Bribery refers to any offer, payment, promise or transfer of a Thing of Value to influence someone to win or maintain business or secure some other improper advantage.
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Anti-Bribery, Gifts & Entertainment
What is bribery?
What is a kickback?
A kickback is an improper offer, payment, promise or transfer of a Thing of Value for having done something. It’s a bribe after the fact.
What is a “Thing of Value”?
A “Thing of Value” is as broad as it sounds. It includes money, physical objects, entertainment, travel, lodging, favors, donations or anything that the recipient might want or value.
What should I do?
Never request or accept a bribe or kickback. This includes requesting or accepting, directly or indirectly, those from anyone (either in the public or private sector) to win or maintain business or to secure any other type of improper advantage.
Exchange gifts with care. Employees should not seek or accept gifts or entertainment from suppliers, contractors or others dealing with Coty, if it could influence their judgment. Any gift or entertainment valued over USD $50.00 (or equivalent local currency) should be considered excessive.
Do not give gifts or any other Thing of Value to government officials. The rules are typically stricter regarding bribery and kickbacks than in the private sector, and can be a criminal offense.
Promptly disclose receiving an excessive gift to the Compliance Team. This means any Thing of Value worth more than USD $20 (or the equivalent in local currency) from a government official, or any Thing of Value worth more than USD $50 (or the equivalent in local currency) from any other source.
Follow our policy on Anti Bribery and Anti Corruption. The policy contains details that will help you decide the appropriateness of giving and receiving Things of Value.
Who is a government official?
The law typically defines “government officials” broadly to include:
- Elected or appointed officials at any level.
- Officers or employees of businesses that are state-controlled or state-owned, in whole or in part.
- Political party officials and those acting on their behalf.
- Candidates for public office.
- Officers or employees of a public international organization, such as the United Nations or World Bank.
- Anyone acting in an official or unofficial capacity on behalf of any of the above.
Key rules for gifts:
- Coty may give its products as gifts to employees for personal use only. Employees cannot sell these products.
- Employees must never give anything of value to government officials without express permission from Coty Compliance and Legal teams.
- Never give or accept cash or cash equivalents, such as gift cards, in any amount.
- Employees can provide meals, gifts or entertainment to business partners as long as it complies with the law and is within common courtesies. Refer to our Gifts and Entertainment Policy. If rejecting a gift is not culturally acceptable or returning it is impractical, the gift should be discussed with your local Compliance Officer or Human Resources for appropriate handling.
- If you need further clarification on exchanging gifts, contact your local Compliance Officer or the Global Compliance Officer.
Is the gift appropriate?
To decide whether something is an appropriate gift, ask yourself: