GIFTS AND ENTERTAINMENT POLICY

TABLE OF CONTENTS

1. Purpose and Scope
2. Definitions
3. Prohibited Items and High-Risk Scenarios
4. Monetary Thresholds and Approvals
5. Public Officials
6. Commercial Counterparties
7. Logging and Recordkeeping
8. Travel and Hospitality
9. Charitable and Political Contributions
10. Exceptions and Escalations
11. Enforcement
12. Annex: Threshold Matrix and Gift Log Template

1. PURPOSE AND SCOPE

• Prevent improper influence and ensure compliance with anti-bribery and trade control laws.
• Applies to all employees, officers, directors, contractors, and third parties acting on behalf of the company.

2. DEFINITIONS

• Gift: anything of value given without equal value in return (items, services, discounts).
• Entertainment: meals, events, hospitality, or travel provided to/from third parties.
• Public Official: government, state-owned entity employees, candidates, party officials, public international organization staff, or close relatives acting on their behalf.

3. PROHIBITED ITEMS AND HIGH-RISK SCENARIOS

• Cash/cash equivalents (gift cards over de minimis), lavish or indecent venues, personal services, "per diem" payments, travel for family/friends, facilitation payments (unless legally required for safety and pre-approved by Legal).
• Gifts/entertainment during active tenders/approvals or audits are prohibited absent written pre-approval.

4. MONETARY THRESHOLDS AND APPROVALS

[// GUIDANCE: Tailor values by country/risk; include local VAT limits.]
| Category | Threshold (USD or local) | Approver | Notes |
|----------|-------------------------|----------|-------|
| Routine meal (commercial) | [$$] per person | Manager | Must have business purpose |
| Routine gift (commercial) | [$$] per item | Manager + log | No cash equivalents |
| Public official meal/gift | [Lower $$] | Compliance pre-approval | Must be lawful and modest |
| Travel/hospitality | [$$] per trip | Compliance + VP | Agenda required; economy class unless approved |

5. PUBLIC OFFICIALS

• Stricter limits; pre-approval required; document business purpose and attendees.
• No gifts/entertainment to secure improper advantage; record in public official register.
• Consider local laws on even nominal value items.
• New York-specific: Apply the stricter of this Policy or New York state and local ethics rules (state ethics commission guidance, NYC Conflicts of Interest Board rules, and agency-specific policies). When in doubt, treat the item as prohibited and seek Compliance approval.

6. COMMERCIAL COUNTERPARTIES

• Modest, infrequent, and tied to legitimate business purpose.
• Reciprocal hospitality must remain reasonable; avoid timing near contract awards/renewals without approval.

7. LOGGING AND RECORDKEEPING

• Record all gifts/entertainment above [LOG THRESHOLD] in centralized register (date, counterpart, description, value, currency, approval, attendees).
• Keep receipts and approvals for audit; reconcile to expense reports.

8. TRAVEL AND HOSPITALITY

• Pre-approval for paying third-party travel; economy class unless Compliance approves.
• No side trips, spousal/guest travel, or per diem without approval.
• Provide agendas; pay vendors directly where possible (no cash reimbursements).

9. CHARITABLE AND POLITICAL CONTRIBUTIONS

• Charitable contributions tied to counterparties require Compliance/Legal pre-approval; avoid directing to entities connected to public officials without due diligence.
• Political contributions permitted only where legal and approved by [LEGAL/GR]; never to influence official action.

10. EXCEPTIONS AND ESCALATIONS

• Exceptions require written approval from [COMPLIANCE/LEGAL] with documented rationale and controls.
• When in doubt, seek pre-approval; conservative approach prevails.

11. ENFORCEMENT

• Violations may result in discipline up to termination; may be reportable to regulators.
• Non-retaliation for good-faith reporting of concerns or refusals to engage in improper conduct.

12. ANNEX: THRESHOLD MATRIX AND GIFT LOG TEMPLATE

• Annex A: Country/risk-based threshold table.
• Annex B: Gift/entertainment/public official contact log (fields: date, name, entity, role, description, value, currency, purpose, approval, attendees, receipt attached).