code-of-conduct-final-EN-PL-4

BUSINESS INTEGRITY | 9

Gifts or entertainment being offered to a government employee or government official are strictly prohibited.

Accepting or offering gifts or entertainment is generally discouraged and is permissible only in rare circumstances, when they are:

a)

Nominal in value (e.g.; less than $50)

b)

Not prohibited under contract or by applicable laws or regulations

c)

Infrequent, in good taste and unsolicited

d)

Not cash or a cash equivalent (e.g.; gift cards)

e) Special occasions when gifting is customary and to do otherwise may be deemed inappropriate (e.g.; retirement or Chinese New Year) f) Approved by EXP’s Chief Financial Officer The “gift and entertainment” policy of the employer of a potential recipient must be reviewed by the Legal Depart- ment to determine whether the gift or entertainment is appropriate, or may be accepted, prior to any offer of a gift or entertainment. When employees are offered gifts or entertainment that does not fit these guidelines, the employee should decline politely, citing EXP’s Code. If in good faith you believe that declining an offer may not be in EXP’s best interest, you must get written permission from EXP’s Chief Operating Officer before accepting it.