NNPC Limited Code of Conduct: Gifts and Entertainment PDF

NNPC Limited Code of Conduct 6 Gifts and Entertainment NNPC Limited strictly forbids employees from soliciting gifts or hospitality. As a general principle, we discourage employees from accepting gifts or hospitality from business partners and their representatives. Notwithstanding this, NNPC Limit...

NNPC Limited Code of Conduct 6 Gifts and Entertainment NNPC Limited strictly forbids employees from soliciting gifts or hospitality. As a general principle, we discourage employees from accepting gifts or hospitality from business partners and their representatives. Notwithstanding this, NNPC Limited recognises that the occasional acceptance or offer of modest gifts and hospitality may be a legitimate contribution to good business relationships. However, it is important that gifts or hospitality never influence business decision-making processes, or cause others to perceive an influence. NNPC Limited requires employees to abide by these rules of behaviour not only to protect our reputation, but also to protect themselves against unfounded allegations of improper behaviour. 6.1 What Should you Consider? It is recognised that there are times when refusing to accept gifts or hospitality from a business partner or declining to provide them would be considered discourteous. NNPC Limited’s employees should consider the following questions before accepting or offering a gift or hospitality: a) Could my acceptance or offer lead to or imply an obligation? b) Is this gift or hospitality a “reward” for a business transaction? c) Is this gift or hospitality excessive in value? d) Is the frequency of the gift unusual? If the answer to any of these questions is yes, the gift or hospitality should not be offered or accepted. If you are not clear how to answer these questions, please contact the relevant regulatory and compliance unit. 6.2 Acceptable Gifts and Hospitality You may accept or give the following without prior approval: a) A gift (whether of one or more items) of a value not exceeding N100,000 or equivalent, including corporate gifts which feature the logo of the donor (diaries, calendars etc.) and gifts given during the festive season of the year, for example New Year, Christmas, Eid. b) Meals related to a business context of a value not exceeding N100,000 or equivalent per person. c) Occasional invitations to events, not exceeding N100,000 or equivalent in value per person and not extending over a period of more than one day. ’Occasional’ means not more than two or three times a year with the same business partner. 28 NNPC Limited Code of Conduct 6.2.2. Gifts and Hospitality Requiring Management Approval You may only accept or give the following with your line Manager’s approval: a) Gifts or hospitality with a value exceeding the above b) Events for periods exceeding the length, or occurring more frequently than the norms set out above c) Travel or accommodation 6.2.3. Special Occasions Special occasions, involving senior NNPC Limited’s executives and senior external parties, can be a justification for more valuable presents or entertainment, depending on generally accepted business protocol and with the approval of the Supervising Manager. Such gifts irrespective of value must be disclosed to the relevant regulatory and compliance unit. 6.2.4. Prohibited Gifts and Hospitality Employees should never accept or offer the following with or without approval: a) Cash or cash equivalents (example, gift vouchers) b) Personal services. c) Loans. d) Events or meals where the business partner is not present. e) Gifts or hospitality of an inappropriate nature or in inappropriate venues. f) Gifts or hospitality during periods when important business decisions are being made. 6.3 Selected Guidelines for Gifts & Entertainment a) Do not accept or offer gifts and hospitality exceeding the value of N100,000 b) Report any offer of gifts or hospitality of an inappropriate nature or in inappropriate venues (whether below or above N100,000) to the relevant regulatory and compliance unit. c) Declare and register all accepted gifts in the gift register, regardless of value or whether management approval is required. d) Offer gifts and hospitality only in compliance with applicable laws and regulations. 29 NNPC Limited Code of Conduct e) Be aware of the potential conflicts which may arise as a result of accepting gifts or hospitality. f) Understand local customs for the giving and receiving of gifts, entertainment, and benefits. g) Exercise good judgement in line with NNPC Limited’s core values when deciding what gifts are reasonable to give or accept. h) Recharge the costs of an NNPC Limited hospitality event to the relevant business budget to maintain business ownership. i) Do not accept gift vouchers irrespective of the monetary value as it is considered a cash equivalent. j) Do not be embarrassed to decline any offer. Referring to the NNPC Limited policy in cases when offers exceed the value allowed by the policy. This will be understood by the business counterparty who in most cases will be subject to similar rules. k) Ensure you do not give or receive gifts, hospitality, or favours that you would feel uncomfortable explaining to your work colleagues, your family or the media. l) You must not differentiate between giving and receiving of gifts and hospitality directly or via an intermediary. m) When in doubt, consult GRC for guidance. 7 Political Contributions NNPC Limited does not make donations (neither monetary nor otherwise) to political parties; organizations; causes or their representatives. Also, we will not direct our employees to exercise their constitutional right to vote in favour of any political party or political figure. 30