Business Entertainment

Business entertainment is any meal, sporting event, cultural event, or comparable activity that you and any other
business contact attend together or conferences or other business functions where fees, travel or accommodations
are paid by the business contact. Unsolicited business entertainment is permissible if it is for a legitimate business
purpose; not excessive in value; appropriate in nature; and given or accepted without an express or implied
obligation

Accepting or Giving Gifts Accepting or giving a gift in a business setting can create a sense of obligation
or the appearance of obligation. A gift can be anything of value, including such items as a ticket to a
sporting event or play, a non-business meal, a bottle of wine, a coffee cup, a free service, a special
discount, or an all-expenses-paid trip to a conference or trade show. Note: cash and cash equivalents
(e.g., gift cards) are not gifts; they are compensation and are taxable. You may not accept cash or a
cash equivalent as a gift. Also, you may not accept a payment or an item of value that could be construed
as a bribe, or become party to the payment of money or an item of value for the purpose of bribery.

Customary business meals generally are not considered gifts. These are routine meals of reasonable
cost provided for business contacts. However, a business meal for an elected or appointed governmental
official may be considered a gift under the laws governing the conduct of public officials. Before making
any gift to a federal, state, or local government official or employee, confirm its value and contact
Government Relations or email govrelpra@exchange.pge.com to ensure that the gift is in compliance
with applicable gift limits and restrictions.

A gift, including an in-kind gift, a contribution, a donation, entertainment, or another courtesy to a

political candidate, committee, governmental entity, public official, or elected or governmental figure
must be approved in advance by Government Relations

Both contracting authorities and tenderers are bound also by specific normative acts such as competition law, Law no.
161/2003 on measures to ensure transparency in the exercise of public dignities, public functions and business
environment, the prevention and punishment of corruption.

GEO no. 34/2006 provides the fundamental principles of the public procurement procedures, namely: non-discrimination, equal
treatment, transparency, mutual recognition, proportionality, efficient use of public funds and accountability.
The relevance of these principles resides in their creating the general legal framework for the awarding of public procurement
contracts. Moreover, according to the legislation, any situation for which there is no express regulation shall be interpreted
through these principles.

Transparency and accountability in matters of public finance must also be promoted, and
specific requirements are established for the prevention of corruption, in the particularly critical
areas of the public sector, such as the judiciary and public procurement. Those, who use public
services, must expect a high standard of conduct from their public servants

Do not provide, receive or exchange any of the

following types of information with a competitor or its
representative, whether in person, electronically or at an
industry meeting:
Prices.
Bids.
Customers, suppliers, sales territories or product lines.
Terms or conditions of sale.
Production, sales capacity or volume.
Costs, profits or margins.
Market share.
Sales, marketing or development strategies for
products or services.
Distribution methods

OUR POLICY

GE prohibits bribery in all business dealings, in every

country around the world, with both governments and the

private sector.

GE prohibits even small facilitation payments to expedite

routine administrative actions, except in extraordinary

circumstances and with the prior approval of a GE

compliance or business general counsel, or where an

employees safety or security is at stake. Our goal is to

eliminate all facilitation payments.

We maintain strong controls aimed at preventing and

detecting bribery. This includes a rigorous process for

appointing and managing third parties acting on GEs

behalf in business dealings.

We maintain accurate books, records, and accounts

that correctly reflect the true nature of all transactions.

YOUR ROLE Never offer, promise, make, or authorize a payment

or the giving of anything of value to anyone in order to

obtain an improper business advantage.

Remember that providing gifts, entertainment or

anything else of value to government employees

is highly regulated and often prohibited. Do not provide

such gifts and entertainment unless you have received

prior GE counsel approval.

RULE TO REMEMBER >> Do not permit or engage in bribery or corruption of any kind. Follow Corporate
and business guidelines regarding

gifts and entertainment and other business courtesies.

Never contribute Company funds or other GE assets

for political purposes without obtaining prior approval

from Corporate Government Affairs, a Company officer

or GE counsel, as applicable.

Follow your business due diligence procedures and

require that any third party representing GE be carefully

selected and comply with this policy.

Treat with extreme caution a demand from a third

party to receive its commission payment prior to

winning a deal/contract.

Be wary of any suggestion to direct GE business

through a specific representative or partner due to a

special relationship.

Be suspicious of any request to make a payment to

a person who is not related to the transaction being

discussed or a request that payments be made in

another country.
 Watch out for commissions that see

m too large in

relation to the services p

Do not accept gifts other than those of nominal value from suppliers, customers or competitors.