Anti - Corruption Policy – Version 3 – September 2021 6 Internal 2.2 Additional rules concerning specific risks 2.2.1 Gifts and hospitality A business courtesy, also called gifts and hospitality, means anything of value that you give or receive, either directly or indirectly. It may be a tangible or intangible benefit including, but not limited to, goods or services, promotional products, hotel accommodations, entertainment (tickets to events, recreational activities, etc.), company events, meals, drinks, transportation (including upgrade of airline sitting class), gratuities, discounts, personal favors or anything else with a monetary value. Business courtesies help build good business relationships, but they can be interpreted as corruption. You must ensure that : • All gifts, invitations and hospitality packages offered are appropriate and in line with our global and local Gift & Hospitality policies; • Before accepting or receiving a gift, a benefit or an invitation, you consider how it might be perceived publicly and refuse those that might put you in a conflict of interest; • You are transparent with your manager so as to avoid any suspicion of violating the internal declaration procedures regarding gifts, invitations and other benefits; • You never give cash as a gift, whether directly or indirectly, even if such gifts are permitted under local laws or acceptable according to local practices. • You comply with Gift & Hospitality policies and internal authorization process regarding business events, by first contacting your Compliance Officer. Case 1: You are planning to travel abroad to meet with foreign public officials to obtain some legal authorizations. To make sure that the public officials will support your case, you offer him a 6 - bottle wine box and perfume for his wife. Disproportional hospitality and gifts are often linked to obligation or expectation to provide a benefit in return, characterizing bribery or giving the appearance of corruption. Case 2: You participate to a big sales event of one of our partners, and you participate to the contest organized for the event. You win the contest and related price which is a trip for you and your spouse in a dream - like destination. You must refuse and explain our Gift & Hospitality Policy; in parallel, please inform your Compliance Officer and your manager.
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