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1.
an officer or employee of a:
a.
government department or agency
b.
state-owned or state-controlled enterprise
c.
public international organization
2.
a non-U.S. political party, party official, or candidate, or
3.
any person acting in an official capacity for or on behalf of any of the above, e.g., consultant
for a non-U.S. government.
Cash advances to government customers, even when to support the operation of the aircraft being sold or serviced, or the purchase of items not related to the aircraft sold or serviced by Gulfstream, can lead to the appearance of impropriety under various laws, including the FCPA and the OEDC Convention. Cash advances to government customers or the purchase of non-aviation items by Gulfstream for the benefit of government customers are prohibited unless the FCPA Compliance Officer grants a written exception.
3. GIFT AND ENTERTAINMENT LOG – FOREIGN AND DOMESTIC GOVERNMENT OFFICIALS
In addition to the complying with all of the foregoing requirements of this Section C, Company employees who provide gifts, entertainment or business meals (other than Minor Gifts or Minor Business Meals, as defined below) to government employees are also required to promptly create and submit via email a detailed “Gift Log” (Attachment 1) of such activities to the Company’s Ethics Officer. (meals provided to Congressional Representatives are prohibited and are not Minor Meals regardless of cost and must be listed if ever mistakenly provided).
“Minor Gifts” are company logo items secured from the Company Store or the Company Sales Premiums Website if their cost to the Company is less than $35.00 per item. ($10.00 per item when provided to Congressional Representatives).
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本文链接地址：湾流宇航公司公司政策手册 Gulfstream Aerospace Corporation Corporate Policy Manual(9)
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