The holiday season is often a time for us, our clients, and our suppliers to express our appreciation for one another. While a great way to show love for family and friends, gifting in a professional setting can be a little more complicated. Here are some things to remember when giving or receiving gifts on behalf of P&J:
Non-Government Personnel
| No employee may participate in major entertainment functions involving travel (hunting trips, golf excursions, etc.) without prior approval from the Corporate Compliance & Ethics Officer. |
| Entertainment functions and gatherings that do not involve travel are permitted so long as they are infrequent in nature and are not lavish or extravagant. While it is difficult to define “lavish or extravagant” by means of a specific dollar amount, a common sense determination should be made consistent with marketplace practices. |
| Tangible gifts may be permitted where the giving or acceptance of the gift is not illegal, is of nominal value, and is clearly appropriate under the circumstances. The giving or receiving of tangible gifts must be infrequent in nature and may not be lavish or extravagant. While it is difficult to define “lavish or extravagant” by means of a specific dollar amount, a common sense determination should be made consistent with marketplace practices. |
| Money, in any form, is never given, offered, solicited, or accepted. |
| The ethical rules and policies of the contractors, subcontractors and suppliers transacting business with P&J must be respected and obeyed by P&J employees. |
Government Personnel & Gifts
All forms of gifts and entertainment to or from government personnel (Federal, State, and local), including persons that may be acting for or on behalf of the government, are expressly prohibited.
| Maintain a level of unquestionable integrity in all relationships with clients, owners, subcontractors and suppliers. |
| Seek authorization from the Corporate Compliance & Ethics Officer for entertainment functions that involve travel. |
| Document all ordinary and customary business expenses. |
| Report all violations or suspected violations of this policy to the Corporate Compliance & Ethics Officer or your HR representative. |