WE EMPOWER EACH OTHER
WE'RE AT OUR BEST WHEN WE WORK TOGETHER.
Gifts, Entertainment, and Hospitality
We do not seek to gain advantage through the improper use of gifts or entertainment. While the moderate and reasonable exchange of gifts and entertainment is acceptable, good judgment must be exercised to avoid reputational damage to our company and employees.
Offering, giving, soliciting, or receiving any form of kickback or bribe is always prohibited.
Modest meals, entertainment, or gifts that are less than US$200 in value are usually acceptable, but if you have doubts, ask yourself the following questions:
- Is it offered regularly?
- Does the gift come in the form of cash or a cash equivalent?
- Is it unrelated to any legitimate business purpose?
- Does it violate our Code, policies, or the law?
- Does it violate the other party's policies?
- Is it meant to influence a business decision?
- Are reciprocal gifts or favors expected in return?
- Is it given discreetly or "off the books?"
- Is it illegal, offensive, or sexually explicit?
If you answered "YES" to any of these questions, the gift is inappropriate and should be declined and reported.
- Any gift or entertainment over our US$200 limit
- Any gift or entertainment for a government official, regardless of value
You can access our gift and entertainment disclosure forms for gifts given and gifts received online.
If you receive a gift that doesn't meet our policy, return it. If it is impossible to return the gift, contact the Compliance Committee.
A "kickback" is a bribe made as a reward for making or influencing a business arrangement.
"Cash equivalents" can include gift cards, stocks, bonds, loans, cryptocurrency, and other securities.
No. This entertainment is not clearly associated with a business purpose, nor is it likely to be under US$200 in value. To avoid even the appearance of potential influence, you should decline. If you have further concerns, report them your manager, the Compliance Committee, or another Speak Up resource.