Conflicts of Interest. Dos and Don ts for Daimler Suppliers.

Transcription

1 Conflicts of Interest. Dos and for Daimler Suppliers.

2 2 Conflicts of Interest. Dos and for Daimler Suppliers. Gifts. 1.1 Daimler employees should never request or solicit offers for entertainment, meals, gifts or other gratuities, or personal services or favors from business partners. 1.9 Employees and their families should never solicit gifts or accept other personal benefits from Daimler suppliers, dealers or other customers. Promotional material and other items of value up to 30/U.S. $ 30 or less may be accepted if made voluntarily and there is no reasonable likelihood the gifts will influence an employee s judgment or actions in performing their duties. Gifts above this value should not be accepted and the business partner should be advised of the Daimler Integrity Code. Dos» Promotional materials, ordinary business courtesies, or other items with a value of not more than 30/U.S. $ 30 may be offered to our employees if they are granted voluntarily and if any intention to influence our employees decisions can be ruled out. However, prior agreements or understandings between the parties are not permitted, in order to ensure that decisions are not being influenced.» Please present any such gifts openly and without false intent.» According to the Integrity Code, Daimler employees and their relatives are not permitted to request gifts from suppliers, dealers or customers.» Do not offer any gifts of a value greater than 30/U.S. $ 30. Daimler employees and their relatives are not allowed to accept them.» Do not send gifts to our employees private addresses.» Do not offer gifts of money or unspecific donations (e.g. vouchers, cash, checks or money transfers).

3 Conflicts of Interest. Dos and for Daimler Suppliers. 3 Discounts. 1.5 If employees use Daimler suppliers, dealers or customers to provide goods or perform services of a personal nature, fair market value must be paid for the goods or services, and the payment must be documented. 1.8 Employees may take advantage of discounts and other promotions offered by Daimler suppliers, dealers or customers, provided such discounts are available to all Daimler employees. Discounts that have been solicited or bargained for in connection with obtaining or providing goods or services on behalf of Daimler or that are only offered to a limited group of employees are prohibited. Dos» A discount is only permissible if it is available to all Daimler employees.» Do not give discounts or special offers benefiting individual Daimler employees or groups of Daimler employees.

4 4 Conflicts of Interest. Dos and for Daimler Suppliers. Meals and Entertainment. 1.2 Business meals as the guest of a business partner may be accepted if they are offered voluntarily, have a legitimate business purpose and are an integral part of the work agenda (e.g. lunch during a seminar or meeting, cocktail reception following meetings or dinner incorporated into a continuing work period). Employees have a responsibility to inform their supervisors on an ongoing basis about the frequency and nature of meals and entertainment paid for by business partners. 1.4 Attendance at sports events and activities, shows or other appropriate entertainment or social activities as the guest of the same business partner is not allowed more than twice a year. A representative of the hosting company must be present. Dos» You may invite the same Daimler employees up to twice a year to events which you attend together with them. If you do not attend yourself, your invitation will be considered to be a gift, and its value must be limited to 30/U.S. $ 30.» Do not invite the same Daimler business partners to events more than twice a year.» Do not invite Daimler employees to events or meals without being personally present.» Do not extend invitations to Daimler employees during contract negotiations or if the invitation can be misconstrued as influence.» Do not offer Daimler employees disporportionately expensive invitations (e.g. to gourmet restaurants).

5 Conflicts of Interest. Dos and for Daimler Suppliers. 5 Travel and Accommodations. 1.3 Travel and overnight accommodations paid for by business partners are not allowed. Exceptions are permitted for business travel in a business partner s plane with the prior approval of an immediate supervisor and at least a Senior Vice President (level C or higher). If a business partner pays for accommodations or provides in-house accommodations, employees should determine the fair market value, make appropriate payment to the business partner, and arrange for reimbursement via their expense report. Dos» Exceptions are permitted for Daimler employees for business travel in a business partner s plane with the prior approval of an immediate supervisor and at least a Senior Vice President (level C or higher). However, the business partner s invitation must be made voluntarily, and there must be no reasonable likelihood of an influence to the disadvantage of Daimler on the employee s judgement or actions in performing his or her duties.» Third-party business partners are not permitted to pay travel or accommodation expenses for Daimler employees.» Do not offer to cover the costs for family members, or offer cash payments through flat rates.

6 6 Conflicts of Interest. Dos and for Daimler Suppliers. Sponsorship. 1.7 Sponsorship by a supplier, dealer or other customer of Daimler events, of birthday, retirement or other company parties is not allowed. Similarly, neither an employee nor an employee on behalf of the company should solicit or accept supplier participation in employee or company-sponsored charitable or quasi-charitable endeavors. Such participation could introduce variables other than cost, quality and delivery into the supplier selection process.» Do not offer support for events carried out by Daimler AG or by employees of Daimler AG.

7 Conflicts of Interest. Dos and for Daimler Suppliers. 7 Financial Services. 1.6 Solicitation or acceptance of personal financial assistance of any kind from a supplier, dealer or a customer is prohibited.» Do not offer any financial assistance to Daimler employees.

8 Daimler AG Stuttgart, Germany