demonstrated beyond doubt that an employee was faced with a life-threatening situation. In such a case, the coerced payment must be approved by ECCO’s Legal Department. If the situation does not allow time to contact the Legal Department, the situation must be reported immediately to Legal Department when solved. 2.2 Money Laundering Money laundering is the process by which large amounts of illegally obtained money (e.g. from drug trafficking bribery or actions in non-compliance with international sanctions) are given the appearance of having originated from a legitimate business. ECCO only does business with business partners and customers with legitimate businesses. Before entering into business with new partners, their financial and operational legitimacy is carefully examined and ECCO maintains adequate records hereof. 2.3 Facilitation Payments Facilitation payments are small cash payments made to secure or speed up administrative actions, processes, or documents, obtaining mail or telephone services, or expediting shipments through customs. These payments are not intended to influence the outcome of the official’s action, only its timing. ECCO does not endorse facilitation payments and advises, where possible, to attempt avoid making facilitation payments. 2.4 Charitable Contributions and Sponsorships Charitable contributions and sponsorships must not be used as bribery, or to obtain any private advantages such as rebated purchase or sponsorship from business partners. It is important to act objectively and professionally, and keep all private matters aside when interacting with business partners. 2.5 Gifts, Entertainment, and Favours It is common business courtesy in many countries for guests and hosts to offer or accept gifts. ECCO accepts this as part of the culture and does not wish to embarrass others who follow these customs. Gifts can include objects, events, entertainment, or favours. However, gifts should be offered and accepted only as common social or business courtesy at a level appropriate to the status and seniority of those involved. Any gifts or favours interpreted as an attempt to encourage preferential treatment are not acceptable under any circumstances. The standard limit for a gift is to be determined by the local management of each business unit, up to a maximum of US$ 100, or its local currency equivalent. Any gift to be given that is worth more than the agreed limit requires prior approval by the ECCO Managing Board member responsible for the region in question, and the approval must be formally registered. Gifts received with a value over US$ 100 must be passed to the business unit’s HR manager. If possible, these gifts will either be made available to all employees, or donated to charities or similar organisations. Exceptions would include a gift to celebrate an employee’s anniversary with the company, or his or her birthday. 35
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