GUIDANCE
COMPLIANCEOPEDIA
PROCEDURE
All employees are required to
seek advance approval (to be
submitted 5 days prior to the date
on which the gift/hospitality
would be offered / accepted) if it:
Offering
gift/
hospitality
exceeding USD 20 to any
Government Official;
Offering
gift/
hospitality
exceeding USD 100 to any third
party; or
Accepting hospitality exceeding
USD 100 from any third party
including government officials.
GIFTS AND
HOSPITALITY
Gifts and hospitality are often a natural part of business
relations. When handled correctly, and in accordance
with the law and business ethics, gifts and hospitality
can demonstrate respect, appreciation, and good
etiquette while fostering goodwill and positive working
relationships. When such offering or acceptance is
made inappropriately it may expose compliance risks for
conflict of interest, or worse still, a breach of
anticorruption laws.
Gifts refer to anything of value
provided as a token in recognition
of a relationship, including
beautiful numbers that are
provided free of charge to
individuals
who
are
not
VimpelCom employees. VimpelCom Employees are permitted to:
Offer gifts/hospitality of a modest value directly
related to the promotion, demonstr ation or
explanation of the Company's products or services;
Receive hospitality of a modest value directly
related to the promotion, demonstration or
explanation of third parties’ products or services.
Hospitality refer to the provision
of travel accommodation and
lodging including an invitations or
entrance
provisions
to
entertainment focused events,
such as dinners, social, cultural
and/or sporting events. VimpelCom Employees are:
NOT PERMITTED to receive any gifts / branded gifts
/ promotional products , from any third party .
FORBIDDEN to offer or receive any form of cash or
cash equivalent i.e. gift vouchers, cheque, share or
share option to or from any third party. Page 5/10