We exchange gifts and entertainment responsibly

Our shared responsibility

We exchange gifts and entertain in ways that are transparent, appropriate, in accordance with local rules, and lawful. We never give or accept anything that could influence a business decision — or create the appearance of doing so.

Why it matters

Gifts and entertainment can help build strong business relationships. But if they are inappropriate, too frequent, or poorly timed, they can damage trust and create legal and reputational risk. In our industry — especially when we work with government customers — even the appearance of improper influence can harm Omterra. We protect our company and each other by using good judgment and acting with transparency.

How we energize with integrity

We exchange gifts and entertain responsibly by:

  • Giving and accepting only modest, reasonable, and appropriate gifts or hospitality.
  • Not offering or giving gifts of cash or cash-like items.
  • Never making an offer or accepting anything to influence a decision or gain an unfair advantage.
  • Using extra care when dealing with government and public officials. Even small courtesies may not be allowed.
  • Following all approval, disclosure, and documentation rules.
  • Recording gifts and entertainment accurately in our books and records.

Spark your understanding

Gift or hospitality:

Anything of value offered or received. This includes meals, travel, entertainment, tickets, discounts, services, or other courtesies.

Anyone who works for or represents a governmental legislative or judicial body, a state-owned or state-controlled company, a public international organization, or a political party. This also includes candidates for public office and other people treated as public officials under the law.

Make it current

Question: I want to invite my biggest customer to dinner at a high-end restaurant. How much can I spend without prior approval? Is there a threshold?

Answer: There is no specific threshold under which gifts or entertainment are automatically allowed. Think about the timing, value, and circumstances, including the position of the participants. If the invitation influences or appears to influence an important business decision, do not offer it. When in doubt, speak with Compliance.

Power sources

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