BUSINESS GIFTS POLICY

POLICIES AND PROCEDURES FOR NORTH AMERICA

I. INTRODUCTION
Saint-Gobain is committed to the lawful and ethical operation of its businesses. The Company
recognizes that the giving and receiving of business gifts is a customary practice that serves to
strengthen working relationships, provided the gifts are of a nominal value.
This policy has been developed to provide guidelines on the giving and receiving of business
gifts and applies to all employees of Saint-Gobain in North America. If you are ever unsure about
whether a gift is acceptable, please contact Saint-Gobains Vice President of Business Practices
and Compliance Programs or the General Counsel of the Company.

II. POLICY
For the purpose of this policy, a gift is defined as an object offered for no payment, an offer of
accommodation or a meal invitation, or any benefit enjoyed by the beneficiary for free and
which has a monetary value. Giving a gift must be a gesture of pure courtesy as part of normal
business relations. The giving or receiving of gifts must always fall within a purely professional
scope.
Gifts may only be accepted if sent to the employees professional address and if their value is
token in nature (not to exceed US$25) and with limited frequency (i.e., no more than once per
quarter). Business units or Delegation/SSC departments involved in purchasing goods or
services are encouraged to set more restrictive limits. Employees in the North American
Purchasing group (including anyone with purchasing responsibilities within the Delegation, SSC
or the business units) are required to follow the Gifts Rules for Saint-Gobain North America
Purchasing Functions, available on the Company intranet at http://portal.saintgobain.com/wps/portal/usacanada under the Purchasing Guidelines section.
This policy applies to all gifts that may be given to third-party external partners, such as
customers, suppliers or service providers, as well as those received by employees of the
Company from third parties.
This policy is designed to avoid the risk of:
creating a conflict of interest, for example when the value of the gift (monetary or
otherwise) is such that the recipient may not act in sole consideration of the interests
of his or her employer;
obligating or influencing the beneficiary;
damaging the image of the Company.

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For additional information, please refer to the Conflict of Interest Guidelines section of the Code
of Ethics and Business Conduct Guidelines and the examples in Appendix B, available on the
Company intranet at http://portal.saint-gobain.com/wps/portal/usacanada under the Business
Practices and Compliance section.

A.

Giving Gifts to a Third Party (outside the Company)

The giving of gifts to a third party, such as a customer or prospective customer of the Company,
must always be given in appropriate circumstances and with a valid business purpose. Examples
include a sales call, business meeting, trade show, convention, company event (such as a
product launch or new plant opening), or a holiday or charitable event.
1.

Prohibited Gifts
a.

Giving sums of money, gift cards or other cash equivalents

Exceptions: product rebates, free product, transactional incentives, or
rebate/promotional gift cards given under a program approved by the
business unit (that complies with applicable tax reporting requirements
and provides for adequate controls of the card inventory).

b.

Gifts to elected officials or public servants

Require the prior express approval of the Division President and either
the Vice President of Business Practices and Compliance Programs or the
General Counsel of the Company;
Must be in compliance with any applicable campaign laws and/or
practices.

NOTE: Gifts from one Saint-Gobain business or affiliate to an employee of another

Saint-Gobain business or affiliate are prohibited as they are unnecessary and serve
no valid business purpose.
2.

Permitted Gifts
a.

Company-branded/promotional items, provided:

The value of the item is appropriate with the business purpose;
The item is chosen by the business units communication or marketing
group (or some other dedicated group identified by the business unit) and
purchased in compliance with applicable purchasing procedures;

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The item is distributed according to objective criteria established by the

business unit; and
The giving of such gifts must be limited to persons directly involved in a
business relationship with the company (or with whom we might have a
business relationship).

b.

Non-branded items as gifts, provided:

The value of the item does not exceed US$25; and
The item is given on the occasion of a special event, such as a product
launch, trade show or other Company-sanctioned event.

c.

Invitations to events such as business meals, site tours, sporting or cultural

events, trade events, etc., provided:
The invitation is justified on professional grounds and part of the normal
course of business;
The overall cost of the event or entertainment (i.e., food, lodging,
transportation, registration fee, etc.) does not exceed US$500 per invited
guest and is considered reasonable (neither lavish nor extravagant) under
the business circumstances;
NOTE: Invitations to a major or exclusive event such as the
Masters, Super Bowl, World Series, Daytona 500, or Kentucky
Derby, could be considered lavish or extravagant in many cases
depending upon the nature of the event, the business purpose and
the numbers and type of customers being entertained at such an
event. Therefore, no employees of the company are authorized to
purchase tickets or otherwise organize such an event without the
prior approval of the business units senior officer in North
America (which for most business units would be their designated
member of the North American Executive Committee).
Payment of accommodations or travel expenses on behalf of a third party
(e.g., customers or others) may only be made if related to a clearly
identified operation, such as a site tour, training course, etc., and limited
to the duration of the event/operation (this can be interpreted to cover
sales calls and customer entertainment provided it is reasonable and
neither lavish nor extravagant);
The invitation must not be aimed at, or result in, the recipient being
obligated to the gift-giver or influenced by it;
NOTE: Invitations to business meals and entertainment must comply with the
definitions and restrictions of business meals and entertainment as set forth in
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the Saint-Gobain Corporation Corporate Expense Card Policy, Section 7.0,
available on the Company intranet at http://portal.saintgobain.com/wps/portal/usacanada under the TECC section.
Any exceptions to the rules and requirements for giving of gifts to third parties must have the
prior express approval of the Division President and either the Vice President of Business
Practices and Compliance Programs or the General Counsel of the Company.
B.

Gifts Received from a Third Party

1. Gifts received from a third party such as a vendor, prospective vendor or customer,
may be accepted in appropriate circumstances with a valid business purpose. Examples
include a sales call, business meeting, trade show, convention, company event (such as
a product launch or new plant opening), or a holiday or charitable event.
2.

Receiving sums of money or cash equivalents is strictly prohibited.

No gifts may be accepted in cash or anything convertible into cash such as a gift
card.
NOTE: Gifts by the Company to employees are covered under the Controllers
Bulletin, Business Gifts For Employees, available on the Company intranet at
http://portal.saint-gobain.com/wps/portal/usacanada.

3.

In general, all gifts received (with the exception of branded/promotional items,

business meals and entertainment) must be pooled and shared between members of
the recipients department or work area; otherwise, they should be given to a social
organization or a charity.
Any gift (excluding branded/promotional objects as previously noted) that is
not pooled and shared or given to a social organization or a charity should be
disclosed to the Division President, a Vice President of the department (in the
case of Delegation/SSC employees), or the CEO (in the case of corporate Vice
Presidents) and either the Vice President of Business Practices and Compliance
Programs or the General Counsel of the Company.
Invitations to business meals and entertainment must be ordinary and
reasonable for the business purpose, be neither lavish nor extravagant, and be
compliant with section 7.6.3 of the Saint-Gobain Corporation Corporate
Expense Card Policy.

4.

Gifts may never be solicited for any reason whatsoever. It is strictly forbidden for any
Company employee to ask for a gift or other favor from any person, company or
organization.

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5.

No gifts may be accepted from potential suppliers or service providers if a request for
proposal is about to be or has been launched or during open negotiations of
contracts or services.

6.

All agreements with vendors are required to contain a contract clause provision
specifically stating that they are not to give gifts to employees of the Company
(please reference the General Contacts area of the Forms section of the Law
Department on the Company intranet at http://portal.saintgobain.com/wps/portal/usacanada for an example of the No Gifts Policy provision
for vendors).

7.

Acceptance of invitations to events such sporting or cultural events and/or other

forms of entertainment is only acceptable under the following provisions:
The invitation is justified on professional grounds and by a business purpose
(i.e., must be considered usual and customary and neither lavish nor
extravagant under the business circumstances);
The employees supervisor must authorize the acceptance of the invitation in
advance.
If the total value of the event is greater than US$500 per invited employee,
then express prior approval of both the Division President (or the Vice
President of the department in the case of Delegation/SSC employees) and
either the Vice President of Business Practices and Compliance Programs or the
General Counsel of the Company is required.
Business units or Delegation/SSC departments involved in purchasing goods or
services are encouraged to set more restrictive limits as deemed appropriate.
NOTE: North American Purchasing Departments (and any related employees) may
never accept such invitations (please refer to the Gifts Rules for Saint-Gobain North
America Purchasing Functions, available on the Company intranet at
http://portal.saint-gobain.com/wps/portal/usacanada under the Purchasing
Guidelines section).

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III. FREQUENTLY ASKED QUESTIONS (FAQs)

1. FAQs Giving Gifts to a Third Party (i.e., outside the Company)

I typically hand out $5.00 Starbucks gift cards to customers at our yearly
tradeshows. Is this okay?
No, as a matter of policy, the giving of gift cards or other cash equivalent benefits to
third parties is strictly prohibited; the exception being rebate/promotional gift cards
for which the business unit has sanctioned a specific program and controls the card
inventory.

What types of gifts are acceptable to give out at tradeshows or customer events?
Company-branded/promotional items chosen by the business units communication
or marketing group are acceptable as gifts as are non-branded items provided the
value of the item does not exceed US$25.

I was invited to the wedding of a customers son. Will the business pay for the
wedding gift?
Although the invitation may be related to the relative of a customer, the nature of
such an event has no discernable business purpose. Any such gift would be a personal
gift from the attendee and would not be reimbursable by the business.

I dont like the selection of promotional items that are available through our
employee store. Can I have the company logo placed on an item I would like to
order through an outside vendor?
Items that are selected to have the company logo placed on them should be vetted
with the business units communication or marketing group prior to the
purchasing/production of any such items.

I would like to give my customer a holiday gift. Is this reimbursable?

The giving of a gift to a customer on the occasion of a traditional festivity (such as a
holiday gift) is permissible provided the gift is not money, gift cards or other cash
equivalent benefits and the value of the gift does not exceed US$25.

Each year, we take customers to the Masters Golf Tournament. We purchase the
tickets, lodging, and airfare for these customers. Can we continue to do this?
Yes, however, this type of event requires the prior approval of the business units senior
officer in North America (which for most business units would be their designated member of
the North American Executive Committee).

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Can I raffle items such as iPods, iPads, Kindles, or televisions at tradeshows?

Non-branded items as gifts are permissible for product launches, trade shows or
other Company sanctioned events provided the value does not exceed US$25. Items
such as iPods, iPads, Kindles, televisions, etc. are considerably in excess of the
permissible value limit. In order to be able to utilize such items in a raffle one would
need to get the prior express approval of the Division President and either the Vice
President Business Practices and Compliance Programs or the General Counsel of the
Company.

2. FAQs Gifts Received from a Third Party

During the holidays, a manager received a large gift basket from a vendor. Can this
basket be raffled to an onsite employee?
No. Gifts received (with the exception of branded/promotional items) must be pooled
and shared between members of the recipients department or work area. In the
event pooling/sharing is not possible due to the nature of the gift, the gift must be
donated to a social organization or charity.

I was invited to go fishing in Canada by a customer. The customer offered to fly me

to the event in their private jet. Is this acceptable?
Acceptance of such an invitation is permissible only if justified by a valid business
purpose and the event is considered usual and customary and is not lavish or
extravagant. The Company deems any invitation of travel on a private jet to fall
under the category of lavish and/or extravagant and therefore such an invite would
not be acceptable under the circumstances.

What do I do if a supplier sends me a gift card as a gift?

Receipt of gift cards from a third party is strictly prohibited. In the event a gift card is
received the employee receiving the gift card should return it and explain that such
gifts are not acceptable per the provisions of the Companys gift policy. If return of
the gift card is not possible, the employee should seek instructions for how to handle
the gift card from the Vice President of Business Practices and Compliance Programs.

I suspect a co-worker of mine is accepting inappropriate gifts. What should I do?

As with all compliance-related issues, if an employee suspects that a co-worker is
violating the gift policy it should be brought to the attention of the Vice President
Business Practices and Compliance Programs directly or communicated through the
Companys confidential compliance hotline (1-800-548-2088).

I received an iPad in the mail at my home from XYZ Company. What should I do?
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All gifts received from third parties must be received at the employees professional
address and must not exceed US$25 in value. The receipt of an iPad at ones home
address would not be permissible. In the event such a gift is received at ones address
the employee receiving the gift should return it and explain that such gifts are not
acceptable per the provisions of the Companys gift policy. If return of the gift is not
possible, the employee should seek instructions for how to handle the gift from the
Vice President of Business Practices and Compliance Programs.

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