The purpose of business entertainment and gifts in a commercial setting is to create good will and sound working relationships, not to gain unfair advantage with customers. No gift or entertainment should ever be offered, given, provided, or accepted by any Company employee, family member of an employee or agent unless it: (1) is not a cash gift; (2) is consistent with customary business practices; (3) is not excessive in value; (4) cannot be construed as a bribe or payoff; and (5) does not violate any laws or regulations. Without approval of your supervisor and a Corporate Officer or a direct report of a Group President, you may not receive a gift in excess of $500 in value. This limit applies to one-time gifts as well as a series of gifts to the same recipient, or from the same source, within a 12-month period.
Gifts of a nominal value may be accepted on an infrequent or occasional basis, such as during the holiday season, as a reasonable business courtesy.
Routine business-related entertainment, such as a business lunch or dinner, sports outings or cultural events, is acceptable under this policy, without regard to the gift limit above as long as the event has a business purpose and the applicable vendor or customer is attending the event with you (otherwise, the entertainment is considered a gift and subject to the gift limit described above).
At times, alcohol may be available at company-sponsored functions and business-related activities. In such situations, use discretion and act responsibly to ensure your safety and the safety of others.
You also should not provide gifts, gratuities, and entertainment to Company employees or agents that would be prohibited by the Code if they were made by third parties to Company employees or agents.
Please discuss with your supervisor any gifts or proposed gifts that you are not certain are appropriate.
Government officials: There are special rules (including criminal laws) that apply to dealing with for government officials, including federal, state, and local officials, as well as officials of other countries. Consult the Legal Department before you offer, promise, or provide gifts, entertainment, or anything else of value to any official.