I Understand our Gifts and Entertainment Policies

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’s 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.

There are policies that address gifts given to Cisco employees.

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”).