Giving and Receiving Gifts, Gratuities or Services Policy

Giving and Receiving Gifts, Gratuities or Services Policy

Policy.v2 Page 1 of 6

Contents 1.0 Purpose... 3 2.0 Definitions... 3 2.1 Gifts... 3 2.2 Gratuities... 3 2.3 Services... 3 2.4 People, Performance & Culture... 3 2.5 Recovre... 3 3.0 Receiving Gifts, Gratuities or Services... 3 3.1 Guidelines... 3 4.0 Giving Gifts, Gratuities or Services... 4 4.1 Guidelines... 4 5.0 Political and Charitable Contributions... 5 6.0 Consequences of Non Compliance... 5 7.0 Procedure... 5 8.0 Responsibilities... 5 8.1 Employee Responsibilities... 5 8.2 Manager Responsibilities... 5 8.3 People, Performance & Culture Responsibilities... 5 Who Do I Contact For Further Information?... 6 Related Documents... 6 Policy.v2 Page 2 of 6

1.0 Purpose To outline the circumstances in which gifts, gratuities or services can be given or received by Employees in a way that will not; Compromise the Employee s judgement; Compromise Recovre s position; Damage relationships with others; Indicate favouritism or prejudice towards a person or group of people. This policy applies to all Recovre Employees. 2.0 Definitions 2.1 Gifts Something that is bestowed voluntarily and without compensation. 2.2 Gratuities A favour or gift, usually in the form of money, given in return for service. 2.3 Services Undertaking work for another. 2.4 People, Performance & Culture Recovre s Human Resources Department. 2.5 Recovre The Recovre Group Pty Ltd, ACN 003 330 167 and Related Bodies Corporate. 3.0 Receiving Gifts, Gratuities or Services 3.1 Guidelines Employees should not accept personal gifts, gratuities, services or extraordinary hospitality, which may influence or appear to influence a purchasing decision, compromise their integrity, or cause them to act in a partial manner in the course of their duties. Gifts may include, but are not limited to, the following: Meals Refreshments Entertainment Loans Travel and accommodation Gifts and vouchers Cash Employees should access the nature and value of the gift, gratuity or service being offered. Employees must seek prior approval from the appropriate level of management and complete a Gift Declaration Form in the following situations: Policy.v2 Page 3 of 6

Where the gift, gratuity or service is not obviously a business supported or related initiative, (e.g. not branded and presented as a Recovre gift, gratuity or service) and is valued at A$500 or above; or Where it is clear that the gift, gratuity or service is an endorsed relationship building or promotional activity or item (e.g. company branded gifts, alcohol, theatre tickets, sporting events etc) and is valued at A$1000 or above. It is not permissible for Employees to accept any service, accommodation or travel of any value whatsoever, unless rendered in conjunction with the performance of Recovre s business. Tips are not to be charged to a corporate credit card and will not be reimbursed. In the event that a tip is charged to a corporate credit card, it will only be reimbursed if approved by the State Manager/Regional Manager or Executive Director. Employees (or members of their family) may not accept from an individual or company doing or seeking to do business with Recovre any loan, guarantee of loan, or payment (excluding loans from recognised banks and financial institutions that are generally available at market rates and terms). Any Employee who intends to accept gifts, gratuities or services, which may not fall within the boundaries of this policy, should complete a Gift Declaration Form and send it to People, Performance & Culture. 4.0 Giving Gifts, Gratuities or Services 4.1 Guidelines Recovre recognises that it is accepted business practice that entertainment and small tokens such as Christmas cards, may be extended to prospective and existing customers. Employees may furnish meals, refreshments or entertainment appropriate to the circumstances in connection with business discussions. The furnishing of meals, refreshments or entertainment should not, however, violate the standards of conduct of the recipient s organisation or of any contractual agreement with a customer. Beyond this, Employees may not offer or give gifts, commissions, gratuities, or other payments, whether openly or secretly, to prospective or existing customers or government officials. Moreover, Recovre expects that Employees will not offer or give secret commissions, hidden gratuities, or confidential payments to third parties who might influence prospective or existing customers or government officials. Recovre prohibits the provision of any service, accommodation or travel of any value whatsoever, unless rendered in conjunction with the performance of company business. Employees who make, and Employees who approve, expenditure for meals, refreshments or entertainment must use discretion and care to ensure that such expenditures are in the ordinary and proper course of business and could not reasonably be construed as bribes or improper inducement. Any Employee who intends to give gifts, gratuities or services, which may not fall within the boundaries of this policy, should complete a Gift Declaration Form and send to Policy.v2 Page 4 of 6

People, Performance & Culture. An Employee gift costing $300 or more will attract Fringe Benefit Tax (FBT) liability, which will double the charge to the Profit Centre. 5.0 Political and Charitable Contributions The Executive Team and the Managing Director must consent to any political or charitable contributions from Recovre. These contributions are made in accordance with relevant Australian legislation. Any Employee who intends to donate gifts, gratuities or services, which may not fall within the boundaries of this policy, should complete a Gift Declaration Form and send to People, Performance & Culture. 6.0 Consequences of Non Compliance Giving or accepting gifts, gratuities or services outside the boundaries of this policy can place both Recovre and the Employee at risk (that is legal, commercial, technological or reputation (brand) risk. Recovre will therefore treat any non-compliance with this policy in line with the Managing Poor Performance Policy, which may include termination of employment. 7.0 Procedure Employees who come across situations in which they are offered or wish to provide clients with gifts, gratuities or services should maintain transparency by declaring such benefits to avoid a conflict of interest. To do so, Employees must completing a Gift Declaration Form and send to People, Performance & Culture. 8.0 Responsibilities 8.1 Employee Responsibilities Ensure they read, understand and comply with this policy as part of their terms and conditions of employment, as outlined in Recovre s Code of Conduct; Complete a Gift Declaration Form where applicable and submit the completed form to People, Performance & Culture. 8.2 Manager Responsibilities Ensure that all expenses are within the Employee s authority and related to the ordinary and proper course of business; and Note that tips should be charged to corporate credit cards. 8.3 People, Performance & Culture Responsibilities Maintains a Gifts Register that records all gifts, gratuities and services given and received (as reported to People, Performance & Culture) and is available for audit; and Notify Employees of any gifts, gratuities or services reported that do not comply with this policy. Policy.v2 Page 5 of 6

Who Do I Contact For Further Information? For further information about this policy, please contact People, Performance & Culture. Related Documents Document Recovre Pty Ltd Collective Agreement 2007 Code of Conduct Gift Declaration Form Location on Recovre Intranet Human Resources / Employment Conditions Human Resources / Policies & Procedures Human Resources / Policies & Procedures Version Control Version Number Date Author Authorised By 1.0 23/11/2006 Sonia Barron Deanna Moloney 2.0 21/5/2009 Sonia Barron Deanna Moloney Controlled Document Subject to Revision. Information contained in hardcopy material may not be the latest version. Policy.v2 Page 6 of 6