No
Bribery

Bribery not only harms P&G, but also the communities where we do business. We prohibit bribes to government officials and employees everywhere we do business. Most countries have strict laws against bribery and it is important to remember that engaging in bribery, or even appearing to engage in such activity, can expose us to criminal liability.

• You must never offer or pay a bribe. Bribery includes more than cash payments.
• Gifts, travel and entertainment, and offers of employment for government officials, employees or their families might be perceived as bribery and must be carefully reviewed.
• Even donations to charity, when given at the request of, or in hopes of influencing, a government official can be considered bribery.
• It is also important to know that a “government official” could include people like doctors or nurses at government-run hospitals, teachers or administrators at public schools or universities, or buyers for government-owned stores.
• Special rules also apply to interactions with healthcare professionals, who may also be considered a government official.

Besides bribery, P&G also prohibits “facilitating payments,” which are small payments to individual officials to secure or speed up routine government actions.

• Expediting payments, such as speeding up a passport renewal, which are permitted under applicable law and made to the agency itself (not to an individual) are not facilitating payments.
• You must never offer or pay a facilitating payment unless you have received prior written authorization from the Ethics & Compliance Committee.
• Any payments made to assure the immediate personal safety of an individual would not be considered a violation of our WBCM, but must be reported immediately to the Ethics & Compliance Office.

In addition to not giving or offering bribes or facilitating payments to government officials, you must never allow an external party to do so on P&G’s behalf, or enter into any transaction where you suspect an external party is engaging in bribery.

• You should also be aware of “red flags” (for example, cash payments, payments without supporting documentation, payments in another party’s name) that suggest the possibility of bribes or payments by someone at P&G or an external party with whom we do business and report them to the Ethics & Compliance Office or Legal.

You must never make supplier, customer or other business decisions based on any personal benefit given or offered to you.

• In particular, you must not solicit or accept bribes or kickbacks from anyone who does or is seeking to do business with P&G.
• You must never offer or give any bribes or kickbacks to any supplier, customer or other external party.
• Keep these principles in mind when offering or receiving any form of gifts or entertainment.