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Gifts and Entertainment

Our Policy

As a general rule, you can accept a meal, gift, or entertainment from nongovernment customers, suppliers, or business partners if it is unsolicited, inexpensive, and not given to influence business decisions.

Similarly, employees may provide reasonable meals, gifts, or entertainment to nongovernment customers, suppliers, or business partners, provided that it is related to proper business purposes, is not offered to influence a business decision, and is permitted under applicable laws and Avaya’s Travel and Entertainment policy.

Gifts are often exchanged as a part of business relationships. Often these consist of Avaya-branded items or other non-lavish items consistent with local norms.

The graphic below provides guidance for necessary approvals for gifts and entertainment:

Non-Lavish Gifts (less than $100 USD) and/or Entertainment (less than $250 USD):

Lavish Gifts (more than $100 USD) and/or Entertainment (more than $250 USD):

Written approval from your direct manager

Written approval from (i) your direct manager and (ii) the Ethics and Integrity Team

(Convert USD to local currency)

Please note the following guidelines apply to all gifts, entertainment, or other advantages:

  • Cash or cash equivalents are not acceptable forms of gifts in any circumstance.
  • Gifts should not be lavish.
  • Permissible gifts must be given with complete transparency and accurately reflected in Avaya’s books and records through appropriate receipts and documentation.
  • Gifts, meals, and entertainment for officials and employees of governments (including government-owned entities), in every country around the world, are highly regulated and often prohibited and must be reviewed in advance by the Ethics and Integrity Team.
  • All travel for customers, partners, press, or suppliers must be in accordance with Avaya’s Travel and Expense policy and reviewed in advance by the Ethics and Integrity Team.

Showing Accountability and Trustworthiness

Do not provide or accept gifts, entertainment, or other favors of the type or amount that go beyond common courtesies consistent with ethical and accepted business practices.

Do not use third parties such as partners, suppliers, or family members to provide gifts, entertainment, or favors.

Gift Receiving

  • You can accept a gift, meal, entertainment, or other favor from nongovernment customers, partners, or suppliers, provided it is unsolicited, reasonable, and not given to influence your judgment. In other circumstances, you should decline and explain Avaya’s policy.
  • Before accepting a gift, an invitation for a meal or entertainment, or other favors that seem lavish or excessive, consult your supervisor or email the Ethics and Integrity Team.

Gift Giving

Employees may provide reasonable gifts, entertainment, meals, or favors to nongovernmental customers, partners, or suppliers provided that:

  • You are not asked to provide it.
  • It is not being offered to influence the recipient’s business decision.
  • It is permitted under applicable laws, regulations, rules, and consistent with ethical and accepted business practices.
  • It is consistent with Avaya’s policy.

Recognition Gifts

Supervisors and employees must consult Human Resources before presenting any gift or other form of recognition to Avaya employees to ensure compliance with Avaya’s recognition policy.

Knowledge Tip

Consult with your supervisor and the Ethics and Integrity Team regarding the following:

  • Golf outings
  • Trips to resorts
  • Tickets to events such as concerts, sporting events, or theater shows
  • Gifts for you and your family

What is the difference between a gift and business entertainment?

Business entertainment can entail dinners, sporting events, trade shows, or other customer events at which representatives of both parties are generally in attendance and business is typically discussed. A gift is something given or received, such as tickets for an event at which representatives of the organization extending the gift are not in attendance.

A customer asks me to obtain four tickets to a large sporting event and hints that this will close the sale more quickly. Can I buy the tickets?

This potential scenario raises a number of concerns. First, a gift cannot be solicited. Second, four tickets to an event is considered lavish. Third, the facts do not suggest that a business conversation or product demonstration would be taking place.

A supplier invites me to a sporting event that it is hosting with other customers, offering an opportunity to meet its leadership and discuss business relationships. Can I go to the game?

You need to obtain approvals in writing based on the Gifts and Entertainment approval matrix and its thresholds prior to attending.

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