You may not ask or accept for yourself or for a relative of yours, neither offer to a client or prospective client, a party to a negotiation, supplier or contractor of any company of ABC Group, any favor, gift, service, entertainment or other benefit which value or frequency exceeds normal business relationship, namely cash or easy liquidity gifts.

You must not receive anything that may influence (or that other parties believe may influence) your independent and commercial judgment, the reputation of ABC Group or the compliance with your obligations.

Normal mutual business entertainment or acceptance of gifts with monetary value below or equivalent to US$ 100.00 (one hundred North-American dollars) (frequently with promotional or public relations purposes or by occasion of traditional celebrations) are permitted, however, in case of doubt, contact the Head of your Department for guidance.

In case of unsolicited gift or benefit which violates this Policy and which you believe a return may cause a harmful effect on a commercial relationship, request written guidance to the Head of your Department, to the Vice President or to Human Resources.

Guidance or approval to Heads of Department must be obtained from their immediate superiors, the Vice President and Human Resources.