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This Policy covers gift and entertainment exchanges between Euro Pool Group and third parties (e.g. business partners, customers, suppliers, etc.). When gifts or entertainment are excessive, it can bring unnecessary risks to our business, it can create a conflict of interest or the appearance of bribery. You should always exercise common sense when providing or accepting gifts and entertainment.
At Euro Pool Group we should act restrictive in accepting or providing invitations for entertainment or gifts and only use gifts and entertainment to develop or strengthen business relations, to show appreciation or to create goodwill when appropriate. The proposed gift or entertainment should be appropriate in value and nature considering local customs, the position of the recipient and the circumstances. As a guideline, gifts or entertainment below €50 in value are generally acceptable.
Always keep in the back of your mind that the object of any gift or entertainment, however small, should never be to influence any decision or oblige the recipient to perform something in return.
Cash or cash equivalent (e.g. gift cards or gift certificates) as a gift is never acceptable.
Please note that more and more companies do not allow their employees to accept any gifts or entertainment offered. To avoid embarrassment or worse, please check if any restrictions on accepting gifts or entertainment apply to the relevant business relation before offering any, by checking their website and/or the agreement in place.
For more guidelines, please check out the Anti-bribery page made available on the internal Compliance site.
In relation to government officials, we are even more careful. Therefore, at Euro Pool Group, we should not offer or promise any gift or entertainment to any government official, directly or via a third party, to influence such official’s actions or to obtain improper advantage (e.g. offer tickets or any gift to a customs officer to pass through customs quicker or without fulfilling certain required formalities).
Euro Pool Group can face various issues if we fail to prevent bribery within the company, such as reputational damage, fines, exclusion from public contracts and other serious legal consequences. Employees that do not follow the guidelines of this Policy may be subject to disciplinary action.
To ensure compliance with this Policy and to avoid fines or other reputational damages for Euro Pool Group, please consult with your manager or the Compliance Officer before providing or accepting any gifts or entertainment or reach out to the Legal Department in case of any questions. To avoid any issues, we urge all entities within Euro Pool Group to maintain and update the register of all the gifts and entertainment offered and received, including dates and the reason for providing or accepting the gift or entertainment, on the internal Compliance site.
If you suspect or witness any non-compliance with this Policy, please don’t sit still but take appropriate action using the channels made available by Euro Pool Group on the internal Compliance site.
Join Euro Pool Group on our circular journey – get in touch now.