The following message is from Pavirisa Homprasert, Local Compliance Officer, Thailand
Dear Colleagues,
As we approach the time of year when many of us attend parties and exchange gifts with third parties, we take this opportunity to remind employees of the requirements of the AIG Employee Conflict of Interest Policy, AIG Code of Conduct and AIG Global Anti-Corruption Policy. These policies and the Code of Conduct provide rules and guidelines to help employees make the right decisions when providing or accepting gifts or entertainment.
Important rules regarding gifts and entertainment include:
If an employee is not present at the business entertainment (e.g., a sporting event or cultural event), the event will be considered a gift and is subject to the financial limits (i.e., $150 per person, except where further limited by local law).
Gifts and entertainment between AIG employees are subject to AIG Global Expense Management Standards and Procedures Manual.
Employees who receive gifts that do not meet the gifts and entertainment criteria must (i) if possible, politely reject or return the gift, or (ii) if not possible to reject or return, accept the gift and report it immediately to their manager who will consult with Compliance regarding appropriate next steps.
AIG employees should be especially careful when offering gifts or providing business entertainment to government officials. A Request for Approval of Expenditures for Gift, Meal, Travel or Other Hospitality for a Government Official Form must be submitted to Compliance at least five (5) business days prior to offering gifts or other expenditures regardless of value and, meals above $25.00 per person, except where further limited by local law.
Guidelines for permissible gifts and entertainment include:
Cannot be lavish or extravagant – except where further limited by local law, the cost of a gift should be under $150 per person unless written pre-approval is received from your manager.
Must be reasonable, ordinary, customary and lawful in the country where they are exchanged.
Be reasonable in frequency – the gift or entertainment must not occur regularly or frequently with the same recipients so as to suggest an improper motive.
Have a legitimate business purpose – the gift or entertainment must be offered or accepted only for legitimate business purposes (e.g., promotion of AIG or an AIG product, service, or a potential or actual business relationship).
Prohibited gifts and entertainment include:
Any activity or item that is not in good taste or that might reflect negatively on AIG if publicly disclosed.
Those that might create undue influence, unfairly impact a business relationship, impair good business judgment or represent an inducement to obtain business or favorable treatment (e.g., a bribe, corrupt intent).
Cash or cash equivalent in any amount. Cash equivalents include gift certificates, gift cards, checks, traveler’s checks or money orders, investment securities, negotiable instruments, payment of credit card charges or similar items.
Those that have an inappropriate purpose – violation of the law, regulations, agreements or reasonable customs of the marketplace.
Any gifts or business entertainment solicited by an AIG employee.