This does not mean that gifts, meals and entertainment are prohibited. They can be customary to further good business relationships. They are generally acceptable as long as they are given without improper intention, are reasonable and not intended or likely to influence decisions, create obligations or cause a conflict of interest. We just need to be careful to only offer or receive appropriate gifts, meals, and entertainment that fall within the law and regulations.
What is considered appropriate ? Gifts, meals, and entertainment with a business purpose, reasonable and proportionate to the occasion. They must be legal of course and made openly without expecting anything in return.
Gifts, meals, and entertainment should never be given or offered with the expectation of receiving something in return, as it would then be perceived as creating a situation of conflict of interest or an attempt at bribery or corruption. If or when these criteria are not met, we expect your loyalty and transparency : you must always report such gestures transparently to the Company.
What does it mean?
Gifts, meals, and entertainment refer to any items of reasonable value or hospitality provided to or received free of charge from business partners, suppliers, customers, or other third parties.
Gifts, meals, and entertainment must always be:
- Reasonable - proportionate to the occasion and the position of the recipient, modest in amount and frequency.
- Appropriate - with a legitimate business purpose, suitable in nature and timing for its offering, complying with legal and customary practices.
- Transparent - given openly, ensuring full visibility and documentation of the gesture.
- With proper intent - given without expecting anything in return and free from any intention to unfairly influence decisions or gain undue advantage.
As a result, we never accept cash or cash equivalents (vouchers, gift certificates, or gift cards) ; illegal items (weapons, drugs) ; inappropriate items (any item of sexual nature) ; lavish or extravagant items (all-expenses-paid trip to an exotic destination, memberships to exclusive country clubs).
Additionally, we are not allowed to offer gifts, meals and entertainment to Public or Government Officials (exceptions, if any, require prior assessment and written authorization by the Ethics, Compliance & Privacy department).
How we do the right thing?
Our Do’s
- Before offering or accepting a gift, meal or entertainment, ask yourself the following questions:
- Is it modest or will I feel obligated to reciprocate?
- Is it occasional?
- Is the timing innocent?
- Is it transparent or could it be perceived as an attempt to influence me?
- We disclose and document gifts, meals and entertainment offered, received or refused.
- We only accept or give gifts, meals and entertainment which are appropriate and modest in value.
- We seek guidance when in doubt, or to obtain help when we receive something that is not appropriate and might need to be sent back.
Our Don’ts
- We do not engage in gifts, meals, and entertainment that compromise fair and independent business decisions and that may be or be seen as bribes. Employees must decline them and report them swiftly.
- We never expect anything in exchange of any gifts, meals and entertainment received or offered.
- We do not give or accept anything that we would not feel comfortable discussing with our colleagues.
- We never accept:
- Cash or cash equivalents (vouchers, gift certificates, or gift cards).
- Illegal items (weapons, drugs).
- Inappropriate items (any item of sexual nature)
- Lavish or extravagant items (all-expenses-paid trip to an exotic destination, memberships to exclusive country clubs).
- We are not allowed to offer gifts, meals and entertainment to Public or Government Officials (exceptions, if any, require prior assessment and written authorization by the Ethics, Compliance & Privacy department).
Recognizing inappropriate gifts, meals, entertainment in practice
Because real life is rarely as clear-cut as theory, here are the answers to a few questions you might have.
During a bidding process, a potential supplier suggested that they could offer me and my partner an all-inclusive weekend getaway. What should I do?
Decline the offer and promptly disclose the incident to both your line manager and the Ethics, Compliance & Privacy department. Accepting such an offer could influence your business decisions.
A supplier invites the project team who worked on a long-term project to a dinner, to acknowledge the successful collaboration. Is it acceptable?
Yes, organizing a project dinner after the successful completion of a project is generally acceptable. However, such invitations from suppliers must never be expected, requested or implied as necessary to maintain the relationship. The invitation should be reasonable, infrequent, and clearly unrelated to any ongoing or future business decisions.
If you are unsure or if there are other considerations to take into account, (e.g., ongoing negotiations, active tenders, or the value of the invitation), seek advice before proceeding.