It is sometimes customary and appropriate, particularly in connection with product demonstrations or promotional events, to give and receive reasonable and proportionate Gifts and/or Hospitality. 

However, if the giving or receiving of Gifts or Hospitality is in any way for the purposes of obtaining an inappropriate advantage or benefit, then this may amount to a bribe which is prohibited under this and other Company Policies and by law. 

Bribery is a criminal offence. The Company prohibits employees from offering, giving, or receiving bribes or personal inducements, or requesting others to do so on their behalf, for any purpose. 

Our Policy (among other things) requires that any Gifts or Hospitality offered, given or received is:

  • In good faith, occasional, appropriate and reasonable and compliant with any applicable laws and regulations;
  • For reasons related to the business of the Company and the individuals involved, and never lavish or extravagant;
  • Never associated with the obtaining of an inappropriate benefit or advantage; and
  • Within the financial limits and approval levels for Gifts and Hospitality and recorded appropriately.

 

Publication date: 20 May 2025

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