We Play to Win and Do Everything With Integrity

Anti-Corruption, Gifts and Entertainment

We comply with anti-corruption laws and seek pre-approval before giving or receiving certain gifts.

A diverse group of friends gathered around a table, enjoying a meal together.

AT APTIV

  • We prohibit bribery, kickbacks or improper benefits in connection with our business or any of our business transactions.
  • We require that all expenses and associated documentation be properly recorded and aligned with our policies and the law.

YOU'RE IN THE DRIVER'S SEAT

  • Never authorize, ask for, offer, give or accept money or anything of value, directly or indirectly, to improperly influence an act or decision.
  • Never direct or allow third parties who work on our behalf to do something we are not permitted to do ourselves.
  • Facilitation payments to a government official made in order to expedite or secure performance of non-discretionary, routine governmental actions are not permitted at Aptiv, regardless of the amount.
  • Be careful with gift-giving. Check with your supervisor or the Global Legal and Compliance Team if you are unsure about what is (and what is not) appropriate.
  • Make sure you follow the gifts and entertainment rules of any government official or commercial business partner.
  • Obtain any necessary approvals before giving or receiving any meal, gift or entertainment.
  • Do not offer anything to a government official (including a state-owned enterprise), no matter the monetary value, unless you have approval in advance.
  • Avoid any conduct that could suggest even the appearance of something improper.

Spotlight Icon SPOTLIGHT ON
MEALS, GIFTS AND ENTERTAINMENT

To determine if compliance pre-approval is required for a meal, gift or entertainment expense, ask yourself:

Who is the giving or receiving party?

A government official (including employees of a state-owned enterprise)

Find Out!

A commercial business (including suppliers, customers, business partners, etc.)

Find Out!

When in doubt, ask for help before proceeding.

Case Study IconCASE STUDY

Before extending an invitation to your customer, given the cost of the seat, you must seek pre-approval from your supervisor and the Global Legal and Compliance Team. You should also make sure that accepting the invitation is permitted by your customer’s policies.

A diverse group of friends gathered around a table, enjoying a meal together.

Spotlight Icon SPOTLIGHT ON
MEALS, GIFTS AND ENTERTAINMENT

To determine if compliance pre-approval is required for a meal, gift or entertainment expense, ask yourself:

Who is the giving or receiving party?

A government official (including employees of a state-owned enterprise)

Find Out!

A commercial business (including suppliers, customers, business partners, etc.)

Find Out!

When in doubt, ask for help before proceeding.

Want to Know More iconWANT TO KNOW MORE?