Business Gifts and Entertainment
Gifts over the value of €150 (or local currency equivalent) must be reported to the Head of Business Unit or Country Manager concerned who will ensure it is recorded in the Gifts Register and decide if it may be kept or not. Entertainment may only be offered or accepted in the ordinary course of business provided it is reasonable and not excessive and neither influences the recipient’s objectivity nor could be construed as a means to make the recipient feel obligated. We require our businesses to comply with the above principles and to put in place procedures that will assist and enable them to do so, and expects all its employees to act in accordance with them.
Financial donations are not permitted to political parties anywhere in the world.
Employees are prohibited from buying or selling shares on the basis of inside information. Inside information is defined as information that is not available to the public, and includes financial data, plans for mergers, acquisitions or disposals, changes in dividend policy, new products or major management changes. Trading shares in ITE Group plc or any other publicly traded company on the basis of inside information is prohibited, as is the passing on of inside information to anyone who uses it to purchase or sell shares or other securities. Insider trading is illegal and may result in prosecution.
We are committed to free and fair competition and will compete strongly but honestly complying with all local competition laws.
We will not condone the offering or receiving of bribes or other such facilitating payments to any person or entity for the purpose of obtaining or retaining business or influencing political decisions.
Confidentiality and Accuracy of Information The confidentiality of information received in the course of business will be safeguarded and respected, and never used for personal gain. False information will not be given in the course of commercial negotiations.
Conflict of Interest
Any personal interest, which may prejudice, or might reasonably be deemed by others, to prejudice the impartiality of employees must be formally declared to a senior manager. Examples of this include owning shares in business partners and personal or family involvement in trading contracts.