As a U.S.-based company we are subject to restrictions on trading with some specific countries, individuals, or entities. We are also prohibited from activities related to certain other countries’, groups’ or customers’ attempts to implement boycotts, embargoes, or other trade restrictions, if those actions are incompatible with U.S. trade policies (for example, efforts by some to restrict or prohibit trade with Israel). We keep detailed policies (CMP 903 and CMP 919) and routinely updated listings (e.g., Denied Parties Listings) regarding the individuals and countries with whom we may not trade and regarding what boycott and embargo activities are prohibited. If you have any questions about trade and economic sanctions that may apply to your work, please contact the Law Department.

Gifts and Entertainment

Gifts can be anything of value, including goods, services, travel, lodging, and meals and entertainment, even when the giver is not present. Gift-giving practices vary around the world. Business gifts and entertainment are courtesies designed to build good working relationships with customers and business partners. Gifts are inappropriate, however, if they create an obligation or are given with an intent to improperly or corruptly influence a business decision.

Gifts are permitted generally if they are:

Nominal in value

Infrequent

Provided openly

Unsolicited

Not cash or cash equivalents (such as a loan, stock, or gift certificate)

Something that would be considered appropriate by an independent observer (e.g., we should not provide or pay for adult-sexually-oriented venues, services, or entertainment)

Legal in the local setting in which it is given and consistent with the policies of the other company

The standard maximum permissible threshold limit for gifts under Teradata policies (CMP 912) is USD $100 for gifts and USD $200 for entertainment. Lower limits may apply under departmental, local or team policies, rules, or local law (for example, those involved in procurement or entertainment of government officials or representatives of government wholly-owned or government partially-owned enterprises).

If you are offered a gift or entertainment that is not allowed or is over the amounts set forth in Teradata policies, you should politely explain that Teradata policies do not permit you to accept it. If you find yourself in a situation where refusing such a gift would embarrass or offend the person offering it, you may accept the gift on behalf of Teradata, and then report it immediately to your manager.

You should always respect the codes of conduct and policies of other companies. If a gift or entertainment is allowed under Teradata policy but prohibited by the recipient’s code or policy, you should not offer the gift. By far the most important things to remember are that you cannot offer, give, solicit, or receive anything that would compromise—or appear to compromise—the recipient’s ability to make objective business decisions, and that you must make sure gifts and entertainment are transparent to management and accurately reflected and disclosed in appropriate company documentation. Even if you were to use your own money or other resources to provide a gift or entertainment to a customer representative, you still would need to comply with these requirements.

When dealing with government customer representatives, you must be particularly cautious. Laws prohibit some government employees from receiving anything of value, even a modest lunch, a cup of coffee or a token item, such as a meal or promotional item bearing the Teradata logo.