Code of Conduct

Gifts, Travel & Entertainment

Gifts and entertainment are a way to build business relationships. However, business should be won on the basis of merit, and gifts and entertainment should not be used in an attempt to influence the recipient.

Examples include:

  • Receiving a gift or entertainment from a vendor, supplier or customer
  • Receiving travel reimbursement from a vendor or supplier
  • Giving a gift or entertainment to a customer
  • Receiving honoraria for a speaking engagement

To avoid the appearance of inappropriately influencing the recipient, we use good judgment, honor both Convercent’s and the recipient’s gift policies, and avoid anything lavish or unusual that would likely embarrass the recipient, Convercent or our teammates. Likewise, we proceed with caution when accepting gifts and entertainment that could influence our objectivity in our business decisions. If you give or receive a gift, entertainment or other hospitality valued at more than $100, submit a conflict of interest disclosure form. See our conflict of interest policy for more information.

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We use active curiosity to understand and collaborate while respecting our differences.


A: You may accept occasional entertainment from customers and suppliers if the event is attended by the customer or the supplier, and the costs involved are in line with local custom for business-related entertainment. For example, general admission tickets to a local sporting event would generally be acceptable. If the value exceeds $100, you must disclose it through the conflict of interest disclosure form. An event with hard-to-come-by tickets, like the Superbowl, would not be ok.

A: If possible, thank them and politely decline. If returning the gift would offend the giver, you may accept the gift, but notify Ethics & Compliance. Ethics & Compliance will work with you to either donate the item to charity, or to distribute or raffle the item among a large group of employees. If it is an item that can be shared, like a gift basket, share it with your team or put it in a common area (like the kitchen) for everyone to enjoy.

A: It’s best to share items like a gift basket with your team or putting it in a common area for everyone to enjoy. However, if we are currently in negotiations with that vendor or in a dispute with them over a contractual matter, it might not be prudent to accept the gift. Any gift valued greater than $100 must be disclosed.

A: Gift cards and cash are not acceptable.

A: You may speak at the conference and they may cover your conference fees and/or travel fees, but you may not accept honoraria.