Gifts, Entertainment, and Improper Payments

Giving and receiving gifts of nominal value and entertainment that is not lavish or unreasonable is generally an accepted and legal business practice. However, offering, soliciting, or accepting an improper payment, i.e. a bribe, or anything that could appear to be a bribe is absolutely prohibited.

In fact, anti-corruption laws, such as the US Foreign Corrupt Practices Act, the UK Bribery Act, and other anti-corruption laws make it illegal for companies, or any of their agents or foreign subsidiaries, to provide anything of value directly or indirectly to a government or foreign official in order to secure or retain business or steer it to any other company or individual. Penalties can include steep fines and jail time.

Before giving a gift or participating in business entertainment, you are expected to understand any applicable laws, the recipient’s own policies regarding gifts and entertainment, and our policies, including the following guidelines:

For further details, please consult the Code or contact your supervisor. Click the Continue button to advance to the next slide.