Gifts And Entertainment Policy

 

Background Information

This policy applies to any situation where Plexus is giving or receiving gifts, meals and entertainment. This includes any of the following situations:

  • Where a Plexus employee gives any gift, meal or entertainment while acting within the scope of his or her employment.
  • Where a Plexus employee receives any gift, meal or entertainment while acting within the scope of his or her employment.
  • Where a Plexus employee is acting outside of the scope of his or her position at Plexus, but is dealing with a person or entity with whom the Plexus employee regularly interacts as an employee of Plexus.
  • Where a person or business engaged by Plexus (such as a consultant) gives or receives any gift, meal or entertainment on behalf of, or for the benefit of, Plexus.

General Guidelines

Discretion and Guidance

Appropriate discretion in the giving and receiving of gifts, meals and entertainment is critical for protecting Plexus’ reputation with shareholders, customers, suppliers and regulators and to avoid violating legal requirements. Whenever there is any doubt as to whether a transaction involving gifts, meals or entertainment is appropriate, you should exercise caution and, prior to engaging in the transaction, seek guidance from your local human resources representative or Plexus legal. If there is any doubt whether a gift, meal or entertainment transaction would violate this policy, the transaction should be avoided. A good rule of thumb to follow is whether a disinterested observer would view the gift, meal or entertainment as an unethical or unfair business practice.

Reasonable gifts, meals and entertainment permitted generally

The giving and receiving of gifts, meals and entertainment is a regular occurrence in conducting business activities. Plexus employees are permitted to give and receive gifts, meals and entertainment in the normal course of business activities provided that such transactions meet the requirements of this Policy.

Corrupt Transactions Prohibited

A corrupt transaction is giving or receiving anything of value for an improper purpose (for more information, see the Plexus Anti-Corruption Policy). Examples of corrupt transactions include bribes and kickbacks. Some companies have disguised corrupt transactions as travel and entertainment expenses and expensive gifts. This Policy provides detailed guidance and examples to help Plexus employees distinguish between appropriate business gifts, meals and entertainment and improper corrupt transactions.

Requirements For All Meals and Entertainment

All meals or entertainment must meet all of the following requirements:

  • The transaction must be conducted openly and transparently.
  • Accurate records and documentation must be maintained for the transaction in accordance with applicable accounting policies.
  • The transaction must be motivated by hospitality or a legitimate business purpose; the transaction cannot be motivated to improperly influence the recipient’s judgment (see the Plexus Anti-Corruption Policy). 
  • For meals and entertainment involving a customer or supplier, representatives of both Plexus and the customer or supplier must be present at the meal or event.
  • The transaction must be reasonable and consistent with normal and customary business practices. 

Examples of reasonable and customary:

  • A modest meal at a restaurant customarily used for business entertainment.
  • Modest refreshments at conference. 

Example of unreasonable and non-customary:

  • Tickets to an extraordinary sporting event (i.e., the Super Bowl or World Cup).

Requirements For All Gifts

All gifts to and from customers, vendors, third party agents must meet all of the following requirements:

  • The transaction must be conducted openly and transparently.
  • Accurate records and documentation must be maintained for the transaction in accordance with applicable accounting policies.
  • The transaction must be motivated by hospitality or a legitimate business purpose; the transaction cannot be motivated to improperly influence the recipient’s judgment (see the Plexus Anti-Corruption Policy). 
  • The recipient cannot solicit (request) the gift.
  • The transaction cannot involve direct cash gifts or payments (or the equivalent—such as gift cards).
  • Approval from the regional leader of human resources or any member of Plexus Legal is required for any gift exceeding more than $200 (USD) in value.
  • The transaction must be reasonable and consistent with normal and customary business practices. 

Examples of reasonable and customary:

  • Company logo items.
  • A single bottle of a reasonably priced bottle of wine.
  • A box of chocolates.

Example of unreasonable and non-customary:

  • Use of a vacation or holiday home.
  • Free or discounted travel (i.e., a free ski weekend).
  • Jewelry or expensive electronics.
  • Discounted or free products for personal use.

Regional or Functional Policies

Regions or functions within Plexus may adopt policies on gifts, meals and entertainment that are more restrictive than this Policy. Employees must comply with any applicable more restrictive regional or functional policies.

Government Officials

More restrictive guidelines than those described in this Section 2 apply to gifts, meals and entertainment involving government officials. See Section 3 below.

Gifts, Meals & Entertainment Involving Government Officials

Background

Caution should be exercised before giving or receiving gifts, meals or entertainment to or from any government official. The laws of many countries, including the U.S., severely restrict gifts, meals and entertainment given to government officials.

Who Is A Government Official

A government official includes traditional government officers and employees and also includes any of the following:

  • Political parties and officials. 
  • State-owned enterprises, which are companies owned in part by a government.
  • Employees or agents of state-owned enterprises.
  • Military personnel and members of royal families.

Requirements for Gifts, Meals and Entertainment Involving U.S. Government Officials (Federal, State or Local)

In addition to meeting the requirements under Section 2 of this Policy, any gifts, meals or entertainment given to a U.S. government official must meet both of the following requirements:

  • The value of the gift, meal or entertainment cannot exceed $20 (USD) in the aggregate per occasion.
  • The total value of all gifts, meals or entertainment from Plexus to the U.S. government official cannot exceed $50 (USD) per calendar year. 

The above requirements are commonly known as the “20/50 Rule.” Providing normal refreshments at business meetings, such as water and coffee, does not count against the 20/50 Rule limits. In addition, meals normally offered to employees generally at any facility (such as a cafeteria) are exempt from the 20/50 Rule limits.

Some U.S. government agencies require their employees to pay for their portion of refreshments themselves in all circumstances. Where this is known to be the case, Plexus should make every effort for any food and refreshments provided to be modest and provide a “contribution” jar or basket through which the government employee can cover the cost of his or her refreshments.

Be very cautious when dealing with U.S. government officials. Even innocent gestures such as giving a government official a ride to or from the airport can violate legal requirements. Any questions concerning these transactions should be directed to Plexus Legal.

Requirements for Gifts, Meals and Entertainment Involving Non-U.S. Government Officials

In addition to meeting the requirements under Section 2 of this Policy, any gifts, meals or entertainment to a non-U.S. government official must comply with the local laws and regulations that apply to the official. To determine which local laws and regulations apply to the official, you should contact any representative of Plexus Legal.

Facilitation or "Grease" Payments Generally Prohibited

Facilitation payments (sometimes called “grease payments”) are payments of small sums of money to expedite or secure the performance of a routine governmental action, such as the processing of a visa application. Facilitation or “grease” payments are prohibited unless approved in advance and in writing by a representative of Plexus Legal.

Questions & Guidance

For answers to questions or guidance relating to this Policy, contact your local human resources representative or any representative of Plexus Legal.

Reporting Concerns & Violations

If any employee suspects a violation of the law or this Policy, the employee must immediately raise the concern through the employee’s local human resources representative or any of the people named in the Plexus Code of Conduct and Business Ethics (the “Code of Conduct”); a copy of the Code of Conduct is posted on PRIDE. Alternatively, employees may report concerns via the Ethics Hotline (instructions posted on CONNECT and in the Code of Conduct).

Any violation of this Policy is grounds for immediate disciplinary action, including termination. A violation of this Policy may result in violations of legal requirements in the countries where Plexus conducts business. Substantial civil and criminal penalties, including fines and imprisonment, may be imposed for violations.