Gifts, Entertainment, and Gratuities

Conflict of Interest

Northeast Data, Inc.’s policy on conflict of interest is based on the principle that employees’ decisions must be made solely in the best interest of Northeast Data, Inc. and its clients. Employees should not be influenced by personal or family considerations that might affect their judgment.

Commercial Bribery

Personal payments or bribes to or from employees of Northeast Data, Inc. are strictly prohibited, regardless of legality in certain locations. Our business competition is conducted fairly and based on the merits of our products and services.

Gifts, Entertainment, Gratuities, and Spiffs

Northeast Data, Inc.’s policy on gifts, entertainment, and gratuities is designed to maintain integrity and ensure decisions are based on legitimate business considerations. Receiving gifts, entertainment, or other gratuities from business associates is not acceptable as it could imply an obligation and pose a conflict of interest.

Spiffs for sales of products should be turned over to Northeast Data, Inc. or applied to a customer order.

Additional Guidelines:

• Offering cash or cash equivalents (money orders, checks, gift certificates, loans, etc.) is strictly prohibited.
• Offering other types of gifts (entertainment, meals, travel, services, or other personal favors) by a vendor is discouraged. Business meals and entertainment are acceptable if they maintain an arms-length business relationship and do not influence business decisions.
• Employees shall not request free samples from vendors unless it is strictly for Northeast Data use as a sample of how an item is prior to ordering the item. (for example, coffee cups, lunch bags, or other promotional items.)

What to Do if Offered a Gift:

1. Decline Politely: If you are offered a gift, politely decline and explain that company policy prohibits accepting gifts.
2. Report the Offer: Inform your supervisor or the Human Resources Department about the offer. Provide details about the gift and the person who offered it.
3. Seek Guidance: If you are unsure whether a gift is acceptable, seek guidance from your supervisor or the Human Resources Department before accepting it.

Consequences for Violating This Policy:

• Disciplinary Action: Employees who violate this policy may face disciplinary action, which could include a warning, suspension, or termination of employment.
• Legal Action: In cases involving bribery or other illegal activities, the company may pursue legal action against the employee.
• Reimbursement: Employees may be required to return or reimburse the value of any unauthorized gifts or gratuities received.
• Loss of Trust: Violating this policy can damage the trust between the employee and the company, affecting future employment opportunities within the organization.

Note: Northeast Data, Inc. reserves the right to modify this policy at any time.