Hospitality and Gifts Policy

1. Introduction

1.1 In general, SEW does not believe that it is appropriate for employees to accepts gifts from customers, suppliers, or any other person or organisation with which SEW has (or might) have business connections. This is because it is important to ensure that no employee acts in any way which is inconsistent with SEW’s objectives or with the integrity of the business by accepting or giving a gift in circumstances which could influence or be seen to influence a business action or decision.

2. Purpose and Scope

2.1 This policy forms part of the terms and conditions of all employee’s contracts of employment and any breach of the policy will be regarded as misconduct, leading to
disciplinary actions, up to an including summary dismissal. This policy is also communicated to all our associated persons such as contractors and consultants to ensure that, when they are acting on SEW’s behalf they also follow such rules.

2.2 This policy is to be read in conjunction with the Anti-bribery and Corruption Policy and the Whistle Blowing Policy which are all on SEW’s intranet and are also available from the Human Resources Department upon request.

3. Hospitality and Gifts

3.1 Gifts and hospitality must not give rise to any appearance of impropriety. Whilst modest hospitality can be permitted in the course of a business relationship, employees should not allow a position to be reached whereby they might be, or might be perceived by others to be, induced into a business decision as a consequence of accepting the hospitality. If you are unsure as to what counts as acceptable hospitality the offer should be declined or advice sought from your Head of Department or their Human Resources Department.

3.2 All employees or those working on behalf of SEW, shall be mindful never to give the impression that a gift, hospitality or other inducement may influence them to show
favour to any individual, organisation, supplier or customer.

3.3 Do NOT offer anything of value to any Government official or other public official.

4. Date of Implementation

This policy is effective from 1st July 2011.

6. Review

SEW reserves the right to periodically review and update this policy.

Appendix to Hospitality and Gifts Policy

When you offer or are offered Gifts and Hospitality:

1. Gifts

  • Do NOT directly or indirectly offer or promise the giving of anything of value to anyone in connection with business dealings in order to obtain an improper advantage or influence an individual to act in violation of his or her duty
  • Do NOT offer monetary gift.
  • Do NOT create an appearance of offering disproportionate benefit even if it was not the intention
  • Do NOT provide gifts to the same recipient so frequently as to raise any appearance of disproportionality and impropriety
  • Do record fairly and accurately any gifts that are made or received in the hospitality record book that is kept by Gillian White in the Swan Building
  • Do pay special attention if the recipient has direct or indirect influence or authority over any decision that will affect SEW’s interests (project tenders, granting of a licence, changes in legislation/regulations, etc.). Could anyone think your gift looks like bribery? Don’t make or accept any gifts during sensitive periods
  • Do not accept, directly or indirectly, anything of value where receipt could or might appear to influence any decision with respect to SEW business decision
  • Do notify the SEW Human Resources and return the gift with an explanation as to why
  • SEW policy preventing acceptance when you receive any gift which does not meet this guideline

Promotional gifts of nominal value which carry the company name and/or logo (such as pens, umbrellas, T-shirts) can normally be offered or accepted.

2. Meals

  • DO NOT offer non-business-related meals.
  • DO NOT offer meals, the value of which is more than that of an ordinary working meal under local standards (avoid very expensive wines and delicacies).
  • DO NOT include the spouse/partner or other guests of the invitee, except for a special occasion

3. Entertainment

  • DO NOT accept invitations to events if you have decision making authority over any decision affecting SEW’s interests from a company during the decision making period. For example, during a tender process; or at the time of annual contract renewals; or entering into new contracts with suppliers; or during a dispute with the person giving/receiving the gift.
  • DO NOT accept large value entertainment gifts from contractors or suppliers as this could give rise to an appearance of impropriety.

4. Travel

  • DO NOT pay the travel and accommodation expenses of third parties which are not directly related to the SEW services.
  • DO make sure that the distance of travel and duration of stay are justified by good faith business reasons.
  • DO make sure that the business purpose could not be accomplished more cost effectively without traveling or by traveling to a closer location.
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