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POLICY FOR BUSINESS GIFTS, TRAVEL,
OF FOREIGN OFFICIALS
July 17, 2013
The following Travel, Entertainment and Gifts policy is an addendum to OSIsoft’s Policy
Regarding Improper Influence of Foreign Officials. It is mandatory that all OSIsoft employees and anyone acting on OSIsoft’s behalf (including distributors and resellers) follow this policy for all gifts, entertainment, or travel provided to Foreign
Officials, as described below.
Business Gifts, Travel, and Entertainment of Foreign Officials
Foreign Official includes:
You must obtain written preapproval from 1) your Theater Vice President, and 2) Compliance Counsel prior to incurring any expense associated with the following:
If you wish to seek pre-approval, you need to provide the following information to your Theater Vice President, who will then seek approval from Compliance Counsel if they approve:
A list of all attendees, their titles and their roles; If it’s an event that OSIsoft is sponsoring you must provide:
You may give a business gift, defined as anything of value provided free of charge or without payment, to a Foreign Official if the following requirements are met: :
The value of the gift is less than $100 USD;
The recipient has not received a gift within the last six months;
The gift is provided as a token of esteem, courtesy or in return for hospitality;
The gift is not provided during a competitive bid process or contract negotiation, unless the gift is promotional material such as OSIsoft logo marketing items;
A gift that includes the company’s logo (e.g., pens, t-shirts, hats, mugs, ties, tote bag) is preferred.
The gift is NOT cash;
The gift is presented openly with complete transparency.
You may provide meals or entertainment to a Foreign Official if the following requirements are met:
following requirements are met:
The amount spent on behalf of the Foreign Official over any six month period is less than $150 USD and no single event exceeds $1,000 USD;
The entertainment paid for can be commonly deemed reasonable and is not excessive, lavish, or frequent; Sightseeing or other recreational activities during an OSIsoft sponsored trip are not allowed unless they are minimal and incidental in nature. A modest city sightseeing tour, for example,
No gift or entertainment may be provided:
All gifts and entertainment must be:
OSIsoft can pay for the travel and lodging of Foreign Officials, but only under the following limited circumstances:
OSIsoft will only pay costs directly to an OSIsoft approved service provider.
All travel and lodging expenses must be directly related to an OSIsoft sponsored promotional or training event, e.g., User’s Conference stay at a designated hotel only.
Reimbursement for airfare will be for economy class only.
All transportation and lodging must be per OSIsoft’s Corporate Travel Policy.
The foreign government or public sector entity must approve who receives the travel and lodging. You may not select the particular Foreign Official who will travel. That decision must be made solely by the foreign government or public sector entity. An invitation letter detailing the
purpose, approximate expense for, and itinerary of the trip must be sent in advance to the foreign government or public sector entity. The letter should also request the foreign government or public sector entity to confirm that the travel complies with
their internal policies and regulations.
Travel and lodging is provided only to the designated officials and NOT their spouses, family members, or friends.
Reimburse for incidental expenses are limited to $35 USD per day and require presentation of valid written receipts..
Any souvenirs provided to the Foreign Official should be in accordance with OSIsoft’s Gift Policy, as described above.
Any entertainment must be in compliance with OSIsoft’s Entertainment Policy, as described above.
Apart from the expenses outlined above, do NOT compensate the foreign government or the officials for their visit, or provide the officials with any stipend or spending money.