1. When does a gift become a bribe?
Ethical Spotlight December 2018

2. Introduction
With the Christmas around the corner, it is a good time to make sure our rules on Gifts, Hospitality and Expenses (GHE) are effective and understood.
The exchange of reasonable GHE can build goodwill in business relationships.
But the offer or receipt of GHE is prohibited if not reasonable, or could inappropriately affect the outcome of a business transaction.
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3. Gift or a bribe?
A bribe is an offer or receipt of any money, gift, loan, fee, reward or other advantage to or from any person as an inducement to act, or omit to act, in a way which is dishonest, illegal or a breach of trust.
A gift is something of value, either goods or services, that is given without the expectation of return.
Because it is often hard to determine the expectations of the giver, we have very clear instructions on Gifts, Hospitality and Entertainment in our Business Practice Policy (chapter 7) for us to follow.
The Business Practice Policy is also available in the Do What’s Right app, always conveniently available.
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4. Basic rules on GHE DO’S – All GHE must be:
reasonable in value and infrequent
made in an open and transparent manner
related to a legitimate business purpose
DON’T’S – GHE can never:
be intended to improperly influence or affect the outcome of a business transaction
create an appearance that the giver is entitled to preferential treatment
be made to a business partner with whom you are in ongoing business negotiations
be in cash or a cash equivalent (such as gift cards)
Any GHE that cannot be accepted, must be returned to the giver.
You should always apply the “Blush Test” by asking yourself this hypothetical question before providing or accepting GHE:
“Would I be perfectly comfortable if the facts of this Gift or Hospitality were scrutinized by the CEO, was known by my colleagues or made public in a trade magazine or local newspaper?”
If the response to this question is anything other than “perfectly comfortable” then you should immediately reconsider the situation.
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5. GHE Controls Receiver Form Value Control Private sector Any
Over 200 EUR / person
Pre-approval from line manager
Customer Event
Over 750 EUR / person
Pre-approval from Division Head
Over 1,500 EUR / person
Not allowed
Spouse
Public Officials
Any (except very low level)
Pre-approval from Ethics and Compliance
Remember: Just because it is below the threshold, it doesn’t automatically mean it is ok

6. Stricter rules on some groups of employees
Stricter rules on certain groups of employees were implemented earlier in the year.
The members who the stricter rules apply to are members of:
Group Leadership Team; ​
Division Leadership Team; ​
Group Function Leadership Team; ​
Division Operation Leadership Team; and​
Mill Management Team. 
Also - an employee who is in a position that could affect the result of a sourcing task is also bound by these rules during the sourcing process after receiving separate instruction(s) on an ad hoc basis. 
The stricter rules stipulate:
No member of the above mentioned organizations shall accept any Gifts, Hospitality, Expenses or any other positive special treatment from suppliers.​
In general, keep supplier meetings to normal work hours; ​
Travelling and hotel costs of Stora Enso employees are always paid by Stora Enso; ​
Gifts are returned politely but firmly; ​
Only participate in supplier events with direct business agenda and with interest for Stora Enso. Moderate catering during such events is acceptable; ​
We cover our own costs at business lunches, or keep the business relationship equal through paying every other time; ​
Suppliers should not sponsor any Stora Enso organized activities. 
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7. Stricter rules on some groups of employees
In practice, what types of GHE offered by suppliers are no longer acceptable for the targeted Stora Enso representatives under the new rules comparing with the general rules in the Business Practice Policy?​
Events without a direct business agenda with interest for Stora Enso, for example a stand alone cocktail party without business content.​
Business entertainment such as sports games, concerts, hunting, golfing etc, even though in connection with a business event. ​
Gifts - for example fruit baskets, wine bottles, gift cards etc. Company giveaways with very low value, for example a pen or a note book is ok.
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8. Discuss in your teams
Do you receive gifts from suppliers, customers etc?
Have you ever felt uncomfortable when receiving them?
Do you know the internal rules on GHE and where to find them?
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