Gifts and Hospitality

Conflicts of interest can arise when employees are offered gifts, hospitality or other favors, which might, or could be perceived to; influence their judgment in relation to business transactions such as placing orders and entering into contracts. Gifts, hospitality and sponsorships may not be given and received except as permitted by applicable law and/or regulation and must be in line with the company’s policy on gifts, hospitality and sponsorship. There should be no underlying motive to illegally or improperly influence a transaction, decision or activity by the giving and receipt of gifts, hospitality and sponsorship. The corporate executive committee of the company will periodically determine a threshold applicable throughout the company which will govern receipt of gifts from external parties in any one year. The value of any gift, hospitality or sponsorship received or the cumulative value of gifts, hospitality or sponsorship received from one external party which exceeds the threshold must be disclosed.

Acceptance of unsolicited gifts and favors of the following nature would not be considered contrary to this code and policy on gifts, hospitality and sponsorship provided they are lawful and there is no underlying motive to influence illegally or improperly a transaction, decision, activity or secure favorable treatment:

• Advertising or promotional material of limited commercial or nominal value such as golf shirts, mugs or calendars;
• Occasional business entertaining such as lunches, cocktail parties or dinners;
• Occasional personal hospitality such as tickets to local sporting events or theatres, provided that the cost of any accommodation and transportation is borne by the recipient;
• Appropriate and customary and cannot reasonably be considered extravagant and in line with accepted business practice; and
• Gifts that would not be embarrassing to the company, the employee or the giver when subjected to scrutiny.

Unacceptable forms of gifts and entertainment include, but are not limited to, cash or cash equivalent (gift cards and vouchers etc.), product or service discounts that are not available to all employees in the business unit or department, gifts of a monetary value higher than the stipulated threshold amount, accommodation, flights and other forms of transportation.

We should not accept personal favors or other preferential treatment when these are offered on account of our employment with or position in the company. We should not solicit and should be cautious in accepting gifts, entertainment and hospitality offered by business partners and parties, and entities with which the company is negotiating or considering transactions or contracts. These might be perceived as placing the company under an obligation.

It is permissible for employees who accept invitations as guest speakers, lecturers or who serve on professional bodies or institutions to accept a sponsor’s offer to pay reasonable accommodation and travel costs provided the offer is routinely made as part of the sponsor’s practice and the offer is disclosed and approved. The giving and receipt of gifts, hospitality and sponsorship as outlined in this code and permitted under the company’s policy do not automatically make it acceptable to receive or give gifts, hospitality and sponsorship contrary to the stipulation of any applicable legislation or regulation.