We're always eager to show gratitude toward our clients and business partners, and they often do the same for us. But when gratitude takes the form of gifts, meals, entertainment or hospitality, we must exercise extreme care. Offering and receiving business courtesies is about strengthening relationships, not gaining an unfair advantage.

Roadmap to Success

• Be aware that all gifts and courtesies must comply with the law, CDM Smith policies and the policies of the other party's organization.
• Business courtesies should be modest in value and given infrequently. Business courtesies exceeding the policy thresholds require Compliance and Unit President (or Corporate functional head) review and approval.
• Avoid even the appearance of corruption by ensuring business courtesies are given openly, tied to legitimate business purposes and never in the form of cash or cash equivalents (such as gift cards, gift certificates or loans).
• Help maintain the accuracy of our records by properly recording all gifts, meals and other related expenditures.
• As a general rule, government officials have strict rules and limitations on the acceptance of gifts and other business courtesies.
• Employees are strictly prohibited from offering gifts or other business courtesies to or accepting business courtesies from U.S. Federal Government employees, military officers or their agents.
• In the event lodging, per diem and transportation costs may be required for government officials, seek pre-approval, regardless of cost.

Putting It Together

CP.0300.06 Business Courtesies