What is a Gift?
Except as specifically set forth below, a “Gift” is anything of value that is given to or received from any person or organization with which any Haynes entity does business or is actively considering doing business (e.g., vendors, consultants, customers) or with which any Haynes entity competes, or any person employed by any such organization, or that otherwise directly or indirectly relates to a person’s employment with any Haynes entity, whether or not to or from any of such entities or persons. Gifts include—but are not limited to—gifts; meals; lodging; loans; cash; gratuity; favors; entertainment; fees; commission; favorable terms or discounts on any personal product or service; personal services; equipment; prizes; products; transportation; use of vehicles, vacation or other facilities; stocks or other securities; home improvements; tickets; gift certificates; gift cards; discount cards; memberships; employment or consulting relationships or services; or any other form of compensation or benefit. Notwithstanding any other statement in this policy, a “Gift” shall not include any event (including, without limitation, sporting events, meals and related transportation) attended with representatives of a customer, supplier or other business partner of Haynes as a part of the normal course of Haynes’ business.
A Gift is considered given or received by a Haynes employee if the Gift is given or received by any of the following:
- The employee;
- Any family member or relative of the employee, including, but not limited to, payments to or by, or employment of, any such family member or relative; or
- Any other person or entity at the employee’s direction or for the employee’s benefit
If you are at all uncertain whether or not something is a Gift, you must assume that it is a Gift and is subject to this Gift Policy (e.g., if a vendor or potential vendor who is also a personal friend gives you a birthday present). It is important to avoid even the appearance of impropriety. Consequently, every transaction with an active or potential vendor, competitor, consultant, business partner or customer of any Haynes entity should be considered and evaluated as a Gift even if you believe the transaction involves fair and full consideration between the parties (e.g., if a vendor provides employment to a family member or relative or if an employee buys or sells a car, product or services from or to a Haynes business partner
or its employees).
The following guidelines are intended to assist employees and supervisors in evaluating and determining the appropriateness of various types of Gifts (whether given or received):
Appropriate Gifts: Using good judgment and moderation, occasionally receiving from or offering to employees of a nongovernmental entity Gifts or entertainment of moderate, reasonable value is appropriate and can create goodwill and enhance business relationships, provided the applicable requirements specified in this Gift Policy are complied with.
Inappropriate Gifts: Other types of favors, Gifts and entertainment are simply wrong and unacceptable, either in fact or in appearance, so that they are never permissible regardless of any other provision of this Gift Policy. No one can accept, request, offer, give or approve the following types of Gifts in connection with work at Haynes:
- Any amount of cash or cash equivalents, including, but not limited to, gift certificates, gift cards or discount cards (even if only redeemable for merchandise), stock or other securities;
- Favors, Gifts, or entertainment that would be illegal or violate any law, regulation or any Haynes policy, including, but not limited to, bribes, kickbacks or the like;
- Anything as part of an agreement to do anything in return for favors, Gifts or entertainment.
The foregoing definition of Inappropriate Gifts shall not include gift cards, merchandise, etc. donated by Haynes’ customers, suppliers or other business partners to or through Haynes on behalf of a charitable organization in connection with a charitable event and without intent of benefitting any specific individual associated with Haynes.