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Offering or receiving any gift, gratuity or entertainment that might be perceived to unfairly influence a
business relationship should be avoided. These guidelines apply at all times, and do not change during
traditional gift-giving seasons.
The value of gifts should be reasonable, both with respect to frequency and amount. Gifts that are
repetitive (no matter how small) may be perceived as an attempt to create an obligation to the giver and
are therefore inappropriate. Likewise, business entertainment should be moderately scaled and intended
only to facilitate business goals. Use good judgment. "Everyone else does it" is not sufficient justification.
If you are having difficulty determining whether a specific gift or entertainment item lies within the
bounds of acceptable business practice, ask yourself these guiding questions:
It is legal?
Is it clearly business related?
Is it moderate, reasonable, and in good taste?
Would public disclosure embarrass the Corporation?
Is there any pressure to reciprocate or grant special favours?
If you are unsure of the reasonableness of any gifts or hospitality, talk with your supervisor and the Chief
Executive Officer or Senior Vice President, Finance before receiving, offering or making any gifts or
hospitality. Furthermore, strict rules apply when we do business with governmental agencies and officials,
whether in Canada or in other countries, as discussed in more detail below. Because of the sensitive
nature of these relationships, talk with your supervisor and the Chief Executive Officer or Senior Vice
President, Finance before offering or making any gifts or hospitality to governmental employees.
XVII.
Community Engagement
ORLEN Upstream Canada is committed to creating lasting local value and we aim to create such value to
our local communities through our business activities. In our discussions and engagements with local
communities we seek to understand their expectations and explore opportunities for mutual benefits while
trying to avoid adversely impacting community members. Our contribution to communities may include
direct and indirect local employment, local procurement of goods and/or services, local infrastructure
development and capacity building as well as social investments.
Solutions must be relevant to our business needs and local conditions and comply with our values,
policies and local regulations.
XVIII.
Payments to Domestic and Foreign Officials
Directors, officers, employees, consultants, and non-employees must comply with all laws prohibiting
improper payments to domestic and foreign officials.
For example, in Canada, the
Corruption of Foreign Public Officials Act
(the "
Act
") provides that every
person commits an offence who, in order to obtain or retain an advantage in the course of business,
directly or indirectly gives, offers or agrees to give or offer a loan, reward, advantage or benefit of any
kind to a foreign public official or to any person for the benefit of a foreign public official as
consideration for an act or omission by the official in connection with the performance of the official's
