I want to offer or provide/arrange

1.2.2.1      A Gift

A Gift

Where permitted by law and not in violation of the recipient’s company policy, you may provide a Gift to a customer, business partner or the likewise, if it fits within the following standards:

  • You should limit gift giving to promotional items of nominal value. Ordinarily, this means that the Gift will bear a Stora Enso logo.
  • In exceptional cases, for example at the retirement day of the manager of an important customer, more exclusive Gifts can be offered, but you should rarely offer Gifts that are more than Euro 200 in value. Please note that this is nothing but a maximum amount. It does not say that Gifts below this amount is always permissible or reasonable.
  • Gifts shall not be given to the same recipient on a repeated and regular basis.

You may only provide Gifts in an open and transparent manner and not under any circumstances in which the Gift giving is or needs to be concealed

The following Gifts, Hospitalities and Expenses are never acceptable

  • Gifts, Hospitalities or Expenses where your intent is to influence the recipient to do something improperly.
  • Gifts, Hospitalities and Expenses in violation of the recipient’s company policy.
  • Gifts, Hospitalities or Expenses to a business partner under on-going business negotiations.
  • Gifts, Hospitalities or Expenses to family members of client- or customer representatives.
  • Cash or a cash equivalent (such as gift cards, vouchers or the likewise).
  • “Adult” entertainment or any sort of event involving nudity or lewd behaviour.

If you have any questions regarding Gifts please contact Legal, Ethics and Compliance.

1.2.2.2      Providing Gifts or Hospitality to a Public Official

Providing Gifts or Hospitality to a Public Official

When dealing with Public Officials, even small, bona fide, legitimate Gifts, Hospitalities, or Expenses may be misinterpreted as illegal bribes and may establish a criminal offence.

You may however provide Hospitality to a Public Official if the following standards are met:

  • It is acceptable to provide ordinary business courtesy Hospitality of nominal value, such as tea and coffee, a sandwich lunch where the Public Official is attending a meeting at your office or other non-excessive Hospitality when hosting a visit from a Public Official.
  • If you are hosting a visit from a very senior Public Official such as a government Minister, it is acceptable to provide a level of Hospitality that is appropriate to his status.
  • There should never be any suggestion, or perception, however, that the provision of Hospitality is intended to influence the Public Official.
  • Public Officials are frequently subject to their own strict guidelines or codes, or to legislation. Where feasible, you should take steps to ascertain what the guidelines or applicable legislation permits or requires and ensure that any Gifts or Hospitality you offer complies with such guidelines or legislation.
  • You must always seek approval before offering Gifts and Hospitalities to a Public Official with the exception of Gifts or Hospitalities of very low value (e.g. a pen or notebook to use at a meeting, tea, coffee etc.).

You must always seek approval before offering Gifts and Hospitality to a Public Official with the exception of Gifts or Hospitalities of very low value (e.g. a pen or notebook to use at a meeting, tea, coffee etc.).

If you have any questions regarding or concerning gifts or hospitality to Public Officials please contact Legal, Ethics and Compliance.

1.2.2.3      Hospitality (Meals and Entertainment)

 Hospitality (Meals and Entertainment)

Where permitted by law and not in violation of the recipient’s company policy, you may provide Hospitality (Meals and Entertainment) to a customer, business partner or the likewise, if it fits within the following standards:

  • You should only offer or provide Hospitality (meals and entertainment) that is consistent with generally accepted business practices and serves a valid business purpose.
  • The Hospitality offered and provided must be appropriate to the underlying business purpose and should not be extravagant.
  • The Hospitality must be offered without creating an express or implied obligation or incentive to conduct business. A representative of each company must be present.
  • Hospitality should not be provided to the same recipient on a repeated and regular basis.
  • You should provide Hospitality in an open and transparent manner and not under any circumstances in which the Hospitality is, or is sought to be, concealed.

The following Hospitality is never appropriate:

  • Hospitality where your intent is to influence the recipient to do something improperly.
  • Hospitality in violation of the recipient’s company policy.
  • Hospitality to a business partner under on-going business negotiations.
  • Hospitality to family members of client- or customer representatives.
  • Cash or a cash equivalent (such as gift cards, vouchers or the likewise).
  • “Adult” entertainment or any sort of event involving nudity or lewd behaviour.

 If you have any questions regarding or concerning the provision of Hospitality please contact Legal, Ethics and Compliance.

1.2.2.4      A Customer event

 A customer event

 Customer events are commercial events providing hospitality or other forms of courtesy and information to deepen customer relationships. Customer Events normally include travelling, accommodation and Hospitality.

In the case of more extensive customer events which are of significant value, such as events including travelling and over-night accommodation, the following rules should be observed:

  • Customer Events are only permissible only if there is a clear business objective for the trip.
  • Customer events, and other kind of customer hospitality, should be avoided in relation to customers under on-going business negotiations.
  • If possible, you should ask for confirmation from the employer of private sector guests to provide a declaration that the acceptance of the Hospitality will not be in breach of any corporate code.
  • The ratio of Stora Enso staff to customers shall be high, normally 1:2.
  • Record details of the trip, including costs and identity of the guests and agenda.
  • Keep the cost of trips under review, and ensure that excessive or lavish hospitality is avoided.
  • Include a seminar on Business Ethics.

The total cost for each customer representative should never exceed Euro 1,500.

Remember:

  • The total cost for each customer representative should never exceed Euro 1,500.
  • Customer events where the cost per guest exceeds Euro 750 needs to be reported to and approved by the Division Head and the Division Lead Counsel.

 If you have any questions regarding or concerning the arrangement of Customer Events please contact Legal, Ethics and Compliance.

1.2.2.5      A donation

A donation

A Donation (Charitable Contribution) is a gift for charitable purposes, i.e., contributions given to a charitable or not-for-profit organisation for which no benefit is received, or expected to be received, by Stora Enso (as opposed to Sponsorship).

We must ensure that Donation is not being used as a subterfuge for bribery.

  • Donations shall comply with local and regional laws and regulations and the Stora Enso Sponsoring and Donations policy.
  • All Donations must be approved by the CEO or CFO and in some cases by the Board of Directors or the Annual General Meeting.
  • All Charitable Contributions and Sponsorships made on behalf of or in the name of Stora Enso must be reported to Stora Enso Legal Services. A list of Stora Enso’s Charitable Contributions and Sponsorships is distributed to the Board of Directors and the GLT annually.
  • Donations must be accurately and fairly reflected in the accounts of the Company.

If you have any questions regarding Donations, please ask your manager or contact Legal, Ethics and Compliance.

1.2.2.6      Sponsorship

Sponsorship

A Sponsorship is the supporting of an event, activity, person or organisations financially or with products or services and utilising the publicity of the sponsoring target. Both parties benefit from the cooperation (as opposed to Donations).

When providing sponsoring we must ensure that the sponsorship is not used as a subterfuge for bribery.

  • Sponsorships shall comply with local and regional laws and regulations and the Stora Enso Sponsoring and Donations policy.
  • All Sponsorships made on behalf of or in the name of Stora Enso must be reported to Stora Enso Legal Services. A list of Stora Enso’s Charitable Contributions and Sponsorships is distributed to the Board of Directors and the GLT annually.
  • Sponsorships must be accurately and fairly reflected in the accounts of the Company.

If you have any questions regarding Sponsorships please ask your manager or contact Legal, Ethics and Compliance.

1.2.2.7      Community Project

 Community Project

 Community Project refers to projects supporting development or creating improvements of communities in areas where Stora Enso operates by providing resources needed to affect change.

It is helpful to understand that Donation is for charitable purposes, providing Sponsorship returns with receiving general publicity, while Community Project has clear targets associated with particular business or project.

Examples in real life:

  • Charitable contribution after earthquake in western China, Donation
  • Scholarships to university students in forestry or paper industry in Brazil, sponsorship
  • Supporting in road or school construction for villagers who lost lands as a result of Stora Enso investing in an industrial park, or for villagers who lease forest land to us, Community Project.

It is equally important to keep in mind that when arranging Community Project we must ensure that they are not used as a subterfuge for bribery. Although Community Project are not required to be reported the same way as Donation or Sponsorship, it is recommend for each business unit to have strict control over any Community Project expenditure.

If you have any questions regarding Community Project please ask your manager or contact Legal, Ethics and Compliance.

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