This section of the Policy refers to 4 areas:
- Gifts and hospitality;
- Facilitation payments and Kickbacks;
- Political contributions; and
- Charitable contributions.
Gifts and Hospitality
Suntera accepts that normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:
- It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits;
- It is not made with the suggestion that a return favour is expected;
- It is in compliance with local law;
- It is given in the name of Amber, not in an individual staff member’s name;
- It does not include cash or a cash equivalent (e.g. a voucher or gift certificate);
- It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to Amber for helping with a large project upon completion);
- It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift;
- It is given/received openly, not secretly;
- It is not selectively given to a key, influential person, clearly with the intention of directly influencing them; or
- It is not above a certain excessive value, as pre-determined by us (usually in excess of GBP£50.00).
We shall not offer to, or accept gifts from a government official or representative or politician or political party, without the prior approval of Amber's Directors.
Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is done in accordance with Amber’s procedures.
We recognise that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
Before declining or accepting any gift, we shall carefully consider the intention behind a gift being given or received.
Facilitation Payments and Kickbacks
We do not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
We do not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
We will not make any donations, whether in cash, kind, or by any other means, to support any political parties or candidates because we recognise this may be perceived as an attempt to gain an improper business advantage.
We accept (and indeed encourage) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise).
We shall ensure that all charitable donations made by Amber are legal and ethical under local laws and practices.