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Gifts and Hospitality Procedure: Group Code of Conduct
Gifts and Hospitality Procedure: Group Code of Conduct
Gifts and Hospitality Procedure: Group Code of Conduct
PROCEDURE
GIFTS AND HOSPITALITY PROCEDURE
Overview
This Procedure provides guidance for giving and accepting gifts and hospitality, and applies to all CIMIC
Group Employees.
The Group Code of Conduct (the Code) requires all Employees to exercise care when offering or
accepting gifts and hospitality in order to protect themselves and the Group against allegations of
improper behaviour, conflict of interest or bribery.
The Code prohibits gifts or hospitality which are1:
cash or gift vouchers
gifts or hospitality given or received with the intention of unduly influencing business decisions
hospitality of an inappropriate nature or at inappropriate venues
gifts or hospitality in exchange for business services or information, loans, cash or product/service
discounts not available to all Employees
facilitation payments, even where allowed under local jurisdictional laws or business practices.
Gifts and Hospitality at CIMIC
Offering or accepting gifts and hospitality may be a legitimate means of building good business
relationships. The key principles of this Procedure are that gifts and hospitality must:
be for a legitimate business purpose;
be reasonable in terms of value and frequency; and
not create a sense of obligation.
All Employees are required to exercise judgement in determining what is occasional, proportionate
and modest. The higher the monetary value of the gift or hospitality, the greater the level of
transparency that is required.
What gifts or hospitality can be accepted or offered?
If an Employee is offered a gift or any hospitality, or wishes to give a gift or issue an invitation to any
hospitality, they should follow these steps:
Step 1: Is the item or event for a legitimate business purpose?
If no, or it is otherwise a prohibited gift or hospitality, the gift or hospitality must not be accepted or
offered.
Step 2: If yes, where does the gift or hospitality appear on Table 1?
1
Gifts and hospitality through an intermediary will be treated as given or received directly by the Employee.
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Record only ‐ If Table 1 requires the gift or hospitality to be recorded but does not require approval, it
may be accepted, and the Employee must promptly email the relevant Gift Register setting out the
details including the date, giver/host, the value and details of the gift, event or other hospitality.
Record and Approval ‐ If Table 1 requires the gift or hospitality to be recorded and requires approval
the Employee must:
seek prior approval from their Manager, using the Gifts Approval Form; and
email the Gifts Approval Form, showing the relevant approval, to the Gift Register.
Details of the gift will be stored on the Gift Register.
Where gifts or hospitality are received unexpectedly and prior approval is not able to be sought, (such
as a Christmas gift or a meal following a work meeting) it must be recorded within 7 days of receipt of
the gift or attendance at the event. Retrospective approval must be sought if appropriate.
Gift Register
CIMIC and each Operating Company will maintain a Gift Register which records details of gifts and
hospitality forwarded to it by Employees. The Gift Register will record the details provided to it in a
database for regular inspection and reporting by the General Counsel, Business Conduct
Representative and/or Internal Audit. Entries in the Gift Register may be used by the Reportable
Conduct Group or management for any purpose including in relation to accessing any aspect of an
Employee’s conduct or any complaint pursuant to the Code or the Anti‐Bribery and Corruption Policy.
The email address or other lodgment details for the Gift Register to be used by Employees of each
Operating Company are set out in Table 2.
Legitimate business purpose
Gifts or hospitality are for a legitimate business purpose if their primary objective is to build a good
business relationship consistent with the business plan of the relevant business unit.
A gift or hospitality is not for a legitimate business purpose if it might reasonably be considered to
impair objective judgement, improperly influence a decision or create a sense of obligation. The risk is
that the item could be perceived as a bribe, or lead to fraudulent or corrupt behaviour, as outlined in
the Anti‐Bribery and Corruption Policy.
Specific Gifts
Travel ‐ If there is a valid business reason for an Employee to attend an event or function, the Group
will pay (subject to appropriate Manager approval) for the travel and accommodation costs of its
Employees, rather than allow them to accept sponsored travel. Sponsored travel is unacceptable,
including if undertaken during a period of leave.
If clients or business partners are invited to travel to a CIMIC Group project (e.g. to conduct audits),
the Group may provide reasonable travel, accommodation and food during the required period with
appropriate prior approval in accordance with this Procedure (as set out above) and the Group Travel
Policy.
Facilitation payments are small payments of cash or in‐kind made to individuals, used to ‘facilitate’ a
routine government action and are often distinguished from a bribe. The Code prohibits facilitation
payments.
All Employees are expected to respond to any demand for a facilitation payment by stating that the
Code prohibits them from making any such payments. Further assistance can be obtained from the
Business Conduct Representative.
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Group Events/Hospitality ‐ Where the Group sponsors an event, or offers hospitality, it is the
responsibility of the Employee hosting the event to record and seek prior approval in accordance with
this Procedure, giving details of proposed guests.
Suppliers ‐ If an Employee wishes to engage a consultant, contractor or supplier to the Group
(collectively known as Suppliers) for a non‐business related purpose, that engagement will also need to
be recorded in the Gift Register.
Decisions by Managers
Where a Manager receives a request for approval, the Manager must consider the request, and use
their best endeavours to provide a decision within 24 hours, giving reasons for the decision.
Cumulative value
The cumulative value of gifts and hospitality offered or received over a period of time is a relevant
factor in considering whether there has been a breach of this Procedure. A series of gifts may be in
breach of this procedure even if each items value is below threshold, because when seen together
they create an impression of an inappropriate relationship, capable of unduly influencing business
decisions.
Exemptions
This Procedure does not apply to:
Token gifts, valued under AUD $100, such as pens, coffee mugs, project related souvenirs
Reasonable meals during business meetings as part of a work activity
Reasonable meals provided to an employee as a speaker or presenter at an industry function
Recognition items received in a business context, such as plaques, framed certificates, photographs,
or models
Gifts or vouchers to acknowledge outstanding performance or other employee recognition by
Group management up to a value of $50.
Declining a gift or hospitality
The Group does not expect individuals to be disrespectful to the persons making offers of a gift or
invitation. Employees should respectfully explain this Procedure to vendors, suppliers, partners and
contractors.
If an inappropriate or excessive gift or invitation is received the Employee must:
1. Decline and return the item with a tactful yet clear explanation that accepting the gift or invitation
is in breach of the Code and this Procedure
2. Notify the offer to the Gift Register, with commentary explaining the situation where appropriate.
If the person providing the gift requests that the item be donated to a charity of choice, the Employee
should contact their Business Conduct Representative.
At times, clients, suppliers, contractors and other business partners may express an interest in
entertainment that involves inappropriate content or excessive cost. This can bring the CIMIC Group
brand into disrepute. Employees are unable to participate if the conduct is in breach of the Code. If
this situation arises, the Employee must explain tactfully that the Group does not permit company time
or funds to be used for entertainment that is excessive in value, sexually explicit, or otherwise
inappropriate. The Employee should not try to solve the problem by offering to pay for it personally.
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Breach of this Procedure
The requirements set out in this Procedure are mandatory. A breach of this Procedure is a breach of
the Code. If an Employee is unsure whether an intended action infringes this Procedure, they should
contact their Manager or Business Conduct Representative.
Failure to properly record and seek prior approval where required will be treated seriously and may
lead to disciplinary action, including termination.
Procedure Information
Owner: Group General Counsel and Company Secretary, CIMIC
Approved by: Executive Chairman and Chief Executive Officer, CIMIC
Effective date: 25 September 2015
Note: CIMIC Group procedures may be amended from time to time.
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Table 1: Schedule of Amounts for Gifts and Hospitality
Item / Event Examples Amount AUD Requirement Obtain prior
(per person) to record approval
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Table 2: Gift Register
Operating Company Contact Details
CIMIC Group Limited GroupGiftRegister@cimic.com.au
Leighton Contractors compliance@leicon.com.au
Leighton Asia GiftsRegister@leightonasia.com
Thiess compliance@thiess.com.au
EIC Activities GroupGiftRegister@cimic.com.au
Pacific Partnerships GroupGiftRegister@cimic.com.au
Any other Operating Company GroupGiftRegister@cimic.com.au
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Gift Approval Form
Name of Requestor: (Must be person who is receiving or offering Gift / Hospitality)
Date of request (DD/MM/YY):
Division/Department:
Is this a Gift or Hospitality? Gift Hospitality
Estimated Value
The nature of the Gift or Hospitality
Who it is for / from
The reason it has been / is being given
Approval
What is the reason for seeking approval?
I, the Requestor, confirm that I have read and understood the Gifts and Hospitality Procedure and
the Gift or Hospitality above does not violate the Procedure.
Reviewed and Approved / Not approved:
Signature of Requestor Signature of Approver
Date Date
Please forward the Gifts Approval Form, showing the relevant approval to the Gift Register.
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