Gifts and Entertainment

Building ethical business relationships

Distell appreciates the important contribution its suppliers, business partners and customers make to its success. The company is committed to fostering healthy, mutually-beneficial relationships with them.

Giving and receiving gifts and entertainment have a role to play in building business relationships; however, the acceptance of gifts or the giving thereof should never create improper influences or obligate the recipient to perform in return. The proposed gift or entertainment should be appropriate in value and nature considering local custom, the position of the recipient and the circumstances.

"The acceptance of gifts or the giving thereof should never create improper influences or obligate the recipient to perform in return"

No Distell employee may give, offer, promise or authorise the giving of anything of value to a government official or anyone else, directly or through an intermediary, such as an agent or business partner, in order to influence official action, or to obtain an improper advantage.

Marketing events, promotions, business lunches, etc., are permitted, subject to the requirements set out and be duly reported in terms of Distell's Gifts and Entertainment Policy as well as in compliance with Distell's Anti-Bribery Policy.

Distell expects its employees and business partners to apply extreme caution in all dealings with government officials. No gifts or entertainment may be offered, given to, or paid to any government official by or on behalf of Distell without the prior approval in writing of the Distell Compliance Officer and/or the Distell Group Company Secretary.

All gifts and entertainment given or received must be recorded in the Gifts and Entertainment Register and properly accounted for. Any gift and/or entertainment given or received will require appropriate approval, depending on the value.

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