Financial Crime World

EJ Corporate Compliance Policy

Gifts, Meals, Entertainment, and Travel

At EJ, we strive to maintain positive business relationships with our customers, suppliers, and partners while adhering to the highest ethical standards. This policy outlines our guidelines for gifts, meals, entertainment, and travel to ensure that our interactions are professional, respectful, and compliant with applicable laws.

Gifts and Business Courtesies

  • Permissible Gift Values: Gifts or benefits valued at less than $100.00 are generally acceptable.
  • EJ Logo Gifts: Gifts bearing the EJ logo are encouraged.
  • Gift Acceptance Guidelines: Never accept a gift or benefit given in expectation of, or as a reward for, business or favorable official action.

Meals and Entertainment

  • Reasonable Business Expenses: Infrequent, reasonable meals or entertainment with customers, suppliers, or partners may be permissible for legitimate business purposes.
  • Managerial Approval: Always seek prior approval from your manager before offering to pay for travel expenses or meals/entertainment.

Travel

  • Business-Related Travel: Paid-for travel for business associates is acceptable only if directly related to a legitimate business purpose and approved by your manager in advance.
  • Travel as Incentive: Never provide a trip as a reward for obtaining or retaining business or as a reward for the award of previous business.

Third-Party Intermediaries

EJ partners with third-party intermediaries, including agents, brokers, distributors, professionals (lawyers/accountants), franchisees, consultants, and joint-venture partners. We must exercise caution when working with non-U.S. third parties to ensure compliance with anti-bribery and anti-corruption laws.

  • Selecting Third Parties: Select non-U.S. third parties solely on merit.
  • Prohibited Activities: Never retain a non-U.S. third party to perform prohibited activities.
  • Due Diligence: Conduct anti-bribery/anti-corruption due diligence and risk evaluation before retaining non-U.S. third parties in high or medium corruption risk countries.

Compliance Hotline and Company Contacts

We encourage all employees to report any evidence of policy violations, FCPA violations, or other anti-corruption law violations to their manager or the Office of Corporate Compliance. The Compliance Hotline is a toll-free, confidential service available 24/7 for reporting concerns.

  • Compliance Hotline Contact Information:

Remember, at EJ, we have a zero-tolerance policy for retaliation against anyone who reports concerns in good faith. All calls and online reports will be promptly investigated and reviewed at the EJ Corporate Headquarters.