We exchange only reasonable gifts and hospitality with customers, suppliers, and other third parties and only for legitimate business purposes.

While giving and receiving business gifts and hospitality can build good working relationships and goodwill with customers and suppliers, it also can create a conflict of interest and an appearance of impropriety. We make business decisions based on the quality and value of the products and services offered.

All team members must:

• Never exchange cash or cash equivalents (gift cards, checks or gift certificates) or loans.
• Never exchange any gift or item of hospitality with a government official or commercial entity unless it’s expressly permitted by our policies.
• Be sure to consult and follow any country-specific policies related to gift giving.
• Always complete a Gift & Hospitality Approval and Disclosure Form for any exchange with a government official, regardless of value.
• Given to a government official, in accordance with all policies, disclosure processes, and monetary limits.
• Follow the gift and hospitality policies of our business partners and government officials. Not sure whether someone can accept a gift? Ask them about their policy and seek guidance from the Ethics & Compliance Department.
• Follow all local laws, which may be more restrictive than U.S. law.

GIFT GIVING DO's

Team members may give a gift on behalf of the Company if it is:

• In good faith, without expecting any return favor or improper benefit or business advantage;
• Legitimate/bona fide, reasonable;
• Directly related to the promotion, demonstration or explanation of our products or services, or the execution or performance of our contract; and
• Given infrequently and does not otherwise create the appearance of impropriety.

GIFT GIVING DON'Ts

• Give, offer or receive any gift or hospitality that serves to, or appears to, inappropriately influence business decisions or create an unfair advantage.
• Give, offer or receive cash and cash equivalents.
• Use a third party to offer or give gifts or hospitality to a government official.

GIVING & RECEIVING GIFTS OR HOSPITALITY: DISCLOSURE REQUIREMENTS

If a Government Official IS involved and all
requirements met

• Complete disclosure form regardless of value
• Consult country-specific guidelines document
• Pre-approval if value is more than $25USD (or local equivalent)
• Provide names of officials, amounts and reason for expense on your expense report
  
  

If a Government Official IS NOT involved and all
requirements met

• Complete disclosure form if value is more than $100USD (or local equivalent)