Gifts and Entertainment

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Across
  1. 2. Keep accurate __________ of gifts and entertainment exchanges.
  2. 4. If you are offering a gift to this type of government official, be sure to check the gift’s monetary limits, which can be found on the Integrity and Compliance office website.
  3. 6. If you want to provide entertainment to a third party and its value exceeds $150 USD, you will need approval from this person.
  4. 7. Do not give one. Do not offer one.
  5. 12. Avoid this appearance when offering gifts or entertainment that might be perceived by others to be provided for an improper purpose.
  6. 13. Where Gifts and Entertainment principles can be found.
  7. 15. Generally, raffle prizes should not exceed this amount in USD without approval.
  8. 16. Gifts and entertainment, when modest and appropriate, help promote ________.
  9. 17. NetApp sponsored raffles must include NetApp Official ___________ authorized by Legal or ICO.
  10. 19. This is not so common, but must be used when determining gift value.
  11. 20. Generally, gifts should not exceed more than one ______ USD without approval.
  12. 21. Any third party with whom NetApp seeks to do business or that seeks to do business with NetApp.
  13. 27. The Gifts and Entertainment Policy applies to everyone who works at ________, including all directors, officers, and employees globally.
  14. 28. This type of interest can affect or appear to affect our objectivity in making decisions for our company and can arise in a variety of situations from personal relationships to financial investments.
  15. 29. If you are entering into a contract negotiation, this is a requirement.
  16. 31. If Melissa wants give a $150 USD concert ticket to Bob, who works for one of NetApp’s suppliers, this will likely not violate the gifts and entertainment policy as long as Melissa does this.
Down
  1. 1. This happens when anything of value is given directly to or from a third party in exchange for obtaining (or retaining) business or securing an improper advantage.
  2. 3. Not complying with these rules, poses a huge _____ for NetApp.
  3. 5. Be careful not to offer gifts or entertainment that might be perceived by others to be provided for an __________ purpose.
  4. 8. To obtain this, look at NetApp’s Travel & Expense Policy.
  5. 9. You should never give a gift to these people without reviewing NetApp’s policies and asking for approval from Legal or ICO.
  6. 10. You should never accept this if it is below-market from people doing business with NetApp.
  7. 11. When offering or accepting business-related gifts and entertainment to others, you must always use good _________ and good taste.
  8. 14. Complying with NetApp’s Gifts and Entertainment policy is important to ensure you do not violate the anti-bribery and anti-_______ laws.
  9. 18. Your spouse or life partner and any children or parents of both you and your spouse or life partner, as well as other relatives who share your home or otherwise are dependent on you or your spouse or life partner for support are considered this type of family.
  10. 22. One should always act with this and the best interests of NetApp.
  11. 23. Anything of value to the recipient provided or accepted from a representative of a NetApp business partner, any third party in conjunction with NetApp business, or a NetApp employee.
  12. 24. Any benefit provided by a NetApp employee to a third party, or by a third party to a NetApp employee, where the giver is present at the time of the event.
  13. 25. The Gifts and Entertainment Approval Form can be found on the ______ website.
  14. 26. Compliance with the law in not unnecessary, it is this.
  15. 30. A NetApp employee may never give or accept this as a gift.
  16. 32. Do not accept compensation or anything of value from these parties.