Gifts and conflicts of interest

Customers and suppliers sometimes offer gifts or hospitality. This page summarises POL-HR-002. When in doubt, ask before you accept.

Gifts

Value of the gift What to do
Up to $100 You may accept it
Over $50 Record it in the gift register (even though you may accept it)
Over $100 Decline it politely, or hand it to HR

The gift register is kept by the General Counsel (Marcus Webb). Legal also has a separate rule, POL-LEG-004, which asks for gifts above $100 per person per year to be reported.

Conflicts of interest

A conflict of interest exists when a personal interest could affect, or look like it affects, your work decisions. Examples:

  • A close relative works for a customer or supplier you deal with.
  • You own shares in a supplier that Northwind is choosing.
  • You have a second job with a company that competes with Northwind.

You must declare a conflict within 10 working days of becoming aware of it. Tell your manager and the General Counsel's office. A declared conflict is not a problem in itself; an undeclared one is.

Cash and gift cards

Never accept cash or gift cards, whatever the amount.

Owner: Carol Nakamura - Last updated: 2026-09-18