Gifts & Entertainment

We neither give nor accept gifts or entertainment that could raise concerns about our personal integrity

Even when gifts or entertainment are exchanged out of the purest motives of personal or professional friendship, they can be misunderstood and perceived as an improper advantage to create influence.

We must not give or accept any gifts or entertainment that could raise any concerns regarding our personal integrity or Roche’s integrity and independence.

To avoid both the reality and the perception of improper relations with existing or potential business partners, both public and private, Roche employees should adhere to the following principles:

Giving Gifts & Entertainment

  • Gifts or entertainment may be given only where appropriate and where there is no risk of creating the perception of influencing the recipient in his/her decision.
  • Gifts must be of minimal value and entertainment must not go beyond what is reasonable. Expenditures for lavish or inappropriate gifts or entertainment are strictly prohibited.

Receiving Gifts & Entertainment

  • Demanding or soliciting gifts or entertainment of any kind is prohibited. This includes not only merchandise but all kinds of advantages.
  • Unsolicited gifts or entertainment may only be accepted if they do not go beyond common courtesy and are an accepted local business practice.
  • Offers of entertainment may only be accepted if they arise out of the normal course of business, cannot be seen as lavish and take place in settings that are appropriate.

If in doubt about the appropriateness of accepting an unsolicited gift or entertainment, we must consult our Line Manager and act according to his/her decision.

We are all expected to:
  • Make sure that the giving and acceptance of any gifts or entertainment does not raise any concern regarding our personal integrity and Roche’s integrity and independence.
  • Never solicit gifts or entertainment from any existing or potential business partners of Roche.
  • Contact our Line Manager and act according to his/her decision, if in doubt about the appropriateness of accepting an unsolicited gift or entertainment.
Questions & Answers

A key Roche customer is having a dinner party to celebrate his company’s 50th anniversary. Other important business people and government officials will be there. I have been invited. Am I allowed to accept the invitation?

Yes, provided you are invited as a Roche representative and your Line Manager is in agreement.

A key Roche supplier has invited my wife and me for a golf weekend as a thank-you to a long-standing customer. May I accept?

No. Accepting the invitation could compromise your and Roche’s integrity and independence, especially as the invitation appears to be lavish and is extended to a family member who is unrelated to the business.

I have been working with a service provider for months and have finally reached the conclusion of the project. The service provider is now in town and asks me if I would like to go out for dinner with him as his guest, in the spirit of maintaining a good business relationship. May I accept the invitation?

Yes, provided that it is a modest dinner and you can maintain personal and company integrity and independence. Unsolicited gifts or entertainment may be accepted provided they do not go beyond common courtesy and are an accepted local business practice. The value and frequency must not raise any suspicion of an obligation on the part of the recipient. The offer of any advantage that does not meet these conditions must be rejected.

Further Informations