Gifts & Hospitality Policy – External Version 5 5. F ree from undue influence Business C ourtesy should be appropriate to the giver and the beneficiary positions and circumstances. It should therefore never be offered to influence a decision in favor of the given counterpart y or be solicited or creating an obligation on the recipient to give something in return Pay attention to appearances. Even the only appearance of such a situation might create inappropriate judgement . Providing a small souvenir for national holiday and other customary occasion which does not oblige the recipient (e.g. bar of chocolate, postcard, flowers ) (see principle 4 above for reasonable value and nature ) - a B usiness C ourtesy given in secret and/or undocumented. - invitation to travel given to/received from a supplier/customer during a tender process or contract negotiation/renewal given to influence decision maker . - a small, unlawful sum of money given directly or indirectly, to someone to perform routine functions or speed up admini strative formalities which the person is required to provide ( also called “facilitation payment ” ) . 6. P roperly approved and recorded Business C ourtesies must be properly approved (see Section 3 - Approval process) and recorded as such in the accounting documents. 2. 2 . Additional principle s for Hospitality Packages Specific attention should be given to Hospitality packages due to a high cost and potential risk of misuse of such incentives. See below requirements for such travel: Certain c ountries ban Business C ourtesies to public officials (including hospitality packages), See A ppendix for a list of those countries . In countries that allow Hospitality Packages to clients who are Public Officials (e.g. employees of state - owned companies) - such as travel to see a solution prior to a tender or conduct factory acceptance tests abroad after delivery of the project - it is required to clearly state the conditions for the travel by following requirements: ▪ S end an official invitation to the Public Official stating the r ea son for travel and what exactly the Hospitality Package will contain (i.e. what will be paid and what will be not paid by Schneider Electric) ▪ I nform the third party that, in the end, the costs will be charged on the project costs ▪ O btain a confirmation from the third party that the Hospitality Package is in line with ✓ local legislation and ✓ their internal policies . ▪ T he Public Official should arrive to the location maximum 1 day before the event and leave maximum 1 day after - no extra stay is allowed . Allowed Forbidden • Lodging: Hotel Accommodations must be aligned with Schneider Electric’s local Travel p olicies in terms of standing and costs (price per room for a hotel in the Country where the Hospitality Package is given or received) . No 5 - star hotels are allowed for pu blic officials • Transportation (airfare, train, taxi) : Travel class m u st be alighted with local Travel policies • Meal (in line with local thresholds for hospitality ) • Some entertainment activities are possible but should be limited to 20% maximum of agenda’s time • Third - party events’ participation fees • Other travel related expenses (e.g. visa’s cost) • Travel and travel - related expenses for relatives , spouses and other guests • Personal expenses • First - class air travel or private jets expenses • Per diem paym ents* __________________ * Per diems or daily allowances are specific amount of money that an organization gives to cover living expenses when travelling on the employer's business.
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