Code of Conduct: Integrity Standard - Gifts, Gratuities & Kickbacks Q&A
| 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 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 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).
Integrity Standard - Gifts, Gratuities, and Kickbacks
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