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Gifts and Entertainment Policy

Policy Application

Target is committed to ensuring our working relationship with all suppliers and business partners is based on high business ethics and integrity.

The Company fully supports the development and transparency of professional relationships between our team members and our suppliers, but in doing so we must ensure that a high standard of integrity is maintained.

Purpose

For the purpose of this policy, supplier or business partner includes any existing or potential supplier of goods or services to Target and includes agents or contractors.

This policy applies to all team members, contractors and consultants to Target Australia Pty Ltd and any of its subsidiaries. In this policy the term team member includes all these groups.

Any breaches of this policy will be treated as serious misconduct and will result in disciplinary action being taken, which could include termination of employment.

Gifts

Target has a ‘No Gifts’ policy, which demonstrates our high standard of business ethics and integrity to our suppliers and business partners.

A ‘gift’ is any item or service designed to promote the supplier offering the item, and includes but is not limited to, cash, services, merchandise or promotional items outside routine sales transactions, from a customer, agent, contractor, supplier or business partner.

Line Managers must be advised of all gifts received.

Team members should actively promote the Company’s ‘No Gifts’ policy to suppliers, agents and contractors to avoid any embarrassment by using the Gift Advice Letter 1008.

Any team member who receives a gift must return the gift to the sender thanking them and advising them of the Company’s ‘No Gifts’ policy using the Gift Return Letter 1009.

Where it is impractical, or difficult to return a gift without offending or incurring disproportionate costs in doing so, then the following rules apply:

  • The gift must be donated to charity or shared amongst team members at line manager’s discretion
  • Under no circumstances can these items benefit the individual team member who was the recipient of the gift

Promotional Samples

Gifts do not include samples that are provided for the purposes of assessing a product’s suitability for sale.

Appropriate management of samples in line with the principles of this policy is the responsibility of line managers.

Samples and giveaways as a promotional activity to team members are allowed when organised as an approved event.

Receiving donations from suppliers for personal fundraising efforts is a breach of the gifts policy.

Supplier Funded Events & Entertainment

Events and Entertainment includes offers associated with meals, drinks, sporting events, tradeshows and entertainment functions.

Offers may only be accepted where there is a business purpose, and where an existing business relationship exists and the supplier is hosting the event.

The following rules apply for attendance at events or the acceptance of entertainment:

  • Any event or entertainment must be approved in advance by the relevant General Manager
  • Any entertainment >$1,000 must be approved in advance by the Managing Director
  • No entertainment is to be accepted in working hours – ie team member must take leave.
  • The conduct of team members accepting entertainment must be commensurate with the standard of behaviour and conduct expected by a person representing Target
  • Offers of complimentary travel and accommodation cannot be accepted
  • Under no circumstances are team members to accept cash or cash equivalents from third parties

It is not entertainment where the primary purpose of the function attended is a professional, technical or business topic (e.g. technical accounting breakfast briefing, business key note speaker including lunch or dinner, etc), however, line manager approval is still required in advance.

Events & Entertainment Register

To ensure total transparency, each General Manager must maintain an ongoing list of invitations received and approvals they have given to attend events or entertainment on an Events & Entertainment Register.

Contract Renegotiation or Tender

If a contract is being re-negotiated or re-tendered, line managers should not approve acceptance of any invitations for events from the existing supplier, or potential supplier, during a period of four months prior to cessation of a supplier’s contract.

Following the awarding of a contract, gifts and events are subject to the standard conditions outlined in this policy.

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