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 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:
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 (email@example.com).
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). Refer to Gifts Travel and Entertainment Policy for Offering Expenses before offering anything of value to a Non-U.S. government employee.
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.
Refer to the Recognition Policy for the rules that apply when the company provides gifts or recognition awards to 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 Global Employee Travel Policy before accepting offers by third parties to pay for Cisco employees' travel.
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.
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”).
It depends on the situation. Please contact Cisco’s Global Compliance Team by sending an email to firstname.lastname@example.org. 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 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 Global Employee Travel Policy for specific guidance.
Have another question, contact the Global Compliance team by sending an email to firstname.lastname@example.org.
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