Integrity

Giving and Receiving Gifts and Entertainment Responsibly

Our Commitment

We are fair and objective in our relationships with third parties. That means we must always exchange gifts and entertainment responsibly and in moderation.

Why It Matters

We are all expected to conduct business fairly and honestly. We must be very careful when exchanging gifts with customers, vendors, suppliers or government officials. Offering a gift could be seen as an attempt to influence a business decision. It might even be in violation of the recipient’s policies. Also, accepting a gift may make us become or seem less objective.

This doesn’t mean we can’t express gratitude to customers and suppliers. To build comradery with third parties, we can offer gifts and entertainment within acceptable limits, as outlined in HARMAN policies.

How We Give and Receive Gifts Responsibly

  • Give gifts and entertainment within the acceptable limits outlined in HARMAN policies.
  • Only offer or accept gifts or entertainment if they are in compliance with law, nominal in value and consistent with customary business practices.
  • Don’t offer or accept significant gifts or entertainment.
  • Never offer or accept a gift of cash from a third party.
  • Promptly report and secure approval for expenses.
  • Document expenses for gifts and entertainment through the Travel and Expense (T&E) system. If your expense does not comply with policy, HARMAN may not reimburse you.
  • Disclose, as necessary any gifts or entertainment given or received using the Gifts and Entertainment Disclosure Tool.
  • Use good judgment, refer to the applicable policies and Gifts and Entertainment Disclosure Tool, and ask your supervisor or the Legal & Compliance Department for help when deciding if it’s okay to accept or give a gift.

Making Connections: How Do I Know If a Gift Is “Nominal” or “Significant”?

You can determine if a gift is significant based on knowledge of local cultural norms and good judgment in context. Any gift, regardless of value, is significant if offered or received to “smooth the way” or further a deal. Contact your supervisor or the Legal & Compliance Department if you are ever in doubt.

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