At Cisco, we promote successful working relationships and goodwill with our business partners, who are vital to our success. As appropriate, I may consider offering or accepting a gift or entertainment with a customer or business partner, but recognize I should be careful not to create a situation that would suggest a conflict of interest, divided loyalty, or the appearance of an improper attempt to influence business decisions.
“Gifts and entertainment” means anything of value. Any gift or entertainment that is given in the course of his/her employment should:
Any exceptions must be approved in writing by the Ethics Office, the vice president of your organization and HR Manager. (If you are a vice president or higher, you need to obtain permission from your next level management.)
The exchange of gifts and entertainment between commercial company business partners and Cisco employees (or their family members) falls into three categories.
*Marketing programs, promotions or Cisco-sponsored events may be subject to other guidelines.
Stricter rules and company policies apply when we interact with government entities and their employees or representatives. Nothing of value should ever be promised, offered or provided to a government employee, either directly or indirectly, in an attempt to influence the government employee to act or refrain from acting in connection with obtaining or retaining any business advantage. For help, contact Public Sector Compliance or Global Policy & Government Affairs.
Note: The law bans all gifts to U.S. Congress and Staff and US government employees, including payment for meals.
Different countries have laws restricting gifts to employees associated with governments (or government-controlled agencies). The Foreign Corrupt Practices Act (FCPA) covers gifts and facilitation payments outside of the U.S. Follow all laws and Cisco’s policy regarding global anti-corruption, addressed in the “I Follow the Law” section of the COBC.
You must use the Cisco Guest Travel and Event Tool (GTET) to obtain approvals before inviting any government guest when Cisco is to pay for any portion of the government guest's travel and/or hotel accommodations.
Refer to the Recognition Policy for the rules that apply when the company provides gifts or recognition awards to employees.
There are policies that address giving gifts internally to Cisco employees.
Gifts to contractors or temporary employees are not reimbursable through Cisco's reimbursement tools.
Gifts between employees are certainly allowed but should be done respectfully. Care should be taken with gifts between managers and their direct reports, or when a group of employees collects money for a group gift for an employee.
Participation in raffles and giveaways that are fair, nondiscriminatory, and conducted in a public forum are typically permitted unless the prize is worth more than US $500. Prizes worth more than the dollar limit can only be accepted with written approval from your manager and the Ethics Office.
Employees must adhere to the Employee Travel Policy before accepting offers by third parties to pay for Cisco employees' travel.
Corporate donations to a government entity, or corporate charitable donations to a non-profit / non-governmental entity must comply with Cisco's Government and Charitable Donations Policy.
In these situations, gifts may be accepted only on behalf of Cisco with the written approval of your department vice president and your HR manager. Any gifts received should be immediately given to HR or the Cisco Foundation. Note: Items received can be directly donated to a Cisco-approved nonprofit organization (listed on the Community Connection website)
In all cases, there can be no appearance of impropriety (see “I Follow the Law”).
No, unless you have permission from the Cisco Public Sector team. If government officials or employees of government-owned/controlled entities (such as telcos, public universities, and hospitals) are involved, the anticorruption laws around the world and Cisco policies are much stricter in prohibiting gifts to prevent bribery or even the appearance of bribery. For more information, review the Global Anti-Corruption Policy or contact email@example.com
It depends on the situation. What is the market value of the tickets? Will the supplier attend the game with you or are the tickets for you to use personally? Are you expected to reciprocate in any way? Refer to the Gifts and Entertainment Policy to determine if you may accept the tickets or if additional steps (such as a waiver) from Ethics Office are required.
You may accept the discount only if it is clearly available to all or many Cisco employees and approved by the company. A discount offered to you personally is inappropriate and accepting it is a violation of our policy.
It depends on: who is offering it, the reason for travel, and any risk of an actual or perceived conflict of interest. There are certain situations where it's permissible to accept reasonable travel and accommodations from a customer, partner, vendor or third party. Refer to the Employee Travel Policy for specific guidance.
The multi-lingual Cisco Ethics Line is available 24 hours a day, 7 days a week, worldwide, with country-based toll-free phone numbers. The Ethics Line is staffed by a leading third-party reporting service. You have the option to remain anonymous* when you call; however, the investigation may be hindered if the investigator is unable to contact you for further information.
*Please note: Some countries do not allow such concerns to be reported anonymously.
Questions and concerns regarding accounting, internal accounting controls, or auditing matters (or other related issues) can be submitted — confidentially or anonymously — to the Audit Committee of the Board of Directors. at the following private mailbox (PMB):
Cisco Systems, Audit Committee
105 Serra Way, PMB #112, Milpitas, CA 95035