Modest business gifts and hospitality can build goodwill, but they must never influence — or appear to influence — a business decision. This policy explains what is acceptable.
Scope
This policy applies to all ASOSH employees and business units. Managers may set stricter local rules, but never more relaxed ones. It should be read together with our anti-bribery policy.
Accepting gifts
Employees may accept an unsolicited gift from a supplier, customer or partner only if it:
- is of nominal value (as a guide, under US$100) and is not cash or a cash equivalent such as a gift card;
- does not create the appearance, or an implied obligation, that the giver is entitled to preferential treatment;
- is not offered during a tender, contract negotiation or certification decision involving the giver;
- is permitted by the giver’s own organisation; and
- would not embarrass ASOSH if it were made public.
Gifts that do not meet these conditions should be politely declined or returned, and reported to your manager.
Accepting entertainment
Business meals and events are acceptable when they are infrequent, reasonable in value, related to a legitimate business purpose and attended by the host. Entertainment that is lavish, frequent, offered during a decision, or of an inappropriate nature must be declined. If in doubt, ask your manager before accepting.
Giving gifts and entertainment
- Gifts we give should be modest and, where possible, branded items such as a pen or an article of clothing with the ASOSH logo.
- Hospitality we provide must be reasonable, related to legitimate business and properly recorded.
- “Adult” entertainment, or anything that could be viewed as excessive or offensive, is never permitted.
Government officials
Extra care is required with government officials. Gifts, hospitality or travel may only be provided where local law allows it, the value is modest, the primary purpose is genuinely business-related and it has been approved in advance and recorded. ASOSH does not normally pay travel or expenses for officials’ family members.
Recording and disclosure
Gifts and hospitality given or received above nominal value must be recorded in the gifts and entertainment register, with a description, value and business reason.
Frequently asked questions
How do I judge the value of a gift?
Use common sense and the retail value of an equivalent item. If you are unsure, assume it is above the limit and ask.
Can my manager set a lower limit?
Yes. Managers may apply stricter rules for their teams — for example in purchasing or certification roles.