PURPOSE OF THE PROCEDURE

This procedure seeks to ensure that gifts and other hospitalities given or received by an employee in Eidos Partners (“Eidos Partners”) is not in violation with applicable laws and tax regulations or which is likely to influence the employees judgement or damage the reputation of Eidos Partners.

Each employee is responsible for complying with the guidelines set out in this procedure and that there is no risk of being suspected of having violated the guidelines.

Compliance is responsible for overseeing that the procedure is complied with.

When we refer to an amount in a specific currency in the following, this shall include an equivalent amount in a local currency and an equivalent value considering local conditions.

GENERAL CHECKLIST

These principles apply for all kind of business and hospitality:

• All expenses must be in compliance with applicable laws and internal guidelines.
• There must always be a proper business context when we offer or receive gifts or business hospitality and such gifts or business hospitality shall never be offered or received during tender or bidding process. During contract negotiations the employee should exercise particular caution and the cost for meals should, as the main rule, be shared with the counterpart.
• Meals, gifts and business hospitality must never be extravagant, and should be in line with customary business practices.
• You should never offer or receive any business hospitality or gifts that are inappropriate, illegal or may expose Eidos Partners to reputational damage.
• Cash or cash equivalents may never be offered, given or received.
• When assessing whether business hospitality offered to a particular recipient is appropriate, both value and frequency must be taken into consideration. With respect to value, this must also be assessed with respect to local conditions.
• Employees must always pay for travel and accommodation for their spouse, family members or friends.
• Employees should not, on their own behalf or on behalf of others, receive, accept, offer or give gifts, other additional benefits or advantages which is likely, or is intended, to influence the recipient’s duties in relation to their employment or performance of assignments.

 

FURTHER GUIDANCE

Gifts or business hospitality, in each case in accordance with the principles in section 2, may be approved by the employee within the limits set out below.

Gifts

• Private sector: Employees may give or receive a gift of a value in excess of euro 100 per gift or euro 500 cumulatively, with the prior written consent by the Chairman of the Board of Directors of Eidos Partners.
• Public sector: Gifts should not be given to public officials, unless:
• If the giving of ceremonial gifts is expected in connection with public holidays according to local tradition, provided that it is allowed under local laws and that the value is below euro 100.
• If bringing a gift to the leader of a delegation from a private company or a public office is expected under local traditions, provided that the value of the gift does not exceed 100 and that the exchange is transparent and takes place in an open meeting or at a corporate event.
• Under any circumstances advice on local laws should always be obtained before giving a gift to public officials.

 

Meals

• Private sector: Employees may host or accept a business lunch at a cost of up to euro 50 per person or a working dinner at a cost of up to euro 100 per person, without prior written consent.
• Employees may only host or accept invitation to a business lunch at a cost in excess of euro 50 per person or a working dinner at a cost in excess of euro 100 per person, with a prior written consent by the Chairman of the Board of Directors of Eidos Partners.
• Public sector: There must be a legitimate need for inviting a public official to a meal, for instance in connection with a visit to the offices of Eidos Partners, inspections, or a conference sponsored by Eidos Partners.

In addition, the business context criteria under section 2 above must be applied strictly in relation to public officials.

The same limitations on amount and other aspects as under the private sector will apply when a public official is invited to a meal.

 

Travel and expenses

Work related travel and accomodation shall be carried out in accordance with Eidos Partners’s travel and entertainment procedure.

Without the prior written consent by the Chairman of the Board of Directors of Eidos Partners, it is prohibited to have paid or pay for travel expenses for business partners or public officials, except for short distances by taxi for business purposes.

 

Entertainment

Employees cannot give, receive or participate at events, hereunder trips, that combine business and entertainment, without the prior written consent by the Chairman of the Board of Directors of Eidos Partners.

The criterion that the event must never be extravagant, inappropriate or appear to serve to cause an improper influence as specified under section 2 above must be taken into consideration. The extent of the professional content of the event may also influence whether an approval will be given.

 

REPORTING AND CONTROL

Gifts and hospitality shall immediately be reported to Compliance regardless of the value.

Compliance shall keep a register of gifts and hospitalities.

Each employee shall provide necessary information to Compliance on demand.