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Gifts and Entertainment

Employees or the immediate family of employees shall not use their position with Travelport to solicit any cash, gifts or free services from any Travelport customer, vendor or contractor for personal benefit. Gifts or entertainment from others should not be accepted if they could be reasonably considered to improperly or materially influence Travelport business relationship with or create an obligation to a customer, vendor or contractor.

Receiving

The following examples are guidelines regarding accepting gifts and entertainment:

• Nominal gifts and entertainment, such as logo items, pens, calendars, caps, shirts and mugs are acceptable.
• Reasonable invitation to business-related meetings, conventions, conferences or product-training seminars may be accepted.
• Invitations to social or cultural events may be accepted if the cost is reasonable and your attendance serves a customary business purpose such as networking.
• Invitations to sporting activities or ticketed events that are usual and customary in the conduct of business and promote good working relationships with customers and suppliers may be accepted.
  

Giving

Just as Travelport has rules for receiving gifts and entertainment, we must also be careful how we offer them. Offering social amenities or business courtesies of a nominal value such as modest gifts, meals and entertainment is common in the commercial world and is meant to create goodwill and enhance business relationships. Using good judgment and moderation, occasionally exchanging entertainment or gifts of nominal value with non-governmental individuals or entities is appropriate unless the recipient’s employer forbids the practice. Any social amenities or business courtesies must always comply with the policies of the recipient’s organization and applicable law.

Special gift giving rules may apply to employees involved in seeking business with or providing services to government entities, including entities controlled or owned by government entities (i.e., government-owned airlines). Contact the Office of the Chief Compliance & Ethics Officer or your business unit General Counsel, if applicable, for specific information and guidance on these rules.

For additional guidance on receiving or giving of gifts and entertainment, contact the Office of the Chief Compliance & Ethics Officer.