I. Applicability and Overview

UNNATIM is committed to doing business strictly on the basis of the value of products and services offered and purchased and not on the basis of gifts or offers we extend or accept. We have very stringent rules in place that Employees2 (includes Immediate Relative) are required to adhere to.

II. Definition

A gift is anything of value and can take many forms including meals or refreshments; goods or services; tickets to entertainment or sporting events; the use of a residence, vacation home or other accommodations; a raffle prize; travel expenses; a product or service discount; or charitable or political contributions, etc. made on behalf of an Employee.

III. Requirements

• Employees should never give or accept any gift, entertainment, consideration, benefit or privilege (including discounts on personal purchases not offered to all UNNATIM employees) where the value

(i) is not reasonable in its business context or

(ii) places the recipient under a real or perceived obligation to the giver.

• Gifts that are intended to or would result in favourable treatment or influence a business decision, regardless of the amount or value involved, should never under any circumstances be given or accepted.

• Providing gifts, travel, meals or entertainment to a public official or private individual is never permitted if it could reasonably be understood as an effort to improperly influence an official action or obtain a business advantage for UNNATIM.

• An employee should not accept, and should notify his/her supervisor, if offered, any gifts, entertainment or anything else of value from a competitor, customer/client or anyone who conducts or seeks to conduct business with UNNATIM, other than (i) Nominal Gifts or (ii) Ordinary Business Entertainment, as those terms are defined below.

• Nominal Gifts are gifts of token to modest value that will not place the recipient under any real or perceived obligation to the donor or gifts used for advertising or promotion, as long as they are customarily given in the regular course of business.

• Ordinary Business Entertainment, such as lunch, dinner, theatre, sporting events and the like, is appropriate where it is reasonable in its business context and the purpose is to hold bona fide business discussions or to foster better business relations.

• Specific prohibitions include:

– No cash or cash-equivalent may be given or received

– this can include cheques, travellers cheques, money orders

– unless given or received under a UNNATIM-sanctioned sponsored program

– Any gift or entertainment, irrespective of amount, which is, or appears to be, linked to a competitive procurement or bidding process

– Soliciting or encouraging gifts to be given by business contacts

– Providing a service or subscription for free in lieu of payment, for which UNNATIM would otherwise charge, excluding any UNNATIM sanctioned program in connection with regulators or regulatory agencies;

– Charitable giving used as a mechanism to conceal payments made to improperly Influence anyone with decision making authority

• Gifts or Entertainment that is not permitted under this Policy, must be returned

In any of the above events, compliance should be notified immediately.

Business/function specific prohibitions may also apply.

IV. Disciplinary Action

UNNATIM takes violations of this Policy seriously. Failure to comply with this Policy, could result in disciplinary action up to, and including, termination of employment.

V. Relationship to other Policies

This policy shall be read in conjunction with other applicable policies.