Offering or receiving items of value can be a customary part of developing working relationships with our business partners. However, integrity in business is important. To avoid the appearance of a conflict of interest or bias, be especially mindful of our gift policies when dealing with vendors and other business partners during the holiday season.

You may offer gifts to or accept gifts from anyone doing or seeking to do business with our company as long as the gifts are:

  • Infrequently offered or received;
  • Not solicited;
  • Valued at no more than $400 USD (or local equivalent) in any given year; and
  • Not in the form of cash, checks, or gift cards from Visa, MasterCard, or American Express

Note: Different rules apply to gifts to or from a government official.

Gifts in excess of $400 USD must be reported to the Global Ethics & Compliance department and your Department Head and documented on the Business Ethics Disclosure Form.

If a gift does not meet our guidelines, what should you do? 

  • Return the gift, if possible, explaining our company gift policies.
  • Keep the gift as long as you make a donation to a company-supported charity in an amount equal to the market value of the gift minus $400 USD, and provide proof of the donation to Global E&C.
  • Share perishable gifts such as food baskets with members of your department.

Visit the Global Ethics & Compliance intranet site and refer to the Anti-Corruption Policy and Guidelines as well as the Code of Business Conduct and Ethics for additional guidance on giving or receiving gifts.

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