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Cisco 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

What are appropriate ways of offering gifts:

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

Any exceptions to the gift offerings, where cost exceeds the threshold limits set in the GTE Policy must be pre-approved through the GTE Disclosure tool, where these disclosures are routed automatically to your immediate manager, the director of your organization and Vice President (if the cost exceeds U.S. $5000). and Global Compliance Teams for approval.

Before giving or receiving any gift, travel, meal, hospitality or any other item or service of value, you must review the Gifts and Entertainment policies for receiving or offering and when required, disclose using the following tools:

In addition, Cisco employees may never:

  • Offer, accept or request:
    • Anything that is illegal, unsavory, offensive, or would embarrass Cisco
    • Cash or a cash equivalent or, gift certificates and vouchers
    • Something as part of an agreement to do anything in return (quid pro quo)
  • Use your own money or resources for gifts or entertainment above the dollar limit for a customer, vendor or supplier
  • 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 Global Compliance Team (corporate_compliance@cisco.com).

    United States 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). Refer to Gifts Travel and Entertainment Policy for Offering Expenses before offering anything of value to a Non-U.S. government employee.

    Cisco-Sponsored Meetings/Events with Any Government Contact

    You must use the Gifts, Travel and Entertainment (GTE) Disclosure Tool 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

    Company Gifts to Employees

    Refer to the Recognition Policy for the rules that apply when the company provides gifts or recognition awards to 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 Global Employee Travel Policy before accepting offers by third parties to pay for Cisco employees' travel.

    Cisco Donations to Charities

    Corporate donations to a government or government-affiliated 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 Ifs - G&E

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

    It depends on the situation. Please contact Cisco’s Global Compliance Team by sending an email to corporate_compliance@cisco.com. If government officials or employees of government-owned/controlled entities (such as telecommunications, public universities, and hospitals) are involved, the anti-corruption laws around the world and Cisco policies are stricter in prohibiting gifts to prevent bribery or even the appearance of bribery. For more information, review Cisco’s Global "Anti-Corruption and Bribery Policy" or "Gifts, Travel and Entertainment Policy for offering business expenses" or U.S. Public Sector Guidelines or contact corporate_compliance@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 Global Employee Travel Policy for specific guidance.

    Have another question, contact the Global Compliance team by sending an email to corporate_compliance@cisco.com.

  • 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