Top 10 Gifts and Business Entertainment FAQs

1. May I offer or receive gifts such as cash, gift cards, gift certificates or cash equivalents?
   
   No. AIG policies clearly state that employees may not offer or accept cash or cash equivalents in any amount to or from business partners.
   
   
2. Is there a limitation on the value of a gift that employees may give or receive?
   
   The maximum value of gifts is $150 USD. Value is determined by the cost or retail value of the gift, whichever is higher. The value of AIG items is determined by the cost to AIG. The Code of Conduct describes what to do when a business relationship situation may allow for a gift valued more than $150 USD. Generally, the gift is accepted on behalf of AIG and becomes its property. Other policies provide guidance concerning gifts involving government officials (Anti-Corruption Policy). The Expense Management Policies also provide detailed guidance on a number of general gift-giving situations.
   
   
3. May an employee who receives a gift of two tickets to an event, each with a value of $100 USD, give one ticket to another employee in order to meet the $150 USD gift limitation?
   
   No. Employees may not split a gift with another employee in order to meet the individual gift limitation of $150 USD. The same guidance applies to gift baskets, multiple bottles of wine, or other multiple item gifts.
   
   
4. May an employee accept a gift with a value greater than $150 USD?
   
   Yes. Subject to reporting and recordkeeping requirements, an employee may only accept a gift over the $150 USD limitation where declining the gift would offend the gift-giver or harm a business relationship. Generally, in these types of circumstances, the gift is accepted on behalf of AIG and becomes its property. The gift must be given to your manager who, together with your compliance officer, will determine its appropriate disposition.
   
   
5. May an employee give a gift with a value greater than $150 USD?
   
   In exceptional cases under the Code of Conduct, a gift worth more than $150 USD may be provided to a non-broker business partner with prior written approval from the gift-giver's manager. Certain other policies, including the Anti-Corruption Policy place additional restrictions and prohibitions on giving gifts that exceed $150 USD.
   
   
6. What is the difference between gifts and business entertainment?
   
   A gift is anything of value offered to a business partner or received by an employee. Business entertainment is any event, including dinners, luncheons, cocktail receptions, sporting or cultural events provided by either an employee or a business partner in which at least one employee and one business partner attend to further their business relationship in a social setting. If the provider of the business entertainment does not attend, it is considered a gift to the recipient and the gift limitations apply.
   
   
7. May an employee accept a one-time invitation to a sporting event in a luxury box?
   
   Yes. This is a common and permissible form of business entertainment if the employee and at least one business partner are present; otherwise it must be treated as a gift.
   
   
8. May an employee accept an invitation to attend every home game of a sports team?
   
   No. This would violate the Code of Conduct, which requires that business entertainment must be reasonable and cannot be overly generous, extravagant or held too frequently among the same parties.
   
   
9. May an employee host a meal followed by a sporting or cultural event?
   
   Yes, as long as it is reasonable and not extravagant, too frequent or inappropriate. Employees should be aware of the pre-approval and reporting requirements set forth in the Anti-Corruption Policy.
   
   
10. May an employee who plans to attend an industry event at a ski resort accept a business partner's offer of payment for travel and lodging expenses?
    
    It depends. If the offer is a gift because the provider does not accompany the employee and its value exceeds the $150 USD gift limitation, then it is not acceptable. However, it may be permissible as business entertainment if the provider is present during the travel and at the event, and meet all other business entertainment criteria under the Code of Conduct, including an evaluation of the extravagance and potential reputational harm of this type of offer, as well as the identification of a specific AIG business purpose for attending.