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The Gulfstream Legal department may also determine whether disclosure of the payment arrangement would eliminate the impropriety of the payment arrangement. If there are any questions regarding proposed payment arrangements, contact the Gulfstream Legal department.
B. Gifts, Gratuities, and Entertainment -- COMMERCIAL ACTIVITY
1.
Business Gifts Given by Gulfstream
Gulfstream competes solely on the merits of our products and services. Gulfstream does not attempt to influence a customer’s decision to purchase from Gulfstream by offering gifts, meals, entertainment or any item of value. This policy does not address every possible situation involving gifts, gratuities or entertainment. It is important to consider the facts, circumstances and context of each situation on a case-by-case basis. Any situations not addressed by the guidance provided in this policy or referenced materials should be carefully evaluated by consultation with the Gulfstream Ethics Officer who will consult with the Legal Department as necessary.
A gift, or payment of business entertainment expenses, of whatever value, can represent prohibited conduct if provided with corrupt intent to obtain or retain business, and not merely as an unconditional gift with the generalized hope that a favorable business climate will exist. Providing gifts intended as a quid pro quo, and providing frequent gifts to an official in exchange for a pattern of official actions benefiting the donor, would constitute corrupt intent.
Gifts containing the Gulfstream logo procured through Gulfstream-authorized sources or commemorating a company-related event are always acceptable (See also Section C below). Any other gift must be approved in advance by a Senior Vice President and comply with the following guidelines:
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