Spectrum Ethics

Gifts, Favors & Gratuities

Gifts, Favors and Gratuities may be offered with the best of intentions, but do not consider unfair or preferential treatment. A good tip is to think, “If this was publically announced, would it be embarrassing to the Company or recipient?”

Prohibited:

Gifts and/or meals intended to garner favoritism, obligation or inhibit fair treatment (internally and externally).

Gifts and/or meals provided to or received from military/government representatives with the intent, or perceived intent to gain an unfair advantage.

Permitted:

Contractor employees from the same and/or different companies may voluntarily pool their resources to provide a separate group gift (not exceeding $20) to a Government employee.

Spectrum employees may receive from or participate in contractor gift giving to military/government personnel, but not to exceed $20 per gift or a total of $50 per year to an individual.

Key Topics - Conflicts of Interest Gifts, Favors & Gratuities Sponsorships & Fundraising Political Activities Misrepresentation of Position

What is “anything of value”?

A: Corruption may involve the exchange of “anything of value.” “Anything of value” is very broad and could include goods, services or merchandise, such as gift cards, event tickets, retail certificates, entertainment, travel perks, use of vacation homes, free airfare or accommodations, special favors or privileges, donations to designated charities, discounts, free personal services, financial or property loans, co-signing of a loan or mortgage, or a promise of future employment.

Who is categorized as a “government representative” when it comes to gifts & gratuities?

A: “Government representatives” may include:

Government employees of environmental, licensing, tax and custom agencies, commissions or departments

Representatives of public international organizations, such as the World Bank

Mayors or other local city officials who issue permits

Members of law enforcement, including the military, local police and other enforcement agencies

Purchasing managers of government-run airlines, universities, school systems or hospitals

Employees of companies that are owned by the government

Employees of public international charities such as UNICEF