Gifts & Business Amenities

Accepting inappropriate gifts/amenities is a violation of...

• IBM's Business Conduct Guidelines

• US Foreign Corrupt Practices Act

• Local Anti-Corruption Law

• All of the above

IBM employees may give or receive gifts of nominal value with management approval. Nominal is defined as having a cost of $50 USD or less, including incidental costs such as engraving, packaging, insurance, and mailing. Management and CFO Delegate pre-approval is required if the gift to be provided is more than $50 USD per person.

Is this statement true or false?

• True

• False

Business amenities include things such as...

• Transport, hotel and lodging

• Meals and gift

• Entertainment and event entrance

• All of the above

IBM employees may provide or receive business meals if they are less than two times the IBM employee limits as described by IBM Travel Policy. Meals in excess of this amount per person require management pre-approval. Meals above ________ per person will require management and CFO Delegate pre-approval.

Fill in the blank

• $100

• $200

• $250

• $300

Fill in the blank.

Entertainment is limited to sporting and cultural events. IBM employees may provide or receive entertainment having a cost of no more than _________ per person.

This limit is for the cost of attending the event and does not include the cost of other amenities described in this instruction (such as meals or transportation that might be provided in conjunction with the entertainment, and which costs are subject to other restrictions in this instruction).

Management and CFO Delegate pre-approval is required if the value of the entertainment is more than ________ per person.

• $100 USD

• $200 USD

• $250 USD

• $300 USD

Fill in the blank

IBM employees may not give to or receive from an external party any cash, gift cards, gift certificates or any other cash equivalent. With prior review and approval being obtained from___________________, certain limited exceptions are permitted for offering gift cards of $25 USD or less

• CFO Delegate only

• Manager only

• CFO Delegate & Manager

• CFO Delegate and Trust & Compliance

In general, transportation, hotel and lodging for external parties should be paid by the external party and not IBM. However, you may provide or receive ground transportation that would be permitted under the IBM Travel Policy. For any airfare, hotel and lodging, management and CFO Delegate pre-approval is required when providing to or receiving from an external party.

Is this statement true or false?

• True

• False