Gifts, Entertainment and Other Favors
Accepting or giving gifts, entertainment and other favors can also create a potential or actual conflict of interest.
The Code forbids excessive entertainment, travel or gifts of other then nominal value provided to, or by, companies doing business with ONE Gas. “Gifts, entertainment and other favors” means anything of value. Examples of these include, but are not limited to: meals, lodging, discounts, prizes, travel, tickets, stock or money in any form.
Accepting Gifts, Entertainment or Favors
In the course of your work for ONE Gas, you may be offered gifts, entertainment or other favors from customers, suppliers, vendors or other business contacts. Accepting such things usually makes us feel that we should do something in return. This could affect our ability to make objective business decisions in the best interest of ONE Gas.
In general, the only kinds of gifts and entertainment that you may accept from anyone who does or may do business with ONE Gas are:
- Infrequent gifts of nominal value, such as pens, calendars, or small promotional items related to business.
- Occasional reasonably priced meals with a business contact.
- Occasional attendance at sports, theater or other cultural events with a business contact.
Each of us must not:
- Accept anything if it will make you feel you should do, or promise to do, anything in return.
- Accept anything in return for giving someone ONE Gas business.
- Accept anything that does not have a business purpose.
- Accept travel or entertainment events which have an excessive value or involve numerous reasonably-priced instances (e.g., one reasonably-priced concert might be approved, however several concerts may be considered excessive).
If you receive anything that does not meet these guidelines, you should return it and explain that our policy does not allow you to keep it. If you are not sure whether the gift, entertainment or favor violates this policy, talk to your supervisor or the Chief Compliance Officer.
Gifts, Entertainment or Favors to Government Officials
No result sought by a ONE Gas employee, officer or board member ever justifies bribery. Providing or receiving an improper payment is a serious violation of the Code and in many cases the law.
It is illegal and a violation of this Code for any employee, officer or board member to offer, promise, or give, directly or indirectly, a gratuity or anything of value, regardless of amount, to induce or influence a business or government decision or to secure an improper advantage. Examples of payments that may be forbidden include cash, gifts, meals, entertainment, business opportunities, offers of employment, contributions to charitable organizations and more. These activities could be considered bribery or corruption.
Questions & Answers
A: It depends. Accepting lunch invitations is okay if you are meeting for a business purpose, but frequent or extravagant meals can appear to create a conflict of interest. Consult your supervisor if a vendor invites you to lunch on a frequent basis. Tell the vendor about our Code and keep lunch meetings with vendors to a reasonable limit.
A: No. If you tolerate your employee’s inappropriate behavior, you are giving the message that it is acceptable. Your employee should behave the same way at a business meeting as he or she would behave in the office. You should counsel the employee on appropriate business behavior.
A: No. Never accept items from ONE Gas vendors for personal use.