Q: Trish is facing various budget limitations at the end of the fiscal year. To defer recognizing an expense, she asks a supplier to bill our Company a few days late for the purchase of a costly piece of equipment. This way, she can record the purchase in the next fiscal year. The supplier will be paid and her department will meet its budget. Can she do this?
A: No, she must never delay or intentionally record incorrect, incomplete or misleading information about transactions.
Q: Chet is a Senior Account Manager in Sales. One of his customers is a small, rural store chain. The customer tells Chet that if they would buy all their laundry detergent from P&G at a good discount, the customer will drop all competing products and stock only P&G laundry. Can Chet agree to this proposal?
A: Maybe, but he would need to seek approval from Legal before making any form of agreement with the customer. None of us may enter into any agreements – whether verbal or written – that prohibit a customer from purchasing products from a P&G competitor without such approval. Doing so could be in violation of P&G policy and competition laws.
Q: For the launch of a new initiative, Stella proposes to give one very nice Swiss watch to the buyer at each customer. While she means for the customers to use the watches in charity raffles or the like, she knows the buyer will likely take the watch for personal use. Can she authorize this premium?
A: No, Stella can’t approve the premium for the initiative. P&G cannot pay for these expenses, since doing so might create the appearance of bribery.
Q: While planning a trip out of his home country on a P&G project, John urgently needs to obtain a visa for the country he is visiting. If he doesn’t secure it quickly, the deal he’s working on will likely fall through. The visa agency tells him that there will be a 2 day wait for the expedited service and a 2 week wait for the normal service. However, if they pay the desk officer $10 in cash, the visa can be issued immediately. Since it’s such a small amount, can John just authorize the agency to pay the money?
A: No, John can’t make or authorize any such payment, no matter how small it is. He would need to check if this is an official charge, that it will be paid to the Embassy and not an individual officer and that a receipt will be provided. If he cannot get this reassurance, he must wait until the visa can be obtained officially and must inform Legal about the request immediately.
Q. Through his position at P&G, Ned has knowledge that P&G is planning to enter into a contract with a small, publicly traded company that will be significant for that company. He knows he’s not allowed to trade based on this inside information, but is planning to tell his sister so that she can make some money in the stock market. Is this okay?
A. No. Ned can’t trade on the basis of this inside information himself, and he can’t provide it to his sister either. This is called “tipping” and is a violation of P&G policy and securities laws.
Q. The company that employs Hans’ wife was recently bought by one of P&G’s main competitors. Hans isn’t sure whether this matters, since his wife’s company will only be a subsidiary of our competitor. What should he do?
A. Having an immediate family member who works for a competitor poses a potential conflict of interest, and Hans should disclose the situation to his manager immediately. Reports should be made online at coi.pg.com and assistance can be provided by Human Resources. P&G will work to determine whether an actual conflict exists and, if so, what needs to be done to resolve the situation.
Q. Sally, an Account Manager, is offered four box seat tickets to a regular season soccer game by a customer with whom she works. General admission tickets are available. What should she do?
A. Accepting tickets, or any other gift, from a supplier or customer raises significant conflict of interest concerns. If the tickets to game are not associated with any business event (e.g., they are purely for Sally to use with her family or friends), she should graciously decline the tickets. If the tickets are for Sally and her co-workers so they can attend the game with representatives of the customer, then attending the event may have genuine business relationship-building value. Sally should consult with her manager – who must not also be attending – and review the requirements of P&G’s policy on External Party Gifts, Meals and Entertainment to determine what to do.