What we need to know

  • Business courtesies such as gifts, hospitality and travel may create conflicts of interest or be considered bribery in certain circumstances
  • Gifts are something given without the expectation of anything in return, including goodwill
  • Hospitality takes many forms, including meals and beverages, seminars, receptions, social events and entertainment
  • Travel would include the costs of transportation including taxis,busses, trains, flights, accommodation and hotels, and other incidental travel costs.
  • Business Partners, including Public Officials, may need to comply with strict rules on what they may give or receive

What is expected of us

  • We never offer or accept business courtesies which could, or could be perceived to, improperly influence a business decision
  • We never offer or accept cash or cash equivalents, or expensive and extravagant gifts
  • We do not offer or accept gifts except promotional items, of minimal value, and only when it would be customary to do so
  • We may offer or accept hospitality when the business purpose is clear and legitimate, the costs are reasonable, and the context is open and transparent, but we prefer to cover our own costs
  • We always pay our own costs for travel, accommodation and related expenses. Likewise, we do not pay for travel, accommodation and related expenses for others
  • We do not allow business courtesies to be extended to family or close friends
  • We always discuss offering or accepting business courtesies with our immediate supervisor
  • We seek exceptions only in special circumstances subject to a review by the Compliance Function and prior written approval by the Business Unit CEO.

What to look out for

  • Business courtesies are offered during sensitive situations such as ongoing negotiations or procurement processes
  • We are considering sponsorships, donations or social investments
  • We become aware of business courtesies that are not offered or accepted in an open and transparent manner
  • We believe that offering or accepting business courtesies could lead others to question our independence, objectivity or integrity
  • We become aware of repeated offers to or from the same or a related Business Partner

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