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湾流宇航公司公司政策手册 Gulfstream Aerospace Corporation Corporate Policy Manual(6)

时间:2011-10-01 16:41来源:蓝天飞行翻译 作者:admin
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d) Air travel that is part of the employee’s job duties, such as flight crew and maintenance personnel participation in maintenance check flights or entry-into-service operations, is not in the nature of a gift and is always permitted.
 
C.  Gifts, Gratuities, and Entertainment -- GOVERNMENT SALES AND SERVICE ACTIVITY
 
In addition to the preceding guidance on Gifts, Gratuities and Entertainment in the context of the Company’s commercial customers, other limitations apply to Gulfstream’s dealings with government agencies and government employees, both domestic and foreign.  Employees who transact business 
with any governmental agency should familiarize themselves with this section.
 
In addition to the policy set out below, the General Dynamics "Standards of Business Ethics and Conduct" (the "Blue Book") and General Dynamics’ Corporate Policy (CP02-102) “Gifts and Hospitality” both provide further specific guidance for the ethical practices expected of Gulfstream employees when dealing with US government or foreign government officials, and are adopted herein by reference.  Gulfstream employees who interact directly with such government officials should familiarize themselves with such policies, and direct any questions or concerns they may have to Gulfstream’s Ethics Officer, Gulfstream FCPA Compliance Officer or Gulfstream’s Legal Department.
 
1.     US GOVERNMENT ACTIVITY:
 
NASA and DOD regulations prohibit, among other things, entertainment by a contractor, even business lunches. Not all agencies are as restrictive though; so if you have dealings with other U.S. Government agencies (such as the FAA), you should become familiar with the regulations of such agencies and should conduct yourself accordingly. The FCPA Compliance Officer may be contacted for additional guidance.  Gulfstream employees dealing with the US Government are specifically directed to General Dynamics’ Corporate Policy (CP02-102) “Gifts and Hospitality” and are required to comply with it in all aspects when dealing with the US Government.  If issues of guidance or reporting are required under either this Gulfstream policy or the General Dynamics’ Corporate Policy, Gulfstream employees may contact either the Gulfstream Ethics Officer or the General Dynamics’ Corporate Ethics Officer. 
 
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