Legitimate and reasonable gifts, entertainment and expenses

Our group directive on gifts, entertainment and expenses covers both giving and receiving. As a company, we respect a global thresholds and approval processes, taking into consideration local standards in the various regions in which we do business.

We also recognize that other companies and customers often have their own code of conduct to abide by, and we are committed to never putting anyone in a position to violate their commitments. Our controlled and transparent approval process for gifts, entertainment and expenses, serves to support our employees so that they can feel confident they are not crossing the line.

Furthermore, additional controls have been developed for public officials. Employees of government owned or controlled companies are subject to these heightened standards.

In order to determine whether gifts, entertainment or expenses are appropriate, each employee should consider the following criteria:

• Made for the right reason: the gift and entertainment should be given as an act of appreciation, friendship or hospitality;
• No obligation: the gift, entertainment or reimbursement of expense does not place the recipient under any obligation;
• No expectations: expectations are not created in the giver or an associate of the giver or have a higher importance attached to it by the giver than the recipient would place on such a transaction;
• Made openly: if made secretly then the purpose will be suspect;
• No misuse of expenses: payment or reimbursement of expenses shall not be misused to hide inappropriate gifts or entertainment;
• Appropriate: the nature of the gift, entertainment or expense is appropriate and is in line with both general business practice as well as local cultural and ethical standards;
• Legality: it conforms to the laws of the country where it is made and any other applicable laws;
• Conforms to the recipient's rules: the gift, entertainment or reimbursement of expenses meets the rules or code of conduct of the company or organization where the receiving person is employed; and
• Infrequent: such giving or receiving is not a regular happening between the giver and the recipient.