GIFT AND ENTERTAINMENT
DEFINITION OF GIFTS
“Gifts” are items and services of value that are given to any outside parties, but do not include items described below.
- Normal business entertainment items such as meals and beverages are not to be considered “gifts.”
- Items of minimal value, given in connection with sales campaigns and promotions or employee services, safety or retirement awards are not to be considered “gifts” for purposes of this code.
- Contributions or donations to recognized charitable and nonprofit organizations are not considered gifts.
- Items or services with a total value under $100 per year are excluded.
DEFINITION OF SUPPLIER
“Supplier” includes not only vendors providing services and material to the company, but also consultants, financial institutions, advisors, and any person or institution which does business with the company.
GIFTS
No employee or member of his immediate family shall solicit or accept from an actual or prospective customer or supplier any compensation, advance loans (except from established financial institutions on the same basis as other customers), gifts, entertainment, or other favors which are of more than token value or which the employee would not normally be in a position to reciprocate under normal expense account procedures.
Under no circumstances should a gift or entertainment be accepted which would influence the employee’s judgment. In particular, employees must avoid any interest in or benefit from any supplier that could reasonably cause them to favor that supplier over others. It is a violation of the code for any employee to solicit or encourage a supplier to give any item or service to the employee regardless of its value, no matter how small. Our suppliers will retain their confidence in the objectivity and integrity of our company only if each employee strictly observes this guideline.
REPORTING GIFTS
An employee who receives, or whose family member receives, an unsolicited gift prohibited by these guidelines, should report it to his supervisor and either return it to the person making the gift or, in the case of perishable gift, give it to nonprofit charitable organization.
DISCOUNTS
An employee might accept discounts on a personal purchase of the supplier’s or customer’s products only if such discounts do not affect the company’s purchase price and are generally offered to others having a similar business relationship with the supplier or customer.
Entertainment and services offered by a supplier or customer may be accepted by an employee when they are associated with a business meeting and the supplier or customer provides them to others as a normal part of its business. Examples of such entertainment and services are transportation to and from the supplier’s or customer’s place of business, hospitality suites, golf outings, lodging at the supplier’s or customer’s place of business, and business lunches and dinners for business visitors to the supplier’s or customer’s location. The services should generally be of the type normally used by the company’s employees and allowable under the applicable company’s expense account.