Github Company Policies Github Gifts And Entertainment Policy (GitHub)
This document outlines GitHub's Gifts and Entertainment Policy, designed to ensure employees comply with anti-bribery laws and ethical standards in business dealings. It provides clear guidelines on acceptable and unacceptable gifts and entertainment, detailing the necessary approval and reporting processes. The policy emphasizes the importance of preventing improper influence and avoiding legal consequences like fines and jail time.
GitHub Gifts and Entertainment Policy
GitHub recognizes that our business is built on positive and transparent relationships. While informal interactions and exchanges of gifts may be part of developing those relationships and may even be considered customary in some countries, we need to ensure that we’re following anti-bribery laws. We have a legal obligation to behave ethically, including by not using such interactions to create a special advantage or influence a deal.
Company policies
As a reminder, our Code of Ethics states:
You must never pay, offer to pay, promise to pay, induce, accept, or authorize payment of anything else of value, to anyone—including to anyone in a position of power or authority, such as government officials, or in commercial transactions—in order to obtain or keep business, or secure any other improper advantage for GitHub or Microsoft. You also must not solicit or accept a bribe, kickback, or any other improper cash payment. ... [GitHub employees] are required to keep accurate and fair records of all transactions involving any expense made on GitHub’s behalf—for example, by keeping receipts and providing accurate descriptions of your expenses—or any other transaction involving the disposal or transfer of GitHub assets. Such actions are required by the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act of 2010, and anti-bribery laws of other jurisdictions in which GitHub does business and are also simply the right thing to do.
GitHub's Code of Ethics elaborates on certain situations, including gifts, travel, and entertainment; facilitating payments; charitable donations; jobs; and working with representatives, as well as on who is considered a government official.
Our Standards of Conduct prohibit:
Bribing government officials or other individuals to gain an unfair advantage, and taking bribes from anyone.
That means not only no cash or cash equivalent of any kind, but nothing of value, should be given to anyone (including civil servants, government officials, or anyone in a position of power or authority, as well as people not in any of those privileged positions) in order to influence them or taken from anyone to influence GitHub. Such activity is prohibited by the U.S. Foreign Corrupt Practices Act and UK Anti-Bribery laws, both of which govern GitHub’s actions globally.
Examples of acceptable and unacceptable gifts
So what does “of value” mean? Keep in mind that no gifts are acceptable for government officials (ok, maybe stickers). You should always ask them what their policies permit and prohibit. But if in doubt, please run it by Legal to make sure. For example, many U.S. congresspeople will not let you take them out for dinner and pay.
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