Developing good working relationships with our customers, suppliers, and business partners is important to our growth. Reasonable gifts and entertainment are courtesies that are sometimes exchanged to foster these relationships and build goodwill. However, providing gifts and entertainment can also create the perception that business decisions were made based on factors other than fair and objective business criteria. It is for this reason that we must exercise caution and be thoughtful when giving or receiving business gifts and entertainment.

We have a responsibility to make sure that any gift, entertainment, or other benefit we give or receive is appropriate and consistent with Company policies. Avoid all gifts, entertainment, or benefits that might compromise or appear to compromise, the objectivity of all involved parties. Gifts, entertainment, or other benefits should never influence, or give the appearance of influencing, impartial decision-making.

What is expected of you?

  • Review and adhere to the Rogers Gifts & Entertainment Policy.
  • Do not solicit or accept any gift, entertainment, or other benefit from anyone in exchange for doing business with our Company.
  • Never, under any circumstances, offer or accept any cash gifts, cash gift equivalents (such as gift cards), or loans.
  • Seek the guidance of the Director of Global Compliance & Integrity or the Legal & Compliance Department if you are unsure whether you should offer or accept a business gift, entertainment, or other benefit.

Practice Tips

As a general rule, do not give or receive gifts, entertainment, or other benefits unless the gift meets all of the following criteria, as further elaborated in the Gifts & Entertainment Policy:

  • Infrequent and reasonable in value
  • In the ordinary course of business
  • Consistent with customary practices in your industry and country
  • Permitted by the other party’s company policies
  • Compliant with all applicable laws and regulations
  • NOT solicited
  • NOT in cash or cash equivalents, such as gift certificates or gift cards
  • NOT tied to a potential contract or business deal
  • NOT given to government officials or government employees