Gifts & Hospitality Policy – External Version 3 Business C ourtesies – a ny thing of value, such as Gifts , E ntertainment or H ospitality , directly or indirectly offered to or received by third parties (customers, suppliers, partners, etc.) . Business C ourtesies may include, but isn’t limited to: o Marketing material – any kind of branded element and material used to promote a company , its product or its services (business cards, letterhead, flyers, brochures, booklets, thank you cards, catalogues, postcards, USB drives, pens, mugs, tote bags ... ). o Gift – a ny tangible or intangible benefit given or received without the expectation of payment or any thi ng in return ( e.g. loans, prizes, transportation, use of another company ’ s vehicles, use of vacation facilities, stocks or other securities, participation in stock offerings, home improvements, tickets , gift certificates , etc . ) . o E n tertainment – a ny form of hospitality, promotional spending , cultural or sports activities, events, occasional business meals or drinks where Schneider Electric employee and third - party employee are present . If Schneider Electric employee is not present during the activity , such activity is considered as a gift . o Hospitality P ackage – any reception and entertainmen t for existing/potential partners, distributors, customers or other third - party to participate in S chneider Electric - organized events or third - party events for marketing, promotional or advertising purposes (e.g. Innovation Summit) or to perform a Factory Acceptance Test. Public O fficial ( also called G overnment O fficial) : o a nyone holding a legislative, administrative or judicial position ; o a ny elected official or employee of a government, ministry, public agency, political party, state - owned enterprise, or other government institution ;  for the purposes of this Policy, a state - owned enterprise , is a legal entity created by a government to take part in commercial activities on its behalf or with a specific purpose defined by law. If needed, please rely on local legislation for other definitions applicable to your jurisdict ion. o a ny official or agent of a public international organization (e.g. the United Nations Organization, the World Trade Organization...) . 2.1. P rinciple s for all Business C ourtesie s In line with our Anti - corruption policy, Schneider Electric employees must assess compliance of a Business C ourtes y before offering or accepting them , by using the 6 “Gold en ” principles : Principles Description Examples of a llowed B usiness C ourtesies Examples of f orbidden B usiness C ourtesies 1. Regulatory Compliant Must comply with local and international laws and Allowed by receiver’s country of residence / country of origin and recipient’s company . In some countries B usiness C ourtesy for public officials are 1. Definitions 2. Acceptability assessment – Key P rinciples