Entertainment, Gifts, and Bribes (TI)

This pages contains a selection of advice from The Ethics Office at Texas Instruments Corporation.

The advice is that of either TI Ethics Director Carl Skooglund or Glenn Coleman, Manager of Ethics Communication and Education. The articles were distributed among TI employees via TNEWS.

Gifts, entertainment exchange with customers

Exchange of gifts with customers and suppliers

Perceptions

Perceptions-Part II

Perceptions-Part III

Article Number 3: Gifts, entertainment exchange with customers

The rules governing issues of gifts and entertainment vary greatly depending on whether the customer or supplier is the government or a commercial company. When dealing with our commercial (non-government) customers, some exchange of gifts and hospitalities is acceptable, but it presents many responsibilities and possible problems. Various types of entertainment and courtesy expenses are normal in the conduct of commercial business including meals, beverages and other forms of entertainment and hospitality.

A TIer may offer/accept them if

1. They are directly related to the conduct of TI business.
2. They are for the purpose of advancing a business relationship between TI and its customers and suppliers.
3. They are within the bounds of good taste, moderation and common sense.
4. They do not violate the laws or the regulations of the organization from which they are received or to which they are provided.

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Article Number 8: Exchange of gifts with customers and suppliers

For the past two months, this article has dealt with the philosophy and intent of TI policy regarding gifts and entertainment. Definite guidelines will help the TIer determine the acceptability and intent of these items. The following guidelines apply to the exchange of gifts with non-government suppliers and customers and will help the TIer determine propriety and acceptability

1. The TIer must understand the intentions behind the gift, for the exchange of gifts between supplier and customer has the potential of creating a feeling of obligation.
2. Any gift presentation must be conducted openly and publicly.
3. Use the eyebrow test to determine the gift's acceptability. Would it raise the eyebrows of your co-workers if they knew you had accepted the gift?
4. Would you feel uncomfortable or embarrassed if your co-workers knew of your gift?
5. Is the gift to be presented away from the workplace so others will not know of it?
6. Are you going to feel comfortable displaying your gift openly in your workplace?
7. No gifts to family members should ever be accepted.
8. If it feels wrong, simply do not do it.

Advertising or sales promotion gifts of small value that carry a company name or trademark are commonly exchanged and are generally acceptable. They would include such items as calendars, coffee cups, tablets, ball-point pens, appointment books, and small pocket calculators.

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Article Number 181: Perceptions

Sometimes situations are not what they first appear to be. We all have a responsibility to ask questions and raise issues.

Consider the following situations that were reported over the Ethics Office communication lines

1. A TI manager has his secretary order paper for his computer at home.
2. A TIer resigns from TI and comes back to work the following week as a consultant.
3. A blue-badge TIer parks in Authorized Parking and displays a yellow temporary badge on her dashboard...and she does it almost everyday.
4. A TIer plays golf with a major TI supplier every Saturday.
5. A TIer wins an award from a professional organization and accepts a free trip for his family to the award presentation.
6. A supplier fails to get TI business even though his is the lowest bid for the order
7. A secretary plays solitaire on her computer during work hours.

The situations above are typical of many issues brought to the Ethics Office and it is right, they should raise warning flags. Each should cause us to be concerned about whether we are doing the proper thing. Yet in every one of the particular cases, when the unique circumstances were examined, it was determined that there was nothing improper. There was nothing wrong. There were circumstances unknown to the observer that made the apparent violation appropriate for the situation. We will examine each of these situations over the next few weeks to highlight the issues.

So what are the problems? For every situation like the ones above, how many go unresolved? How many result in a TIer thinking that another is failing to meet the TI standards, is cheating the company or fellow employees, or simply is not doing what is right? How many relationships are damaged? How much trust and respect are improperly destroyed?

Remember this: A situation that is perceived as real will be reacted to as if it were real. Each of us has the obligation to consider how our actions will be received and, equally important, will be perceived. We must continually consider perceptions and be proactive in the elimination of misconceptions and their resulting rumors and grumblings.

Each of us has the right and obligation to question activities and to raise issues when others appear to be doing wrong. When we know the complete situation, perhaps it will be merely a matter of reception. But we should always check it out at the earliest opportunity. Allowing it to linger only damages relationships. TI is rich in sources of information. Your supervisor is generally the best place to raise these issues because your supervisor usually knows your situation better than anyone else. However, there are other good sources depending upon the issue: TI Human Resources, TI Legal, the open door to higher levels of your management, and your TI Ethics Office. It is important that you ask and continue asking until you are satisfied that you understand the situation.

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Article Number 183: Perceptions -- Part II

Some situations are not what they first appear to be. We must ask questions and collect facts before passing judgment. A situation that is perceived as real will be reacted to as if it were real. The article highlighted several situations that were reported over the Ethics Office communications lines. Although these situations looked very suspicious on first examination, further investigation revealed that the problem was in perception, not in reality. Let's reconsider these

1. A TI manager has his secretary order paper for his computer at home. Is this a case of improper use of company assets...or maybe theft? In this case, the manager had TI-authorized computer equipment at home where he accomplished much of his work. There are many problems and ethical issues created when we are allowed to work at home on TI-supported equipment, such as labor reporting, hardware maintenance and access to TI computer networks. As in this case, many of those problems result from the perception of others. Nevertheless, ordering computer support equipment and supplies and removing them from TI property was quite appropriate. The manager in this situation should have been more sensitive to the perception of others. The manager should have made it quite clear that the paper was for TI-authorized equipment at home, preventing the misperception with its accompanying loss of trust and respect.
2. A TIer resigns from TI and comes back to work the following week as a consultant. Normally, there must be one year between TIers leaving TI, either through resignation, termination, retirement or LOA, and their return as a supplier or consult. However, this moratorium can be reduced or removed if it is clearly detrimental to TI's interests. Specific information can be found in the procurement policy.
3. A blue badge TIer parks in authorized parking and displays a yellow temporary permit on her dashboard...and she does it almost everyday. TIers may be assigned temporary authorized parking permits if they make offsite business trips at least once a day for at least three days a week.
4. A TIer plays golf with a major TI supplier every Saturday. Socialization with suppliers can be beneficial to TI business...but there are many risks. Sporting events are a very visible situation and wrought with the possibilities of misperception. We rightfully restrict and, in some cases, prohibit the socialization between TIer and supplier if the socialization might improperly influence or appear to influence TI business decisions. Those TIers who might impact the procurement cycle may be more restricted than others. Since different parts and functions at TI might have their unique restrictions, contact your procurement management or your TI Ethics Office for more guidance if you are faced with this situation. If there is no business connection, generally there is no restriction. But perception is critical. Consider how other suppliers might perceive regular socialization.

The situations above are typical of many issues brought to the Ethics Office where there were circumstances unknown to the observer that made each apparent violation appropriate for the situation.

Remember, each of us has the right and obligation to question activities and to raise issues when others appear to be doing wrong. When we know the complete situation, perhaps it will be merely a matter of perception. But we should always check it out at the earliest opportunity. Allowing it to linger only damages relationships.

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Article Number 184: Perceptions -- Part III

A situation that is perceived as real will be reacted to as if it were real. In this series on perceptions, we examine situations that were reported over the Ethics Office communications lines. Although these situations looked very suspicious on first examination, further investigation reveals that the problem is in perception, not in reality.

Let's look at the rest

1. A TIer wins an award from a professional organization and accepts a free trip for his family to the award presentation. The caller in this situation fully understood that it is ethically unacceptable to accept such a gift from a supplier, but this situation is different. The TIer had won a prestigious national award from a professional organization that had no business affiliation with TI. There was no possibility that this gift could impact future TI business decisions. The TIer and his family were welcome to accept this gift and award.
2. A supplier fails to get TI business even though his is the lowest bid for the order. When TI selects a supplier, we look for the short and long-term lowest total cost -- not just price. Total cost of ownership (TCO) means that TI is value conscious, not just price conscious in our supplier selection decisions. In addition to normal TCO factors, TI may consider extraordinary or unique business situations.
3. A secretary plays solitaire on her computer during work hours. There are benefits to game playing. Many of the TI computer users are converting to the Windows environment with its built-in games. Users are properly encouraged to play the games to gain familiarity with the mouse. The question then becomes how much is enough. Guide lines for game playing should be established at the lowest possible level, either by the team or by local management and communicated to the work groups. TIers should not expect that each work group will have the same guidelines for game-playing and must understand that if they move to a new work group, it is their responsibility to learn and abide by the new guidelines.

In each situation above, there were circumstances unknown to the observer that made the apparent violation appropriate for the situation. But we must always remember that a situation that is perceived as real will be reacted to as real.

Each of us has the obligation to consider how our actions will be received and, equally as important, we must continually consider perceptions and be proactive in the elimination of misconceptions and their resulting rumors and grumblings.

Each of us has the right and obligation to question activities and to raise issues when others appear to be doing wrong. When we know the complete situation, perhaps it will be merely a matter of perception. But we should always check it out at the earliest opportunity. Allowing it to linger only damages relationships.

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