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Exchanging Gifts and Entertainment Responsibly

Our Commitment

We earn the trust of our customers and business partners through our performance. Exchanging reasonable gifts and entertainment can build trust and goodwill in our business relationships, but we should never allow these practices to influence our business decisions, or even create the appearance of influence. Gifts and entertainment must have a legitimate business purpose, be reasonable under the circumstances, comply with applicable law and the recipient’s policies and procedures, and reflect our Values.

How We Act with Integrity

Integrity in Action

I would like to send a holiday gift basket valued at $75 to a customer to express gratitude for their ongoing business. Is this acceptable?

Yes. This gift would be acceptable, provided that the customer is not employed by the government and such gifts are infrequent, because it is of “modest” value at less than $100. However, even gifts of modest value can be a problem if they become frequent, conditional, or violate applicable law or the recipient company’s policies.

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Engaging in the Political Process with Integrity