In the marketplace, gifts and entertainment are courtesies designed to build goodwill between companies. They foster positive working relationships between our company and our customers, vendors and suppliers. Conflicts may arise, though, if gifts are offered with the intent to influence a business decision.
In general, we may offer or accept normal sales promotion items, occasional meals or other non-cash items of minimal commercial value. However, it is not acceptable to provide or receive gifts, favors or entertainment if doing so will create or appear to create an obligation. Likewise, you should not offer gifts, favors or entertainment with any expectation of reciprocation. Giving or accepting bribes, inappropriate, lavish or repeated gifts or other benefits is always prohibited, even if acceptable according to local customary practices.
Q: Dominic works closely with several Timken suppliers. One of these suppliers recently held a customer appreciation golf outing. A random drawing was held for a week’s vacation in Hawaii, and Dominic won. Is it appropriate for him to accept?
A: It’s important for Dominic to discuss this with his supervisor or manager before accepting. Depending on how many customer representatives attended and how the drawing was conducted, the prize may be acceptable. However, if accepting the prize will affect Dominic’s judgment and relationship with this supplier, it creates a serious conflict of interest. The same is true if the prize negatively affects Timken’s image – especially to other suppliers.
You may not request or solicit gifts or services, or request contributions from customers, suppliers or other business partners for yourself or for Timken, with the exception of charitable organizations the company supports. Consider the following guidelines when giving and receiving gifts and entertainment. They should:
- Be consistent with accepted business practice
- Be of nominal value
- Be in good taste
- Be infrequent
- Be unsolicited
- Not embarrass you or the company if they were publicly disclosed
- Not be in the form of cash or cash equivalents
If you are offered an inappropriate gift, you should decline it. If doing so would cause you or the company embarrassment, you may accept the gift but then immediately report it to your supervisor or manager, as well as legal services for help in determining an appropriate course of action.