15
CODE OF CONDUCT
BUSINESS
COURTESIES
Giving or accepting gifts, meals, travel,
entertainment, favors or other items of
value (“business courtesies”) is often a part
of building business relationships. However,
these business courtesies can also improperly
influence our business decisions, and they
can create the appearance of impropriety.
Never give or accept a business courtesy
that could influence your judgment on
behalf of Hilton. And use good judgment
to avoid even the perception that any
business courtesy has influenced or is
intended to influence business judgment.
Generally speaking, you may accept or oer
business courtesies so long as they are:
• Legal;
• Customary and commonly accepted;
• Intended to promote successful working
relationships with persons or firms
with whom Hilton maintains or may
establish a business relationship;
• Not excessive in value;
• Appropriate for the job
function of the recipient;
• Not associated with purchasing, procurement
or contracting decisions; and,
• Given and accepted without an express or
implied understanding that the recipient is in
any way obligated by acceptance of the gift.
Entertainment or gifts that are extravagant
in value or exclusive in nature (such as
Super Bowl, Golf Masters or World Cup
tickets) should not be accepted without
prior approval from the Legal Compliance
Team in consultation with management to
carefully consider the nature of the business
relationship with the entity/individual making
the oer and the business role of the Hilton
recipient. In general, Hilton should be solely
responsible for the travel and lodging expenses
associated with these exclusive events.
Stricter standards apply to business courtesies
when they involve government ocials. Hilton
Team Members may never oer, promise,
pay or authorize anything of value to a
government ocial or state owned entity
unless permitted to do so by Hilton policies.
For additional information on Hilton’s policies
regarding business courtesies to government
ocials, see the section of this Code regarding
Bribery and Other Corrupt Practices below.
Team Members must never request gifts or
solicit favors from business partners. When
excessive gifts are received, the item must
be returned with a clear explanation that
the gift violates Hilton’s business courtesies
policy. If you are concerned that refusing or
returning a gift that violates Hilton’s policies
may cause oense, you should consult
the Legal Compliance Team for guidance.
It may be appropriate for the item to be
donated to a charity or displayed at a Hilton
site. Hilton encourages Team Members
to share consumable gifts that meet the
“reasonable and not excessive” standard (such
as food baskets) in a common work area.
Team Members may never accept oers of
expense-paid trips for pleasure from persons
or firms that Hilton does or seeks to do
business with. Hilton business trips are just
that: trips intended to conduct Hilton business
or develop Hilton business relationships.
As a result, only Hilton should pay for
the travel and lodging expenses of
Team Members while on Hilton business
with the following exceptions:
• Travel incident to the business event, such
as transportation between meeting sites.
• Travel and lodging in connection with an
industry event, professional association,
or similar occasion where the organizer
is not a business partner of Hilton.
• Travel and lodging oered to a Team
Member as a presenter at a conference
where all presenters are oered the
same as a matter of course.
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