of Compliance & Integrity or a Legal & Compliance Department representative if you are unsure whether you should offer or accept a business gift, entertainment or other benefit.

Practice Tips

As a general rule, you may give or receive gifts, entertainment or other benefits that are:

  • Infrequent and reasonable in value
  • In the ordinary course of business
  • Consistent with customary practices in your industry and country
  • NOT solicited
  • NOT in cash or cash equivalents, such as gift certificates or gift cards
  • NOT tied to a potential contract or business deal
  • Compliant with all applicable laws and regulations
  • NOT given to government officials or government employees
  • Permitted by the other party’s company policies

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