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Gifts and hospitality Freedom of association
11. Business gifts and hospitality are sometimes 12. We recognise that employees may be
used in the normal course of business interested in joining associations or involving
activity. However, if offers of gifts or themselves in civic or public affairs in their
hospitality (including entertainment or personal capacities, provided such activities do
travel) are frequent or of substantial value, not create an actual or potential conflict with
they may create the perception of, or the interests of our company. Our employees
an actual conflict of interest or an ‘illicit must notify and seek prior approval for any
payment’. Therefore, gifts and hospitality such activity as per the ‘Conflicts of Interest’
given or received should be modest in value clause of this Code and in accordance with
and appropriate, and in compliance with our applicable company policies and law.
company’s gifts and hospitality policy.

RemembeR…

As a general rule, we may accept gifts or hospitality from a business associate, only if such a gift:
• has modest value and does not create a perception (or an implied obligation) that the giver
is entitled to preferential treatment of any kind;
• would not influence, or appear to influence, our ability to act in the best interest of our company;
• would not embarrass our company or the giver if disclosed publicly.
The following gifts are never appropriate and should never be given or accepted:
• gifts of cash or gold or other precious metals, gems or stones;
• gifts that are prohibited under applicable law;
• gifts in the nature of a bribe, payoff, kickback or facilitation payment*;
• gifts that are prohibited by the gift giver’s or recipient’s organisation; and
• gifts in the form of services or other non-cash benefits (e.g. a promise of employment).
(*‘Facilitation’ payment is a payment made to secure or speed up routine legal government
actions, such as issuing permits or releasing goods held in customs.)

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