The Company recognizes that exchanging business courtesies such as meals, entertainment, routine promotional gifts, and other items can be a part of building strong business relationships. However, at other times, such business courtesies are not appropriate.
The Company’s aim is to deter providers of gifts or entertainment from seeking or receiving special favors from Covered Persons in connection with activities performed by or for, or business relationships established with, the Company. The concern is that gifts of more than a nominal value may cause Covered Persons to feel placed in a position of “obligation” and/or give the appearance of a conflict of interest. Covered Persons should not solicit any third party for any gift, gratuity, entertainment or any other item regardless of its value. Covered Persons are encouraged to be guided by their own sense of ethical responsibility, along with any policies or guidelines adopted from time to time by the Company with respect to gifts and entertainment.
The Company provides guidelines to help determine when accepting or offering such courtesies may be appropriate and when to seek advice. As customs vary throughout the world, these guidelines may differ by country. However, there are some principles that are fixed and apply worldwide:
- Do not offer or accept bribes. Do not offer or accept, or attempt to offer or accept anything designed to obligate a person to act improperly or to influence a person’s decisions with regard to the Company’s business.
- Do not offer or accept cash. Do not offer or accept, or attempt to offer or accept, cash or cash equivalents.
- Do not violate the law. Never participate in any business entertainment activity that would violate the law or may embarrass the Company by its public disclosure.
- Do not accept or give anything of value from or to foreign governments, political officials, or candidates for political office. Anything of value accepted from or given to any foreign government or political party officials or candidates, such as gifts and entertainment, are strictly regulated and often forbidden entirely.
- Do not seek personal favors. Do not seek favors directly or indirectly, such as gifts, entertainment, sponsorships, personal loans or loan guarantees, or contributions from individuals, companies, or organizations doing business or seeking to do business with us.
- Do not accept gifts that obligate the company. Do not accept a gift or service that obligates (or appears to obligate) you or the Company to any third party, such as a customer, supplier or other third party, as such is prohibited.
All Covered Persons are strictly prohibited from offering or giving gifts, meals or entertainment to business partners or others (including government officials, government employees, certain other government-related entities and persons, and certain family members of the foregoing) in order to improperly influence them. Covered Persons should consult the Company’s Anti-Corruption Policy before providing gifts or other items of value, including entertainment and travel, to others and should seek to avoid even the appearance of any impropriety. Covered Persons should be aware that practices that may be acceptable in the commercial business environment (such as providing certain transportation, meals, entertainment and other things of value) may be unacceptable and even illegal when they involve government officials, government employees, certain other government-related entities and persons, or certain family members of the foregoing, or others who act on behalf of government entities or persons. Therefore, Covered Persons are required to comply with the relevant laws and regulations governing relations between government officials, government employees and related entities or persons, on the one hand, and customers and suppliers, on the other hand, in every country where the Company conducts business.
Gifts, favors, and entertainment may be given to others at Company expense only if the gift, favor, or entertainment meets all the following criteria:
- It is not in violation of any applicable law or ethical standard.
- It cannot be construed as a bribe, kickback, payoff, or other potentially corrupt behavior.
- It is consistent with customary business practices.
- Public disclosure of the facts will not embarrass the Company or the individual.
Election laws in many jurisdictions generally prohibit political contributions by corporations to candidates. Many local laws also prohibit corporate contributions to local political campaigns. In accordance with these laws, the Company does not make direct contributions to any candidates for federal, state or local offices where applicable laws make such contributions illegal and, in such cases, contributions to political campaigns must not be made with or reimbursed by the Company’s funds or resources.