Don’t accept shiny gifts

01 Gifts & Hospitality

We make sure gifts and hospitality always support a clear business objective and are: openly disclosed and accurately recorded, of reasonable value and appropriate to the nature of the business relationship.

Three key things

1

Never offer or accept gifts, travel, payment or hospitality in return for a favorable decision or business advantage

2

We always pay our own legitimate business accommodation and travel expenses

3

Gifts that you receive may need to be recorded

Definitions

A gift is defined as the offering or receiving of goods or services with a market value. A gift becomes a bribe when there is intent to influence business relationships and decisions.

Business entertainment and hospitality, meetings with current or potential customers and suppliers and stakeholder relations are only appropriate when they follow our Code of Responsible Business Conduct, as well as applicable laws and regulations.

Do the right thing

We make sure we’re doing the right thing by:

  • Paying all accommodation and travel expenses for employees attending events relevant to our business
  • Recording and placing all gifts with a market value above USD 50 in the company gift repository
  • Recording all gifts received by employees engaged in a supplier selection process regardless of the value

Hospitality and gifts can complicate business decision making, so think carefully before offering or taking them. Use your judgement to evaluate the situation, even if the above limit is not exceeded. Note that lower limits can sometimes apply, depending on local guidelines.

In particular, you should:

  • Not offer or accept gifts, travel, payment or hospitality in return for a favorable decision or business advantage
  • Not give gifts, aside from low value company branded items such as pens, to public officials
  • Record gifts with the company gift repository when appropriate
  • Avoid inappropriate gifts and hospitality by actively communicating our policy to vendors and third parties

In practice

I’ve received an approval request for VIP tickets to a jazz festival from an insurance company, who is also the sponsor of the event. The invitation includes tickets and accommodation. Is it OK to accept?

If there is a clear business reason (e.g. we are the client of this company, meeting with important stakeholders), and the event is transparent (with an official invitation and many participants) and of reasonable value then it is OK to go. However, we need to pay for the travel and accommodation ourselves.

The New Year is approaching and I want to give a gift to our stakeholders. The corporate sales team has suggested giving a basket of sweets and a branded headset to a group of corporate customers, including some from the public sector. Is this OK?

To ensure we operate within company policy and local law, don’t give the basket to the public sector customers. You could instead give them a branded notebook and pen, worth less than USD 10. It’s also important to ensure any private sector recipients are objectively (not subjectively) selected.

Find out more

For more information, see our Anti-Bribery and Corruption Group Policy.

If you’re unsure what to do, speak with Group Ethics and Compliance or your local Ethics and Compliance Officer.

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