Gifts and Entertainment: A Toolkit for Managers Page 2: What are Gifts and Entertainment? Page 3: What is the Policy? Page 4: What is Expected of Managers? Page 5: Ethical Scenarios and Discussion Questions Pages 6-7: Additional Resources: Gifts and Entertainment FAQ Additional Gifts and Entertainment Resources

What are Gifts and Entertainment? What risks are associated with gifts and entertainment? Business gifts and entertainment on a modest scale are commonly used to build goodwill and strengthen working relationships among business associates. Providing or accepting occasional meals, small company mementoes, and tickets to sporting and cultural events may be appropriate in certain circumstances. However, if offers of gifts, entertainment or travel are frequent or of substantial value, they may create the appearance of, or an actual, conflict of interest or illicit payment. Conflicts can arise whether giving or accepting, e.g. gifts or entertainment could be seen as an attempt to influence a decision, or to enhance personal lifestyles by misusing company funds. We could be accused of double standards if we give more generously than we are allowed to accept. Conversely, we could be thought to have entered into an obligation to reciprocate, either in kind or with some other benefit if we accept. Giving certain gifts and favors including travel, accommodation, or daily expenses (directly or through intermediaries) to foreign officials, including the attempt to do so, could be considered a criminal offense in many countries and subject you and the Company to severe penalties. Understanding Gifts and Entertainment: Meal Although doing business over a meal is an accepted practice, lavish or frequent meals are prohibited. Gifts Giving small, personal gifts is often a part of local culture. Gifts may not be linked (or appear to be linked) to gaining a competitive advantage in a bidding process or RFP. Gifts of cash or cash equivalents (e.g., gift cards) are strictly prohibited. Entertainment Invitations to entertainment events (e.g., plays, concerts, sporting events) tend to have limited direct relevance to business and create an appearance of impropriety.

Our policy on Gifts and Entertainment What is the Policy? Our policy on Gifts and Entertainment Etihad’s policy on gifts and entertainment is found in parts three and four of the Code of Business Conduct and covers: Receiving gifts and entertainment Offering gifts and entertainment Refusing gifts or entertainment Dealing with public officials Facilitation payments Examples of gifts and entertainment allowed and prohibited by the policy Understanding key concepts Characteristics of an appropriate gift It does not violate any law, policy, regulation, trade organization, etc. Its value is nominal, meaning small, low, or insignificant It is for a valid business purpose It is infrequent and could be reciprocated It is not requested It imposes no sense of obligation on the giver or recipient It is not in cash or anything similar to cash It would not cast doubt on the integrity of a procurement process It is open and transparent, not hidden or secret It is recorded appropriately in the Company’s accounting records

Meeting Your Gifts and Entertainment requirements Manager Expectations What to Do Related Resources Educate yourself on gifts and entertainment compliance. Review this presentation Familiarise yourself with what the Code of Business Conduct says about Gifts and Entertainment Gifts Public Officials Educate your team on gifts and entertainment compliance. Ensure employees complete the Code of Business Conduct training and annual certification Lead periodic discussions on ethical dilemmas Code of business conduct training on ilearn Click here to access training videos on gifts See sample ethical scenarios on page 5 Review FAQ on page 6 Create an environment that makes it easy for employees to discuss and disclose any gifts and entertainment concerns and questions. Reiterate your commitment to a workplace that promotes integrity in team meetings and other regular communications Act sensitively when receiving employee concerns and give the employee your full attention Approve gifts only when allowed by the policy. Grant approvals in accordance with policy and good judgment; seek guidance from the Ethics and Compliance Office when in doubt Ensure you and employees track gifts and entertainment they give and receive Email: ethicscompliance@etihad.ae Call +971 (2) 511 1100 Set a good example. Ensure you remain clearly within the Gifts and Entertainment Policy guidelines Be a role model for gifts and entertainment compliance Seek guidance from the Ethics and Compliance Office to resolve gifts and entertainment issues. If a gifts and entertainment issue is uncovered, consult the Ethics and Compliance Office to manage the situation appropriately

Ethical scenarios to discuss with your team Sample Scenarios Sample Discussion Questions Scenario 1: Receiving travel A supplier based 1,000 miles away has supplied one of our company’s divisions with defective products. The supply chain manager must work with the supplier to determine the root cause of the defect. To facilitate this, the supplier offers to pay the supply chain manager’s airfare and hotel for a visit to the facility. Should the supply chain manager accept this offer? Scenario 2: Taking a local Official to dinner You meet a local official who has opposed our company's plan to build an office in an environmentally sensitive area. You talk for the entire afternoon, and feel you can really gain the official's support if you continue the conversation over dinner. It would be awkward to split the check so you decide to pay. Have you done anything wrong? Scenario 3: Sending Gifts to customers A team member is sending out gifts to her large customers at the New Year to thank them for their business and wish them a Happy New Year. She decides to send these clients a small gift basket with assorted fruits and chocolates. Each basket is valued at $50. Is this an appropriate business gift and gift amount to send? Understanding the risk What does the Code say about this scenario? What does the Gifts and Entertainment Policy say? What aspect of the Policy is potentially being violated? How would this appear to co-workers? Applying the Code/Policy How does the Code and Policy help you resolve the issue at hand? Does the gift/scenario require approval/pre-approval? Solving the situation How could potential gifts and entertainment violations in this scenario be avoided? How should you handle this situation? What can I, as your manager, do to help you in similar situations?

Gifts and Entertainment FAQs Use these frequently asked questions on gifts and entertainment to better understand how to comply with the Code of Business Conduct. If you have additional questions, contact the Ethics and Compliance Office. Accepting Gifts, Meals, and Other Business Courtesies Giving Gifts and Other Business Courtesies Q: Is it ever OK to accept a gift or business courtesy from a customer? A: You should never say or do anything to suggest that gifts are necessary for a customer to receive the same prices or excellent service as anyone else. In some cases, routine business courtesies may be appropriate. Q: Suppose I am offered a gift that I feel I should not take, but it would be embarrassing to refuse…what should I do? A: This is why the gift guidelines call for good judgment and disclosure – each situation can be very different. You should always feel free to decline a gift and return it with a thank you note. If you aren’t sure if it is inappropriate, inform your line manger or the Ethics and Compliance Office to seek guidance and discuss the next steps. Q: A customer with whom I have been working closely recently presented me with AED 1,000 gift card and a plaque for outstanding service. Can I keep it? A: Thank the customer and keep the plaque, however, it is against Company policy to accept cash, or cash equivalents, such as gift certificates from customers. Q: I received an expensive basket of fruit from a supplier as a holiday present. I did not solicit the gift. What should I do? A: Inform your line manager that the gift was received. Where it is impractical to return the gift, it should be shared with others in the work area, or it can be given to a charitable organization. Q: Is it allowable to buy a drink for a supplier representative after a meeting at the end of the day? A: Yes, you may buy a person a drink if it is after business hours and no other company policies are violated. For example, you should not drink alcohol and return to work or drive under the influence. Q: I want to give one of our best customers a special gift to say thanks. I have access to some tennis tournament tickets that I know she would appreciate, but I think it is against her company's policy for her to accept them. If she doesn't care about the policy, can I give her the tickets? A: No. If you know that giving a gift will violate the policy of the recipient's company, you may not give the gift. Just as we want others to respect our standards, we will respect theirs. Q: What is a gratuity? May I give or accept a gratuity? A: Unlike small gifts and business courtesies, gratuities are prohibited. A gratuity, unlike a gift, is given or received expecting to get something, such as business or favors, in return. You cannot give or receive cash or gratuities in connection with the negotiation or transaction of company business. There can be a fine line between an appropriate gift or business courtesy and an inappropriate gratuity. Use good judgment. If you think anyone will perceive that gift or business courtesy as an expectation of getting something (like business or a favor) in return, then don't give or take it. If you are unsure, ask your line manager or contact the Ethics and Compliance Office.

Additional Resources Company-Specific Resources Code of Business Conduct Gifts and Entertainment Policy Ethics and Compliance Office contact information Ethics and Compliance Office intranet site Ethics line Note: To access hyperlinks, right click the text and select “Open Hyperlink” or, when in slide show view, click directly on the link.