CONFLICTS OF OF INTEREST
ourselves , a close relative or associate of gifts and entertainment designed to influence the recipient ’ s judgment is not tolerated at Williams . When interacting with business associates , we must be careful when offering , giving , or receiving gifts , providing meals or entertainment , and paying for travel . There is no substitute for good judgment and if we are concerned about any particular situation , we should err on the side of caution ( See “ Conflict of Interest Policy .” See also , Gifts to Government and Regulatory Officials and Employees discussion above ).
Gifts
A gift is any item of value given to or received from someone who is not an employee of Williams . Examples of a gift include gift baskets , tickets to sporting events , or prizes in a vendor drawing .
Certain types of gifts , because of their nominal value and nature , are within the limits of reasonableness and can be offered and accepted , without prior authorization . These gifts include items with a company logo such as pens , shirts , or golf balls or a modest holiday gift like a gift basket .
Do not accept gifts if it is given in exchange for some action . Do not accept gifts of cash or a cash equivalent , like a gift card or gift certificate . Giving or receiving gifts of greater than nominal value may be considered inappropriate and you should discuss the appropriateness of such a gift with your supervisor or the Business Ethics Resource Center before accepting or giving the gift .
Entertainment
Entertainment is a hosted social event outside of the workplace where a representative giving and receiving are both in attendance . If the party providing the meal , ticket or entertainment is not in attendance , it is no longer considered entertainment and it is a gift .
Providing or accepting entertainment may be allowed provided :
� The purpose is to hold bona fide business discussions or foster better business relations ;
� It is not illegal or in violation of either party ’ s ethical guidelines ;
� It is of reasonable value and would be paid under normal expense account procedures ;
� Unsolicited ;
� It is not provided or accepted on a repeated basis ; �
It would not cause , or be perceived to cause , influence on the recipient ’ s business judgement concerning any transaction with Williams
� It would not be an embarrassment to Williams or the employee if publicly disclosed .
There may be a justified business purpose for us to provide business travel to a third party or receive business travel from a third party . If you receive an offer of paid travel or a premium type of event , first , talk to your manager . Together , you can determine if there is a good business reason to attend and if so , what travel or other expenses should be paid for by Williams . Written VPlevel approval is required before offering or accepting this type of travel , lodging or entertainment .
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