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Corporate Social Responsibility

People behind csr at cisco: why we take ethics and integrity seriously, sarah khokhar.

We have created a new blog series that will focus on the  people behind Corporate Social Responsibility (CSR) at Cisco . Each blog in this series will highlight a different Cisco employee who works closely with CSR initiatives across the company.

Global Ethics and Compliance Manager at Cisco

How people behave inside a company is just as important as how they interact outside a company. Like any Corporate Social Responsibility program that aims to contribute to the greater good, maintaining internal ethical practices means those external programs have greater impact. Would you trust a company that gave back to local communities while their employees were bribing partners or abusing their privilege? Not many would, which is why Cisco takes ethics, integrity, and compliance seriously.

Laura Ellis works with the  Ethics Office , a team that perpetuates a culture of inclusiveness and compliance across and within Cisco. It is their responsibility to ensure policies of the Code of Business Conduct (COBC) are understood by over 75,000 employees, who come to work with diverse backgrounds, beliefs, cultures, and languages. The Ethics Office oversees enquiries, allegations, and disclosures about possible policy violations internally and externally.

Here are a few things you should know about Laura:

Laura is refreshingly passionate about ethics.

Early on, Laura knew she wanted to help people, and she was interested in the big picture. At university, she studied Philosophy and Ethics. Her interest piqued at the different types of ethics she encountered in the world outside of ancient books and philosophers – medical ethics or euthanasia ethics. But something was missing in those university classes.

“The one piece missing from our course was business ethics,” Laura explains. “A business management course was covering business ethics at my school, and I enrolled in the module. We focused a lot on the collapse of a major energy company. It was shocking, ethically, how the company managed to survive for so long with such a toxic environment of deceit. The pressure to succeed and fear of failure were so immense that the company bankrupted itself with one of the biggest business scandals in history.”

From that moment, Laura was hooked. She was captivated by how to prevent a company from culturally eroding. Since she wasn’t sure how to get a job in corporate social responsibility, she focused on HR as her first entry point.

“When I interviewed for an admin assistant role at Cisco, I told the interviewer, ‘I want to work in your Ethics department.’”

Laura got the admin job, and staying true to her goal of working for the Ethics Office, she reached out to the Ethics team, curious to see how she could transition. At the time, the team didn’t have a space open, so she audited the team meetings to learn and understand how things worked. Within a year, she transferred to the Ethics team, and has been there for the past seven years.

Today, Laura’s role is global – she reviews all queries, allegations, and concerns sent to the Ethics Office internally and externally, categorizes them, and triages them to the appropriate teams (Legal, Investigations, etc.) or answers any questions. She also reviews Conflict of Interest Disclosures and external Gifts, Travel, and Entertainment policy processes. Giving gifts externally can be perceived as bribery, so Laura’s team needs to understand local regulations regarding public sector gifts.

Laura believes 99 percent of people want to do the right thing.

Ethics and integrity graphic

Encouraging the  Conscious Culture of Cisco helps in the long term – if an employee shares the same values as the company, they are more likely to safeguard the company from harm and to report potential threats. Cisco nurtures an open environment where employees can feel safe from retaliation if they report anything.

“It’s a fine balance between flexibility and prescriptive policies,” Laura says. “We don’t want our people to feel like they’re policed, but at the same time, we want them to understand that as a global company, we are 100 percent going to take any allegation or investigation seriously. There will be consequences if you’ve breached those policies.”

One of the interesting dichotomies of being in the compliance profession is that low case numbers do not necessarily mean people are compliant. “If you have none, it means no one is speaking up, and if you have too many, you’ve got a problem. I would say our numbers are normal. Ninety-nine percent of people want to do the right thing and our team is there to catch the ones that need a bit of help.”

Laura wants everybody at Cisco to feel like they own a piece of compliance, ethics, and integrity.

Training is a huge part of the Ethics Offices’ responsibilities; however, training doesn’t solve everything. It’s human nature to gloss over policies, and sometimes people are distracted during training. Laura’s team must get creative to help train and educate the entire Cisco workforce so that everyone understands the expectations of Cisco when they make business decisions.

The recent COBC was updated to use more videos, quizzes, and activities that helped employees solidify their knowledge of Cisco policies. On Cisco’s Employee Connection intranet site, the Ethics Office have done quizzes about certain policies. One such quiz revealed that a high percentage of respondents answered incorrectly to Cisco’s gift card policy. “We were amazed. Peoples’ perception of the policy was actually the opposite of our policy,” Laura laughed, “Of course, we doubled down on our efforts to mitigate that. We are very reactive. It is important to understand that the perception of a policy is just as vital as the actual policy.”

Many of Cisco’s policies have recently been fully digitized so that any employee can find any policy. Today, the process is as simple as searching in OneSearch, Cisco’s internal search engine.

The element of human error is one that worries Laura – if someone doesn’t read a policy, they likely aren’t aware that they may be doing something unethical. Part of Laura’s job is to ensure that there are controls and processes in place to prevent policy breaches from happening or catch them very early on.

“Our role is to be the guardrails on either side of a bowling alley. Our people can roll that ball without fear of breaking laws because we’ve put controls in place to prevent that from happening. That’s what helps me sleep at night.”

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Corporate Travel and Entertainment Policy Best Practices

Traveling employees often incur significant expenses on company-funded trips. But how much is too much? According to recent statistics, businesses spend approximately $799 per person per day on a business trip. Expenses can quickly add up if not carefully watched over.  A travel and entertainment policy outlines what expenses are eligible, how much employees (and sometimes senior management) can spend on business-related travel and the specific terms for reimbursement.

In this article, we’ll explore what a travel and entertainment policy entails and how to make the most out of your business travel resources.

Travel and Entertainment Policy Definition

A travel and entertainment (T&E) policy is a set of regulations that govern business-related travel and entertainment expenses. It sets clear parameters regarding what is acceptable in an employee’s spending of company resources and reimbursement procedures. The policy also highlights acceptable activities for employees while traveling on company business; for instance, meetings and conferences.

Why Do You Need a Company Travel and Entertainment Policy ?

For starters, the primary goal of establishing a clearly defined T&E policy is to ensure that employees clearly understand what is expected of them when it comes to spending company funds on work-related trips. It also sets out the guidelines for hosting or entertaining clients for business purposes. 

The travel and entertainment policy also enables management to mitigate risks associated with misuse of funds and identify potential incidents of fraud, alongside non-compliance with legal requirements. 

With that said, here’s a more detailed breakdown of the main objectives of a travel and entertainment policy :

Fraud Prevention

Unfortunately, deliberate and unintentional fraudulent activity in corporate travel still plagues businesses, leading to significant losses in the long run. In fact, it is estimated that companies lose $125,000 to fraud on average. Although the causes and impact of fraud in business vary by department, traveling employees may contribute to fraudulent activity knowingly or unknowingly.  

This arises from the fact that employee and business goals for travel don’t always align. Occasionally, some employees will seek to benefit themselves at the expense of the company. A comprehensive policy prevents fraud by imposing strict procedures for the use of company resources and submission of the expense reports.

>> Related: 5 Ways FinTech Reduces Fraud <<

Better Resource Management

A well-thought-out travel and entertainment policy ensures that employees only adhere to activities that are acceptable and beneficial for the company’s objectives. For instance, paying for a client lunch meeting may be considered acceptable if it helps in solidifying mutually beneficial working relationships.

With a clear policy in place, businesses can ensure that their employees make the most of their allocated travel and entertainment expenses while avoiding overspending and poor management of company resources.

Cost Savings

As mentioned earlier, corporate travel expenses can pile up as a direct result of poor expense management and fraudulent activity. A corporate travel and entertainment policy shields businesses from such issues. This can be achieved by ensuring that spending on business trips, events, and other related activities is done in accordance with the expenses limited by the policy.

The policy also helps companies save money by ensuring that all expenses are properly accounted for and that the company is getting the best value for its money.

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Elements of a Company Travel and Entertainment Policy

Different companies set out different policies that reflect their values and culture. Such elements should be tailored to the specific needs of the organization after taking into consideration its size, budget, regulations, and culture. 

Key elements of a T&E policy include:

The Scope of the Policy

First of all, how a company decides on its travel and entertainment policies does not just revolve around booking flights and hotels. There are regulations and guidelines that govern the spending of the company.

The scope of corporate travel and entertainment policies covers vital details such as: 

  • The person/people responsible for authorizing travel.
  • Who the policy applies to (junior or senior employees?).
  • Possible risks.
  • Expense reporting procedures.
  • Reimbursement procedures.

The list goes on. In essence, the scope of the policy covers all the expectations for employees when traveling on behalf of the company or attending events.

>> Related: The Importance of Well-Defined Travel and Expense Policies for Businesses <<

Travel Approval/Authorization

All travel expenses, routes, and destinations should be authorized by appropriate managers and supervisors before they are incurred. Authorized expenses ensure that the trip is necessary for business, and will be covered by the company’s travel budget. Additionally, an authorization requirement will further help to prevent fraudulent expenses from being submitted for reimbursement.

Travel Budgeting Limits

While each company will have different budget limits, it is important for employees to stay within the budgeted amount so that expenses are kept under control.

Some key considerations for effective budget limits include:

  • The number of days an employee will be expected to be away from work.
  • The total cost of the trip.
  • The number of people allowed to accompany an employee on a business trip.
  • The types of travel that are approved (airfare, car rental, public transport, etc.).
  • Spending on meals or entertainment during a business trip.

Once the total cost of the trip is determined, an appropriate limit can be set for how much money an employee can spend. This limit may be based on the number of people traveling with the employee, among other factors.

Product Tour_ See Travel Management in Action

Travel Risk Management

Travel risk management involves assessing, monitoring, and controlling any risks associated with employee travel. The goal is to protect employees and the organization’s assets from risk by carefully anticipating these risks and adequately planning to mitigate them. 

A risk management plan may include:

  • Establishing safety protocols for the use of local transport.
  • Using approved agencies, suppliers, and companies to ensure quality services and avoid potential scams when booking flights or hotels.
  • Creating a checklist for employees to complete prior to their departure. This checklist can include items such as passport and visa requirements, medical insurance, emergency contacts, etc.
  • Employing tracking technology, such as GPS-enabled devices and applications to monitor an employee’s location during travel.
  • Developing a communication plan for traveling employees so they can keep in touch with the company.
  • Offering security training and advice to employees prior to their departure.
  • Establishing an emergency contact list for traveling employees, in case of any incidents or emergencies.
  • Ensuring that employees are familiar with local laws and customs before they leave.

By taking proactive steps to manage risks, businesses can ensure the safety of their employees while traveling.

>> Related: 10 Questions to Audit and Update Your Business Travel Policy <<

Travel Expense Reporting & Auditing

While T&E policies aim to provide clear travel guidelines for employees, it is important to point out that properly documenting and tracking employee expenses is essential for a company to manage its resources effectively.

Regular auditing further keeps the business compliant with tax regulation policies, and within budget.

When it comes to reporting and auditing travel expenses, there are several measures you can take to ensure accuracy and transparency. 

For starters, clear policies regarding acceptable expenses should be established and communicated to all employees. It should be clearly stated when these expenses must be reported, and more importantly, who is responsible for verifying them. If you’re in charge of a sizeable team, you may also want to consider using automated software systems to monitor and track employee spending in real-time. 

>> Related: Mapping the Travel Expense Accounting Process <<

Action Measures for Non-Compliance

Non-compliance with a company’s corporate travel and entertainment policy can lead to significant financial losses as well as potential legal issues. To ensure that all employees adhere to the rules, a clear action plan must be established for employees who do not comply.

First and foremost, any employee found guilty of violating the policy should receive a formal warning. The warning should be sent via email or letter and should include a detailed explanation of the violation.

If the violation persists, further action may be taken. This depends on company policy around fraud and could include disciplinary measures such as suspension, termination, or even legal action depending on the severity of the situation. 

Regardless, it is important to clearly define these consequences in the travel and entertainment policy so that employees are aware of the potential repercussions.

How to Create an Effective Corporate Travel and Entertainment Policy

Having a clear and effective corporate travel and entertainment (T&E) policy in place can help companies manage their expenses and set expectations for their employees. However, creating a policy that balances employee satisfaction and corporate cost control is no walk in the park.

A well-crafted T&E policy can help organizations save money on their travel and entertainment expenses while also ensuring that employees have a smooth and stress-free experience. 

Here are the key steps taken in developing an effective T&E policy:

Identify the Purpose of the Travel and Entertainment Policy

The purpose of a corporate travel and entertainment policy is to provide guidelines and regulations for traveling employees in their duty to the company. It ensures that company resources are used responsibly and ethically when traveling or entertaining on behalf of the company.

Establish Criteria for Travel

When creating a corporate travel policy, it is important to set clear criteria that determine who is eligible for business travel. Details such as the necessary qualifications, job title, and/or seniority level needed to be eligible for business travel can be outlined in the criteria. Additionally, the criteria for travel define the roles or responsibilities of each person traveling on behalf of the company.

Forecasting Your Budget

Forecasting the budget for business trips helps the company estimate how much money should be allocated for travel expenses and provides insight into which areas are likely to incur the most costs. Forecasting also allows you to set clear expense limits so that employees don’t overspend while on business trips. Some travel management platforms may even help you by calculating dynamic budgets based on real-time rates.

Setting Expense Limits

The policy should also specify which types of expenses are allowable and which are not. This will help employees understand what they can and cannot spend company funds on while traveling, as well as any limits that may apply.

Outlining Acceptable Expenses

It is important to list down what types of expenses are acceptable, as well as the limits on these expenses. 

When it comes to outlining acceptable expenses, there are several categories that should be addressed. Common examples of acceptable expenses in travel and entertainment policies may include transportation, accommodation, meals, and entertainment. It is equally important to specify what types of expenses are not allowed, for instance, personal purchases or services that are unrelated to business travel.

>> Related:  Highlights from the 2023 State of Business T&E Report <<

Handling Expense Claims

Another important aspect of a corporate travel and entertainment policy is to ensure that employees are submitting their expenses properly. To do this, employers should provide clear instructions on how to submit expense claims, as well as any documentation or receipts necessary to support the claim.

Establish a Timeline for Submitting Expense Claims

The company should set clear deadlines for submitting claims and require all claims to be approved before reimbursement is issued. By setting these expectations in advance, you can ensure that all employees are abiding by the same rules when it comes to filing travel and entertainment expenses.

Review All Receipts and Documentation

All receipts and documentation should be properly reviewed. This review should include an in-depth examination of both the original receipts and any accompanying documents. These may include itineraries, expense reports, or other forms of proof.

The purpose of this review is to ensure that any expenses incurred fall in line with the company’s budget. Additionally, the review provides an opportunity to check for any discrepancies or fraudulent activity. If a discrepancy is found, it should be reported to the appropriate supervisor/manager so that any necessary action can be taken.

Compare Expenses to Policy

It is important for businesses to compare employees’ actual expenses to the policy on a regular basis to ensure that all spending is compliant with company regulations.

A good way to compare expenses to policy is by using dedicated expense tracking software . These tools allow companies to track and review employee spending easily, as well as compare it against the policy.

Verify the Accuracy of Expenses

All expenses, no matter how minor, must be reported to the finance department. The responsible supervisor should then assess the accuracy of all expense reports before submitting them for reimbursement. In this process, you should provide a detailed review of individual expense items and overall accuracy of the report as a whole.

>> Related: Sample T&E Dashboards for Proactively Monitoring Compliance, Budget, and Anomalies <<

Follow-Up With Employees

Having a corporate travel and entertainment policy is essential for any business, but it’s just as important to ensure that the policy is being followed. To ensure compliance with company policies and regulations, managers should follow up with their employees regularly.

You should check in with your employees both before and after business trips to ensure that all expenses are properly documented and appropriate. Additionally, you should regularly review employee receipts and other expense documentation to ensure accuracy and compliance with the company’s travel policy.

Pay Approved Claims Promptly

As a business, it is important to pay any approved claims promptly. Doing so helps maintain a positive working relationship with employees and vendors.

When approving claims, ensure the total amount stated in the claim is accurate and all supporting documents are included. Supporting documents may include credit card statements, receipts, and other forms of proof. Additionally, it is important to confirm that the expenses are in line with corporate policy.

Creating a corporate travel and entertainment policy is an important part of a business expense management strategy. By establishing clear criteria for who is eligible for business travel, forecasting the budget, setting expense limits, specifying acceptable expenses, and monitoring spending, companies can ensure that their employee travel activities stay within budget.

What is a travel policy?

A travel policy can be defined as the rules and guidelines established by an organization for business travel matters. Such rules dictate who is eligible to travel, where, and how much they can spend on meals and accommodations. Other essential matters discussed in the policy include reimbursements for expenses.

Why create a business travel policy?

A well-constructed policy helps keep business travel safe, cost-effective, and compliant. The main reason for creating a business travel policy is to protect the organization from financial risks and potential legal issues associated with employee travel.

What should be included in a corporate travel policy?

A comprehensive corporate travel policy contains guidelines for employees and contractors to follow when handling both domestic and international travel expenses. Important matters to be included in the policy should cover reimbursement rates, allowable expenses, booking procedures and restrictions, and safety considerations.

What should you consider when creating a business travel policy?

Key considerations to keep in mind include the destinations and objectives of trips to be taken by employees. The size of the business should also be taken into consideration since startups often don’t have the same resources as established companies.

What’s included in a T&E expense report?

A T&E expense report typically includes details about the dates of travel, expenses incurred, the purpose of travel, and any other relevant information such as airline tickets purchased or hotel accommodation. The names of those attending can also be included along with the cost per person for all meals and entertainment activities.

What travel expenses are deductible?

Generally speaking, several business-related travel and entertainment expenses are deductible. Examples of deductible travel expenses may include transportation (airfare, car rentals, taxis, etc.), lodging (hotel stays), meals, and entertainment.

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In the normal course of business, certain payments for the benefit of government officials may be covered for bona fide business purposes.  For example, paying the reasonable travel expenses for a prospective state-owned entity customer to visit and inspect the company’s manufacturing plant may be a legitimate expense.  Likewise, the giving of small gifts in connection with business meetings or holidays may be customary and accepted in certain countries.

However, gifts, travel, and entertainment are a common area of ABC risk.  Companies should adopt clear policies and procedures to evaluate any proposal to provide gifts, travel, and entertainment before such expenses are incurred.

The FCPA contains two affirmative defenses relevant to gifts, travel and entertainment.  For more on the local law affirmative defense, see here  and for more on the promotional- or contract-related expenses affirmative defense, see here . 

More topics in this series

  • Statutes and Official Guidance
  • Overview of Effective Compliance Programs
  • UK Bribery Act “Adequate Procedures” Defense
  • French Sapin II Law’s “Affirmative Obligation” to Prevent Corruption
  • Travel and Entertainment
  • Charitable Contributions
  • Political Contributions
  • Hiring Practices
  • Third-Party Relationships
  • Mergers and Acquisitions
  • Joint Ventures
  • Spotlight on the New French Whistleblowing Framework

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  1. Gifts and Entertainment Policy

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  2. Gifts & Entertainment Sample Policy

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  4. Travel And Entertainment Policy Template

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COMMENTS

  1. PDF FY22 Code of Business Conduct

    The Code promotes: Honest and ethical conduct in all internal and external relationships Full, · fair, accurate, timely, and understandable disclosure in public reports and documents rotection of condenti erson nd rorietr infortion. Compliance with applicable government laws rules, regulations, and directives.

  2. PDF Cisco Anti-Corruption and Anti-Bribery Policy (External)

    However, if handled inappropriately, gifts, travel, entertainment and other offerings, may violate applicable laws or Cisco or third-party policies or principles. The Cisco Code of Business Conduct (COBC) and the Gifts, Travel and Entertainment (GTE) Policy set forth the standards for an acceptable gift or other offering, and the

  3. PDF English_2019_COBC

    Cisco Systems, Inc. Code of Business Conduct 2019 Ask/Report 2 Contents Welcome Message from Chuck Robbins, Chairman and CEO 3 Our Values 4 ... I Understand Our Gifts, Travel and Entertainment Policy 20 "Ask Yourself" - GTE Decision Tree 21 I Am Trusted with Data 23 I Follow the Law 26 ...

  4. PDF FY20-21 Code of Business Conduct

    The code promotes: Honest and ethical conduct in all internal and external relationships. Full, fair, accurate, timely, and understandable disclosure in public reports and documents. Protection of all confidential, personal, and proprietary information. Compliance with applicable government laws rules, regulations, and directives.

  5. PDF The Supplier Ethics Policy

    Cisco policies Insider trading Gifts, travel, and entertainment Conflicts of interest Unfair business practices Anti-corruption Unauthorized lobbying on Cisco's behalf and speaking to the press Intellectual property rights, privacy, and data protection Cisco's global human rights policy Supplier code of conduct Notice of ethical concerns

  6. Gifts, Travel, and Entertainment (GT&E) Policies

    Your Gifts, Travel, and Entertainment (GT&E) policies, paired with powerful GT&E technology, are some of the best tools for preempting unethical or illegal behavior. Don't sit idle and allow your policies to stagnate on the shelf, going unread, unfollowed, or unenforced. Learn how to avoid the pitfalls of a manual GT&E policy and disclosure ...

  7. People Behind CSR at Cisco: Why we take ethics and ...

    She also reviews Conflict of Interest Disclosures and external Gifts, Travel, and Entertainment policy processes. Giving gifts externally can be perceived as bribery, so Laura's team needs to understand local regulations regarding public sector gifts. Laura believes 99 percent of people want to do the right thing.

  8. PDF Global Gifts & Entertainment Policy

    offering gifts, meals and entertainment to U.S. Government Officials. • Please refer to the Global Anti-Corruption Policy regarding offering gifts, meals and entertainment to non-U.S. Government Officials. • In all other cases, employees may offer or provide gifts, meals or entertainment to Third Parties only

  9. PDF Gifts Entertainment & Travel Policy (GPP10-10

    3 REQUIREMENTS. Giving or receiving gifts, entertainment, and travel must meet the requirements of sections 3.1 and 3.2, below. Where giving or receiving a gift, entertainment, or travel may present a higher risk of corruption, it must be disclosed and pre-approved (Section 3.3). Take particular care offering gifts and hospitality to, or ...

  10. Gifts & Entertainment Compliance: 2020 Best Practices

    Gifts and Entertainment Changes to Make in 2020. The points above are best practices for any year. COVID-19, however, makes 2020 a year unlike any other. Compliance officers need to anticipate that in their travel, gifts, and entertainment policies. For starters, employees are likely to encounter more restrictive travel generally.

  11. Corporate Travel and Entertainment Policy Best Practices

    A travel and entertainment (T&E) policy is a set of regulations that govern business-related travel and entertainment expenses. It sets clear parameters regarding what is acceptable in an employee's spending of company resources and reimbursement procedures. The policy also highlights acceptable activities for employees while traveling on ...

  12. PDF Worldwide Gift and Entertainment Policy

    5 Last Revised: June 2013 The following gifts are never appropriate: gifts of cash, or cash equivalent (such as gift cards or gift certificates); gifts that are bribes, payoffs or kickbacks (e.g., gifts given in order to obtain or retain business, or to secure an improper advantage); gifts that are prohibited by local law; gifts the gift giver knows are prohibited by the recipient's ...

  13. The Complete Compliance and Ethics Manual 2023 Gifts and Entertainment

    By Rebecca Walker, Esq.[1] Gifts and entertainment can be a challenging compliance area for organizations. While traditional wisdom holds that gifts and entertainment can help foster business relationships—and experience suggests that this can indeed be true—gifts and entertainment can also create inappropriate influences as well as ...

  14. PDF Global Gifts and Entertainment Policy

    This Global Gifts and Entertainment Policy covers gifts, meals, and entertainment between Third Parties and FedEx. Appropriate gifts and entertainment can help build and maintain relationships. However, when gifts and entertainment are excessive, they can bring unnecessary risk to our business. This Policy is intended to help us avoid these ...

  15. Gifts, Travel, and Entertainment Overview

    However, gifts, travel, and entertainment are a common area of ABC risk. Companies should adopt clear policies and procedures to evaluate any proposal to provide gifts, travel, and entertainment before such expenses are incurred. The FCPA contains two affirmative defenses relevant to gifts, travel and entertainment. For more on the local law ...

  16. Essential requirements for corporate gifts & entertainment policies

    The following seven points should be reflected in any corporate gifts and entertainment policy and apply to all gifts given on behalf of the company and its officers, employees or directors: No ...

  17. PDF F5 Gifts, Travel and Entertainment Policy-External

    • Extending gifts, travel or entertainment to those you do not have business relations with e.g. spouses, children, family friends of such individuals; • Where there is a government official; • When the gift, travel or entertainment is solicited; • Frequent offers or receipt of gifts, travel and entertainment;

  18. PDF TYPE: Corporate Policy APPROVER: Policy Committee

    spouses or children in offers of gifts, entertainment, and travel is discouraged. You must pay the cost of gifts, entertainment, and travel directly. You may not advance or reimburse the costs to the recipient. The laws, and therefore our policy, for providing gifts, entertainment, and travel differ depending on the recipient.

  19. PDF Gift, Entertainment & Travel Policy

    This policy is divided into 3 sections: Section 1: Overview. Section 2: Accepting and Offering Gifts, Business Entertainment or Travel. Section 3: Definitions and Special Circumstances (e.g. government, solicitation and product testing) When evaluating whether accepting or offering a gift, business entertainment or travel would create the ...

  20. PDF GIFT, ENTERTAINMENT AND TRAVEL POLICY Section One: Scope

    The Gift, Entertainment and Travel Policy is designed to communicate the rules that govern the exchange of business courtesies, and to help you identify and avoid potential conflicts of interest. This Policy is divided into the following four sections: (1) Scope; (2) Guidelines for Exchanging Business Courtesies; (3) Special Circumstances; and ...

  21. PDF Gifts, Entertainment and Third-Party Travel Policy

    Providing travel. Third party travel must be reasonable in value and only be for legitimate business purposes. Unlike gifts and entertainment, however, travel expenses are rarely "nominal". As a result; any request for the payment of travel expenses for third parties must be reviewed on a case-by-case basis.