12 AAR Doing it right for our customers Exchanging gifts and entertainment Exchanging gifts or entertainment can be a local custom in some places where we do business, and it is also a way to build business relationships. However, there are limits on the gifts that we can make or receive. A gift is anything of value that the recipient does not pay the retail price or usual cost for. Common examples include meals, tickets to sporting events or other entertainment, or items such as watches. How we own it • Avoid giving gifts to or accepting gifts from a customer, supplier or anyone else doing or seeking to do business with AAR. • Exchanging certain nominal gifts may be allowed, but make sure they are unsolicited, not being used to influence a business decision and not given in appreciation for a past action. • Understand what constitutes an acceptable gift, including: • Promotional materials bearing the company’s logo or food or drinks that are difficult to return and are worth no more than USD 100, when they are given on occasions when gifts are customary. • Discounts or rebates that are available to the general public or all AAR employees. • Reasonably priced and infrequent entertainment or meals for a business purpose where the giver and recipient are both present. • Refuse or return any other gifts. If you are unable to do so, you must disclose the gift in writing to your manager as soon as possible. Keep in mind that stricter rules apply to gift giving when government officials and employees are involved. In general, do not give or offer any gift—regardless of value—to a government official. For more information, see the “Doing It Right for Our Government Customers” section of the Code. Tania has worked with one of AAR’s biggest customers for several years, and she has become very friendly with her contact at that company. The two of them go to lunch once a month at a high-end restaurant. Occasionally they discuss business, but usually they just chat about their lives. Either Tania or her contact at the other company will charge these lunches to their company credit card as a business lunch. Is she Doing It Right? No, she is not. These lunches are not for a business purpose, and meeting at a high-end restaurant may not follow AAR’s guidelines for gifts and entertainment. Tania should pay for these lunches out of her own pocket unless they are truly opportunities to talk about business.