Group Gifts & Hospitality Policy

DO’S & DON’TS

In order to protect you and Ingenico, these DO’s and DONT’s provide you with practical guidelines to help you determine which gifts and hospitalities you are allowed to receive or offer.

ACCEPTABLE GIFTS AND HOSPITALITY SOME GIFTS AND HOSPITALITIES ARE

(EXAMPLES) ALWAYS PROHIBITED
WHERE INFLUENCING GIFT OR HOSPITALITY TO
Gifts of nominal value bearing DECISION MAKING GOVERNMENT OFFICIALS
the company logo CASH OR CASH EQUIPEMENT
Examples : EQUIVALENT (TVs, personal computers,
Mug, pencil, (gift cards, loans, stocks, …) iPads…)
goodies, stress-ball
WHEN PERCEIVED AS HIDDEN COMMISSIONS,
GENERALLY UNETHICAL KICKBACKS,
Perishable goods of (strip club visits) or other forms of rewards
low value
PRIVATE USE OF VEHICLE, VALUABLE INFORMATION
Examples : BOAT, HOLIDAY HOME (sensitive or confidential
Chocolates, beverages of (or similar ; paid holiday information)
reasonable value, fruits, pastries. trip or entertainments)
WHEN GRANTED DURING
COMMERCIALLY TENDER OR CONTRACTUAL
Business lunch of reasonable NEGOTIATIONS; or linked
UNJUSTIFIED FEES OR
value where both parties are PERSONAL DISCOUNTS to the acquisition of any
present (tuition fees, repair, license, authorisation, permit,
preferential treatments, contract
employment position,..)

Having a doubt about giving or receiving a gift or hospitality ?

The Group Gifts and Hospitality Policy sets out the rules applicable to gifts and hospitability.
The following questions can also help you determine what is acceptable: What should I do as an Ingenico employee and when ?
• Is the gift or hospitality authorised by laws, regulations and local rules? Any prohibited gift/hospitability must be refused. Please discuss
→ Am I sure that the gift or hospitality is legal? any practical issues with your manager.
• Does the gift and hospitality respect local culture and customs of the country/company, including in terms When you receive or intend to give an acceptable
of value? Is it reasonable ? Would your decision-making remain objective?
gift/hospitability of a value exceeding 50€*, you should :
→ Is the gift or hospitality unusual in my business and country? Is it of an unusual value in light of the
recipient's standard of living? Does it seem reasonable? • Obtain your manager’s prior approval on this gift/hospitality;
• and record the gift/hospitality by completing the online
• Could the gift or hospitality be reported in the news without affecting yours or Ingenico’s reputation? declaration form available on Skyway for your entity.
→ If the gift or hospitality were to become public, would that likely cause any embarrassment to Ingenico or
myself? * This policy may be supplemented by specific local internal
rules, particularly with regard to the applicable value thresholds.
• Did your manager agree to it ?
Please refer to any applicable local internal guidelines and to your
➢ If your response is no to any of these questions in bold, then the gift or hospitality is not authorised. local Compliance, Legal or HR business partners.
➢ If you are still uncertain, please refer to Ingenico Group Gifts and Hospitability Policy and your manager.

For more information, please refer to Ingenico Group Gifts and Hospitality Policy