SBIC Code of Business Ethics and Conduct
| Relations with Business Partners | ||
| Keys to Compliance | Striving to maintain straightforward business relationships with our qualified member school entities and business partners should be everyone's goal. These relationships should be based on the quality and cost of the services and goods, rather than on personal relationships. We shall not take unfair advantage of these relationships though manipulation, coercion, or misrepresentation of information. | |
| Gifts and entertainment | You and family members should not accept gifts or paid-for entertainment or other favors unless they are considered of nominal value. Offering or receiving any gift, gratuity, or entertainment, other than those of a nominal value that could be perceived to unfairly influence a business decision must be avoided. |
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| Expense reimbursement and loans from business partners | Reimbursement of your travel or business related expenses are prohibited. An occasional business lunch or dinner is permitted. Never accept loans or other personal services from suppliers, they are prohibited. |
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| Kickbacks | No employee may not offer, give, request, receive or participate in any way in the payment of a "kickback" or other improper payment to influence a business decision. Any employee who becomes aware of the payment of a kickback or other improper payment in connection with the Company's business must immediately inform Senior Management or use the confidential Fraud Hot Line. | |
| Question: A vendor continuously provides me with nominal gifts. Is this appropriate? | Answer: Generally the answer is no, as a repetitive gifts is perceived to be an attempt to create an obligation to the giver and are therefore inappropriate. |
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| Question: Ask yourself if a gift you received is being provided because your position enables you to influence a decision in favor of the business partner | Answer: If you answered "yes", then declining the gift may be the appropriate answer. Because each offering is different, your decision should be evaluated on a case-by-case basis. |
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