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Code of Business Conduct

I Understand our Gifts and Entertainment Policies

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.

"It's Just a Mooncake..."

Video transcript

How do I distinguish between
the different types of gifts?

“Gifts and entertainment” means anything of value. Any gift or entertainment that is given in the course of his/her employment should:

  • Have no obligation or expectations (stated or implied)
  • Be made openly
  • Have reasonable value (conforming to Cisco’s policies for gifts & entertainment, global expenses and travel expenses)
  • Conform to the recipient’s rules
  • Be appropriate, legal and accurately documented (complies with applicable laws and policies)

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.)

  • Commercial Companies

    The exchange of gifts and entertainment between commercial company business partners and Cisco employees (or their family members) falls into three categories.

    Generally Acceptable* (requires no pre-approval)

    • Nominal gifts with a combined market value of US $100 or less, to or from a single source (entity) per year
    • Occasional business meals should follow the Global Expense Policy
    • Occasional business entertainment valued at less than US $200, per source, per year

    *Marketing programs, promotions or Cisco-sponsored events may be subject to other guidelines.

    Inappropriate (wrong in fact or appearance; never permissible)

    • Offer, accept or request:
      • anything that is illegal, unsavory, offensive, or would embarrass Cisco
      • cash or a cash equivalient
      • something as part of an agreement to do anything in return (quid pro quo)
    • Using your own money or resources for gifts or entertainment above the dollar limit for a customer, vendor or supplier

    Questionable (additional approvals are required)

    • Gifts or entertainment that exceed the dollar limits
    • Anything that is not clearly acceptable or inappropriate
    • Gifts or entertainment in connection with a tender or competitive bidding process
  • Government Employees and Agencies

    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.

    U.S. Governments

    Before offering any gift or entertainment to a U.S. federal, state, or local government employee, carefully review Cisco’s U.S. Public Sector Ethics Code and gift/hospitality policy limits.

    Note: The law bans all gifts to U.S. Congress and Staff and US government employees, including payment for meals.

    Governments Outside the U.S.

    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‚Äôs policy regarding global anti-corruption, addressed in the “I Follow the Law” section of the COBC.

    Cisco-Sponsored Meetings/Events with Any Government Contact

    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.

  • Workforce

    Refer to the Recognition Policy for the rules that apply when the company provides gifts or recognition awards to employees.

    Company Gifts to Employees

    There are policies that address giving gifts internally to Cisco employees.

    Gifts to Contingent Workers (contractors & temporary employees)

    Gifts to contractors or temporary employees are not reimbursable through Cisco's reimbursement tools.

    Employee-to-Employee Personal Gifts

    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.

  • Raffles

    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.

  • Other Considerations

    Third-party offers for Cisco employee travel

    Employees must adhere to the Employee Travel Policy before accepting offers by third parties to pay for Cisco employees' travel.

    Cisco Donations to Charities

    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.

    Local Gift-Giving Customs (country or culture-based)

    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”).

  • What if...

    What If...

    As part of my Cisco job, I work with a local government official. Since it's the holiday season, can I give him a fruit basket?

    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 legalcompliance@cisco.com

    What if a supplier offers me two great tickets to a rugby match? May I accept them?

    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.

    What if I have been offered a discount on a product sold by a Cisco supplier?

    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.

    An outside organization offered to pay for my travel to an event they are hosting. May I accept it?

    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.

    Have another question? Post it on the Ethics Discussion Forum or contact the Ethics Office for assistance.

  • Tools / Resources
  • Ask / Report

    Ask / Report

    E-mail

    Online

    Phone

    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.

    Regular Mail

    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