Enom 2010 Annual Report Download - page 193

GIFTS AND ENTERTAINMENT
The giving and receiving of gifts is a common business practice. Appropriate business gifts and entertainment are welcome
courtesies designed to build relationships and understanding among business partners. Gifts and entertainment, however, should not
compromise, or appear to compromise, your ability to make objective and fair business decisions. In no event may any gift in the form
of marketable securities, cash or cash equivalents (such as Visa gift cards) be accepted or offered (other than in customary
circumstances, such as weddings or funerals).
It is your responsibility to use good judgment in this area. As a general rule, you may give or receive gifts or entertainment
to or from customers or suppliers only to the extent that they comport with reasonable and customary business practices. Gifts or
entertainment will be considered to comport with reasonable and customary business practices if: (a) it is of a type that is customary,
considering the job duties, job title, and seniority of the person to whom the gift is offered, and (b) accepting the gift or entertainment
serves primarily to enhance the business relationship with the provider of the gift or entertainment.
All gifts and entertainment expenses should be properly accounted for on expense reports. The following specific examples
may be helpful:
• Meals and Entertainment. You may occasionally accept or give meals, refreshments or other entertainment if:
• The items are of reasonable value; and
• A primary purpose of the meeting or attendance at the event is business related.
Entertainment of reasonable value may include food and tickets for sporting and cultural events.
• Advertising and Promotional Materials. You may occasionally accept or give advertising or promotional materials of
reasonable value.
• Personal Gifts. You may accept or give personal gifts of reasonable value (not to exceed $200 in face value in a calendar
year to or from the same organization) that are related to recognized special occasions such as a graduation, promotion, new
job, wedding, retirement or holiday. A gift is also acceptable if it is based on a family or personal relationship and unrelated
to the business involved between the individuals.
• Gifts Rewarding Service or Accomplishment. You may accept a gift from a civic, charitable or religious organization
specifically related to your service or accomplishment.
If you conduct business in other countries, you must be particularly careful that gifts and entertainment are not construed as
bribes, kickbacks or other improper payments. See "The Foreign Corrupt Practices Act and Other Laws Governing Our Business
Internationally" for a
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