The exchange of small gifts and modest business courtesies between business partners is a common and often a positive part of doing business. This practice, however, can sometimes create conflicts of interest or the appearance of wrongdoing. At Bridgestone, we cannot allow the exchange of gifts and entertainment to influence or appear to influence our independent business judgment or the independent business judgment of the companies with which we do business.Some gifts and forms of entertainment might be acceptable, but require special review and approval. Seek guidance and written approval from your supervisor:• If you are exchanging gifts or entertainment with the same person or company on multiple occasions.• When your location’s policy requires supervisor approval for certain gifts.In addition to these basic principles, be sure to review the gift and entertainment policy for your location closely to understand the specific rules that apply to you. For example, although cash and cash equivalents are generally not acceptable, there may be rare circumstances in which local policy expressly allows for very limited exceptions to this. Be proactive. Regularly inform suppliers, customers and other companies with whom we do business about our policy on gifts and entertainment. An especially good time to do this is several weeks before the holidays or periods in which it is customary to give gifts. You can, seek guidance from your supervisor, a member of the Law Department, Human Resources or Internal Audit.And remember, other companies have gifts and entertainment policies, too. Be mindful of these policies and ask before offering gifts and entertainment.42BRIDGESTONE INTEGRITY IN OUR DAILY WORK LIVESBridgestone employees are prohibited from giving or accepting gifts or entertainment that are:• Illegal.• Offered in exchange for something in return.• Sexually oriented or otherwise inappropriate.• Offered to a government official without the prior written approval of the Law Department.• In violation of any more restrictive policy in effect in your department or at your location.The following are examples of gifts that are usually acceptable:• A box of chocolates or fruit basket during the holidays.• A reasonable business meal at a local restaurant.• Promotional items of small value such as coffee mugs, pens or golf shirts with company logos.• Occasional attendance at a regular season sporting event or similar entertainment event where the price per ticket is not excessive, as determined by the policy for your location.Gifts and EntertainmentNEVER ACCEPTABLEUSUALLY ACCEPTABLE
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