FIFA - Compliance Pocketguide Gift and Hospitality

Compliance Pocket Guide WHAT? Gifts and hospitality are part of doing business, but they have to be handled in the right way. Remember, at FIFA we have zero tolerance for any kind of bribery or corruption. A gift is anything of value that is received or given for free and without expectation of return. At FIFA, we don’t routinely accept or offer gifts over the value of USD 200. The term “gift” may include gratuities, courtesies, favours, discounts, loans, and any other kind of item with a monetary value. Hospitality refers to social-type activities directly related to our business. Hospitality should be reasonable and appropriate to the position of the team member and the occasion. If you’re receiving hospitality and the person who invited you isn’t there, then we consider that a gift, which means it can’t be worth more than USD 200. Also, tickets to football matches are intrinsic to our mission and are not considered a gift. However, tickets to non-football-related sporting events are subject to the restrictions set out in these guidelines. WHY? We play the right way. In some cultures, giving small gifts to mark occasions or getting together to celebrate a successful project are very much part of daily life. But gifts and hospitality must never influence business decisions or gain a business advantage. It’s important to remember that bribes don’t just take the form of an envelope stuffed with cash. Tickets to that must-see event, stays in five-star hotels and valuable gifts can also be bribes. WHO? Working all over the world and experiencing all sorts of cultures is a brilliant part of life at FIFA. The way we work means that almost any team member could offer or receive gifts and hospitality as part of their job. So it’s up to you to do the right thing: think carefully about whether giving or receiving gifts and hospitality is the right thing to do in your situation. If you work with government officials, the risk – or the perception of the risk – of bribery can be higher, so it’s always worth getting advice from your manager or FIFA Compliance before you accept or offer hospitality or gifts.

in your situation. If you work with government officials, the risk – or the perception of the risk – of bribery can be higher, so it’s always worth getting advice from your manager or FIFA Compliance before you accept or offer hospitality or gifts. HOW TO REQUEST AN EXCEPTION Have you been offered a gift worth more than USD 200, or been invited to take part in hospitality that you feel could break the rules? Please decline politely and explain our policy. If you feel that returning the gift or declining the invitation would offend, you may accept but you must tell your manager and FIFA Compliance immediately. They’ll help you assess the situation and agree the next steps. After discussion, if you want to request an exception you should complete the gifts and hospitality disclosure form through the Compliance Portal. Before accepting, receiving or giving a gift or hospitality, we must consider the following: FIT TEST Frequency Does it involve the same organisation, giver or recipient more than once in a single calendar year? (For gifts, keep the threshold of USD 200 in mind.) Intent Is the intent anything other than relationship-building or promoting FIFA and football? Does it breach local law? Timing Is the gift or hospitality being offered shortly before a business decision is due to be made? Could the decision benefit the giver or receiver? Questions? I 20 December 2021 I 01

GIFTS AND HOSPITALITY

Compliance Portal Pocket Guide – Raising ConcernsiCompliance Pocket Guide GIFTS AND HOSPITALITY FIFA team members are responsible for assessing whether they can accept or give an unsolicited gift or hospitality. Here is what you need to know in order to accept or reject it: Questions? I 20 December 2021 I 02 ”TO ACCEPT OR NOT TO ACCEPT, THAT IS THE QUESTION …” 1. Did you receive a gift or hospitality?

Please remember: 2.

Is the gift worth less than USD 200? Or is the cost of the hospitality invitation reasonable? 3. Frequency – does it involve the same organisation, giver or recipient more than

1. Did you receive a gift or hospitality?

Please remember: 2.

Is the gift worth less than USD 200? Or is the cost of the hospitality invitation reasonable? 3. Frequency – does it involve the same organisation, giver or recipient more than once in a single calendar year? 4. Intent – is the intent anything other than relationship-building or promoting FIFA and football? Does it breach local law? 5. Timing – is the gift or hospitality being offered shortly before a business decision is due be made? Could the decision benefit the giver or receiver? If the answer to either of the above questions is YES, continue with the FIT test. If the answer is NO, contact FIFA Compliance. If the answer to any of the FIT questions is YES, contact FIFA Compliance. If the gift or hospitality passes the FIT test, you can approve it yourself. We can’t give or accept money, or things like gift cards or gift certificates. 1a If you are not able to establish a gift’s fair market value, please contact FIFA Compliance. 2a Regarding the hospitality, ask yourself: would you pay for this hospitality yourself? 2b “If you go, I go …” – the person extending the invitation must be present at the event, otherwise this is considered a gift and the USD 200 threshold applies. 1b