Page 20 - Code-Of-Conduct

11. ANTI-CORRUPTION;
GIFTS AND ENTERTAINMENT
Freudenberg is honest and transpar- ent in dealings with others, obeying all applicable laws and corresponding regulations. The use of fraud, bribery, kickbacks or other corrupt practices in conducting Freudenberg business is strictly prohibited.
No associate or anyone else acting on behalf of the company, directly or in- directly, may offer any payment or gift to, or improperly influence, any govern- ment official or officials working for in- ternational institutions. Freudenberg associates may not provide or authorize any funds to any intermediary when any of those funds may be used for cor- rupt payments to government officials or similar officials of institutions.
Invitations to meals as recipient or as an offer to others in a business relation- ship may, depending on applicable laws and customs, be considered legal and usual in the course of business. How- ever, the exchange of excessive or in- appropriate gifts and entertainment is unethical, may be illegal, and may se- verely injure your personal business reputation and that of Freudenberg. Freudenberg provides the following guidelines to allow employees to ex-
change inexpensive gifts or entertain- ment with commercial customers, sup- pliers, both actual and potential:
• A gift must be of nominal value (check amount with Regional Compliance or Ethics Office), e.g., annual present of Freudenberg wine or calendar is prin- cipally acceptable.
• A gift cannot consist of money or its equivalents (e.g. voucher).
• The gift, meal or entertainment is part of a legitimate business relation- ship or celebration.
• The gift, meal or entertainment does not influence, or could not reasonably be construed as influencing, either party in the fulfilment of their res- ponsibilities.
• The exchange of the gift, meal or entertainment does not break any law or violate any generally accepted ethical standard.
• The exchange of the gift, meal or entertainment should be no cause of concern or embarrassment to the company.
If in any doubt, consult your supervisor, the Ethics or Compliance Office or Cor- porate Legal. The restrictions outlined above apply equally to gifts, meals or
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