Ethics Moments

Ethics Moment

PRESENTATION

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Agenda

INDEX

• Why are we here?
• Receiving Gifts and Entertainment: Overview
• Receiving Gifts and Entertainment: Hypothetical Scenario

• Discussion Questions
• Resources

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Why are we here?

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Today we will:

1. Discuss the ethical dilemmas and potential risks involved in accepting gifts or entertainment from third parties, particularly items or experiences of high value that can be reasonably seen as luxurious or lavish.
2. Get a refresher on the relevant policies and resources to help you assess offered gifts or entertainment and ensure that your decision to accept or approve is in line with our policies and values.
3. Reiterate the importance of speaking up if you have a question or want to raise a concern about something that doesn’t look quite right.

What else are we going to discuss?

Receiving Gifts and Entertainment: Overview

The giving and receiving of business gifts is a customary way to strengthen business relationships and, when done transparently and in line with our policies and values, is a lawful and acceptable business practice.

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Receiving Gifts and Entertainment: Overview

What do we need to keep in mind?

Gifts and entertainment should never, however, compromise or even appear to compromise your business judgment or the integrity of our business relationships. Consult the Code of Conduct, Gifts & Entertainment Policy, and Global Anti-Bribery & Corruption Policy, before accepting or approving gifts or entertainment. All gifts and entertainment must be approved by your manager before acceptance and meet the following standards:

What standards do you need to meet?

Be customary, nominal in value, and infrequent - items or experiences that have a high value or can be reasonably seen as luxurious or lavish are unlikely to meet this standard.

Not look like a bribe or kickback - they can’t be reasonably construed as payment or consideration for influencing a particular business decision or action.

Not be offered or given during contract negotiations - you can’t accept gifts or entertainment from a third party if you are directly or indirectly involved in contract negotiations with them or within three months before contract renewal.

Not be cash or cash equivalent - consult your Brand’s policies for more detail and limited exceptions (e.g., for gift cards of small value).

Receiving Gifts and Entertainment: Hypothetical Scenario

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Receiving Gifts and Entertainment: Hypothetical Scenario

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Let's hear your thoughts!

1. What is your reaction to this scenario?
2. What stands out the most to you?
3. Did the senior leader and account manager handle the invitation to attend the vendor-sponsored event in accordance with our policies and values?
4. What should they have done differently?
5. Should their decisions differbased on their different levels of seniority and authority?

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Let’s look at some of the specific items and experiences.

1. Did you have concerns about their acceptance of the USD 500 gift cards?
2. What about the personalized hoodies?
3. Does the entertainment provided (a helicopter ride sponsored by a local government tourism agency to the senior leader and dinner at a five-star restaurant to the account manager) meet our gifts and entertainment standards? Why or why not?

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Let’s look at some of the specific items and experiences.

1. What other factors should be considered when deciding whether to accept gifts or entertainment, especially those that are high in value or may be seen as luxurious or lavish?
2. How might accepting a gift or entertainment from a third party impact our business judgment or decisions Might you be more likely to continue working with them or less likely to consider other service providers? How might that conflict with the Company’s best interests?

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Takeaways

Gifts and entertainment should never compromise or appear to compromise your business judgment or the integrity of our business relationships.

Resources

The Right Results, The Right Way has full meaning when we apply it to our day-to-day job. If you need to ask a question or raise a concern, you can turn to: • Your manager • Another manager • Compliance • Legal • HR • The Helpline: www.BKNGhelpline.com

THANKS

Thank you for participating in this Ethics Moment session! We appreciate your commitment to the practice of ethical behavior in the workplace. To ensure we continue to provide engaging content, we ask that you take a moment to share your feedback with me in a brief survey.

When they arrived...

• Upon arrival at the event, both the senior leader and the account manager are given USD 500 gift cards and personalized hoodies as tokens of appreciation for their attendance and business.
• The vendor offers to take the senior leader on a private helicopter tour with other industry executives as an opportunity to network. At the end of the tour, the senior leader is handed a card from the local government tourism agency that sponsored the tour card from the local government tourism agency that sponsored the tour.

• The account manager is invited to and attend a dinner with the vendor’s junior team at a five-star restaurant.
• After the event, the vendor reiterates how much it values the relationship with the company and that it’s looking forward to discussing the renewal of its contract in the coming months. Both the senior leader and the account manager feel that their experiences at the conference have strengthened their relationship with the vendor and that the trip was valuable in building professional connections within the industry.

What's the situation?

What happened next?

• A senior leader and an account manager are invited by a current vendor to speak at a vendor-sponsored conference in a tropical location to commemorate the vendor’s 50th anniversary. The vendor is one of the company’s key service providers and the invitation to the event includes paid business-class travel, accommodations at a five-star venue, and exclusive dinners with industry leaders. Both employees accept the invitation.

• The senior leader has decision-making authority over the vendor’s contract. The account manager has been involved in managing day-to-day operations with the vendor but doesn’t have purchasing authority.