SECTION 7 GIFTS AND ENTERTAINMENT
any gift must be minimal in value and bear the company logo (i.e. article of SEKO clothing, pin, marketing materials, etc.). In addition, special care must be taken in entertaining Government Officials since, like receiving gifts, entertaining has the potential to be seen as a bribe. (vi) Research local laws prior to giving or receiving any gift to ensure you are in full compliance and will not violate any local law. If you violate such law(s) you may be held liable in contempt of the law as well as fines associated with such. There is also the possibility you may lose the business/ service of such client/customer. (vii) Use common sense and good judgment in determining the value of any gifts/entertainment you are giving or receiving while conducting company business. (viii) Any entertainment should not be extravagant Entertainment should not be at a venue that would be embarrassing to SEKO if disclosed publically. SEKO Representatives are obligated to keep books, records, and accounts that accurately and fairly reflect all transactions and disposition of SEKO assets, gifts, and entertainment expenses. In the event that you have questions regarding this policy and/or whether a Gift or Entertainment offer might be appropriate, you should escalate your concern to your direct manager or supervisor. In addition, you may always contact any of the following individuals for direct guidance and/or to report violations of this policy: Senior Director of Compliance is Sandra Scott, sandra.scott@sekologistics.com ; Chief Compliance Officer is James Gagne, james.gagne@sekologistics.com ; General Counsel, Vice President is Char Dalton, char.dalton@sekologistics.com . SEKOwill protect the confidentiality of your questions and subject matter to the extent possible and appropriate under the circumstances. If you feel uncomfortable reporting a violation under your name, youmay make the report anonymously via SEKO’s Confidential Reporting Hotline (see SEKO Anonymous Hotline Policy at www. sekologistics.com ). SEKOwill actively investigate all inquiries under this policy, and if it is determined that a violation has occurred, SEKOwill take appropriate disciplinary action against the offending party - up to and including discharge of the employee or termination of the agreement with such SEKO Representative. SEKOwill not take or permit retaliation against any person who has complained in good faith about a potential violation of this policy, or who otherwise participated in an investigation of such inquiries. or lavish and should be done in good taste and occur at an appropriate business venue.
SEKO recognizes that business gifts and entertainment on a modest scale are commonly used to build goodwill and strengthen working relationships among business associates. Providing or accepting occasional company mementos, meals, tickets to sporting and other events may be appropriate in certain circumstances. However, if offers of gifts, entertainment, etc. are frequent or of substantial value, they may create the appearance of, or an actual, conflict of interest or illicit payment. SEKO has developed this policy to help employees make the right decisions when providing or accepting gifts or entertainment, while conducting business on behalf of SEKO. This policy applies to all divisions of SEKO and SEKO Representatives worldwide. The following are important rules and guidelines to follow regarding gifts, meals, and entertainment: (i) Never give or receive anything of value to influence a decision or to obtain special or preferential treatment. Gifts that are bribes, payoffs or kickbacks (i.e. gifts given in order (ii) Cash or cash equivalents (such as gift cards, gift certificates, checks) are never acceptable business gifts. If at any given time a gift card/ or cash is accepted, it could be considered as a bribe and could at the very least lend itself to the appearance that the employee’s business judgment may be affected. (iii) Frequent gifts (such as meals, promotional items) to the same individual may be inappropriate. (iv) Be cognizant and aware of the customer’s Code of Conduct and potential policies on gifts to obtain or retain business, or to secure an improper advantage) are never appropriate. as some organizations prohibit the receipt of gifts altogether. Many Codes of Conduct and corporate policies that deal with gift and hospitality acceptance contain a general prohibition against accepting any benefit that could lead to an actual or perceived conflict of interest. Violating our customer’s Codes of Conduct could jeopardize and harm business relationships. (v) Be aware that special rules apply in the federal contractor and public sector work. Government or Public Sector servants are not to accept any gifts, hospitality or other benefits that may have a real, apparent or potential influence on their objectivity in carrying out their official duties, or that may place them under obligation to the donor. A general rule of thumb in dealing with Government or Public Sector servants are that
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