Integrity
Standard - Gifts, Gratuities and Kickbacks
Policy:
We must maintain the highest standards of integrity and objectivity
in dealing with vendors and service providers. We are prohibited
from accepting or giving gifts or gratuities beyond common
business courtesies of nominal value. Gifts or items of value
must never be offered to or accepted from government employees.
Under no circumstances will we accept or give kickbacks when
obtaining or awarding contracts, services, referrals, goods,
or business. A kickback means to willfully offer, receive,
request or pay anything of value, even nominal value, in order
to induce or reward referrals of business including goods
or services.
We will not accept or offer gifts, gratuities or favors
except those associated with common business courtesies
of a nominal value of $50 or less given to or received from
one source. The value of all gifts received in one year
from all business sources must not exceed $150. Gifts exceeding
this policy may be made to customers or other persons subject
to President, Executive Vice President or Senior Vice President
approval.
We must not offer or accept gifts of cash or cash equivalents
to or from any current, former or potential vendor, customer,
broker, or provider. Cash equivalents include checks, honorariums,
money orders, stocks and saving bonds. Gift certificates
and gift cards are not considered cash equivalents for the
purposes of this Standard but are subject to the limitation
on common business courtesies stated above.
Entertainment and meals offered or received by employees
as part of legitimate business activity are not included
in the $50 gift limit, but must be within the boundaries
of reason and moderation. Generally, raffles and prizes
that are part of an outside business activity are not considered
gifts.
Although the Company does not set a dollar limit on gift
giving among employees, it is important to always use reason
and good judgment when giving or accepting a gift. Gifts
of nominal value are always best and contributing to a gift
should always be voluntary. A gift should never be given
to another employee to influence, gain favor or show favoritism.
In addition, Company-approved items provided to employees
as recognition for a business achievement or as part of
Company-sponsored events are not considered gifts for the
purposes of this Standard but are subject to all applicable
federal, state and local tax requirements.
Questions & Answers
Q. A vendor has invited me to its
corporate headquarters to evaluate some new equipment which
the Company is thinking of purchasing. The headquarters
is in another city and the vendor has offered to pay all
of my expenses. Is this okay?
A. No. You must avoid even the appearance
that your decision to buy might be improperly influenced.
If there is a business need to evaluate this equipment,
the Company should pay all expenses.
Q. A vendor has offered me four tickets to the ball game.
The face value of each ticket is $50.00. The vendor does
not plan to attend the event. Is this entertainment or a
gift? Can I accept the tickets?
A. No. The offer of these tickets would
not be entertainment or an acceptable gift. Entertainment,
such as sporting, arts, culture or charitable events must
be part of a legitimate business activity and be within
the bounds of reason and moderation. If the vendor will
not be present then the event is not a legitimate business
activity. Also, you may not accept the tickets as a gift
since the value is $200.00 which exceeds the gift limit
of $50 from one source.
Q. A group of Company employees worked with a consulting
firm on an important special project. After successfully
completing the project, the consultant presented each member
of the group with an engraved pen and pencil set, which
is under $50 in value, as a memento of the project. Is it
okay to accept this gift?
A. Yes. This is a customary business courtesy
and does not give the appearance of improperly influencing
your judgment.
Q. Should Company employees accept compensation for participating
in professional committees or panel discussions, or making
presentations related to Company business?
A. No. Company employees may not receive
compensation for such participation. Compensation for these
types of activities is often referred to as an honorarium.
If an honorarium is paid to an individual, it should be
returned to the sender promptly with a declination letter
explaining the Company’s policy, and a copy of the
letter declining the honorarium should also be sent to the
Compliance Officer.
Q. One of my co-workers is retiring and I would like to
take up a collection in our department and buy her a gift.
Is this okay?
A. Yes. You may take up a collection as
long as your management approves and the contributions are
voluntary. No one should feel pressured or coerced into
contributing or contributing a specific amount toward the
gift. Also, arrange to collect the money in a manner and/or
during a time that is the least disruptive to the work area.
Remember, if you do not understand, or if you have
any questions concerning, this Integrity Standard or any
other part of the Code, contact your Supervisor, a higher
level Supervisor, any of the Corporate Resources or call
the Corporate Integrity HOTLINE
(1 800 838-2552).
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Conduct Page
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