Gift Policy

 

General Rules

• We do not offer, accept, or solicit gifts or hospitality if they are intended, or appear to be intended, as an obligation or a bribe.

• We do not offer, promise, pay, or authorize payments, directly or indirectly, to influence the decisions of any government official, authority, or any other third party.

• We do not offer, accept, or solicit gifts or hospitality in exchange for granting an advantage or ignoring a procedure, in favor of or against a third party.

• We do not offer, accept, or solicit gifts or hospitality when a decision is pending or when it may affect the judgment of a third party.

• Under no circumstances do we accept cash or its equivalent.

• Before accepting gifts and hospitality, we verify that they are reasonable in cost, frequency, and quantity.

• We reject all gifts or hospitality that do not comply with the parameters established herein.

Rules for Receiving Gifts and Hospitality

We may offer or accept gifts and hospitality in connection with our work, provided they comply with the following rules:

• In the case of hospitality:

  • We always attend with the third party (the host must be present).

  • We verify that the costs involved are reasonable for this type of event.

  • If it involves travel, whether within or outside the place of residence, we request prior express and written authorization from our management.

  • We only accept hospitality that does not involve activities, products, or locations that could embarrass or be considered in bad taste by the recipient.

• In the case of gifts:

  • We only accept corporate promotional gifts, gifts of symbolic value, and in any case, gifts whose value, based on a reasonable assessment, is estimated to be equal to or less than €100.

  • We do not accept gifts that could be considered in bad taste or that violate the ethical principles of the company.

Rules for Giving Gifts and Hospitality

• We always respect our level of authority regarding invitations or the giving of gifts to third parties.

• The gifts and invitations we offer must have a reasonable cost, according to our best judgment.

• We always respect the gift and hospitality policies of the third parties to whom they are directed.

Doubts or Inapplicability

• In case of doubt regarding the viability of receiving or offering gifts or hospitality, or if it is not possible to apply the established parameters, we must immediately report the concern to Management for resolution.

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