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. We must not give or accept any gifts or entertainment that could raise 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 must 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. Lavish or inappropriate gifts or entertainment are strictly prohibited.

Accepting Gifts & Entertainment.

  • Demanding or soliciting gifts or entertainment of any kind is prohibited. This includes not only items 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.

 

There are more stringent rules concerning gifts and entertainment provided to certain groups and persons, for example healthcare professionals (HCPs), healthcare organisations (HCOs) and patient organisations (POs).

If in doubt about the appropriateness of accepting an unsolicited gift or entertainment, you must consult your Line Manager.

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 if in doubt.
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.

Further Informations

Further information and guidance can be found on the Roche Internet and Intranet. For specific information consult the Roche Directive on Integrity in Business.