Lead With Integrity

Build. Develop. Inspire.

Business Gifts and Entertainment

The occasional exchange of business courtesies can promote goodwill. However, offers that are too frequent or extravagant in nature can send the wrong message. We never want to distract from the exceptional quality of our people and performance with unethical business practices. That’s why we use good judgment and ensure that anything we give or receive is consistent with FIS policies and the law in jurisdictions in which we operate.

Recognize when offers are acceptable.

We only offer or accept business gifts and entertainment when doing so would be considered legal, ethical, and customary. This includes items of nominal value such as promotional items, chocolates, or flowers.

Know when to disclose offers.

Disclose and register the following offers of business gifts, entertainment, meals or other items into our COI Disclosure application (within the Business Gifts and Entertainment FIS & me page):

  • For non-government officials: any item that meets or exceeds US$100, either collectively or individually.
  • For government officials: any item, regardless of value.

Never offer anything of value to a government official, including state-owned entities, without obtaining permission from the FIS Ethics Office first.

For additional guidance, review the FIS Business Gifts and Entertainment Policy. For potential exceptions and additional country guidance, review the FIS China Entertainment and Marketing Expenses Guideline.

Making Ethical Decisions

If you are unsure whether giving or accepting a gift, offer of entertainment, or other item of value would be appropriate, ask yourself:

Is the recipient a government official?, Is it excessive under the circumstances?, Is it purely entertainment with no business purpose? Will the third party be in attendance?, Are we in contract negotiations or upcoming contract renewal?, Is it something that's given frequently?, Is there any reason, other than a legitmate business reason, for it?, Is it in the form of cash or a cash equivalent (e.g. gift card, gift certificate, credit card) which is strictly prohibited to be given or received?, Does the giver expect something in return, such as a favor?, Does it violate the recipient's rules, customs, and policies?, Will it be inaccurately recorded in our books and records?
Is the recipient a government official?, Is it excessive under the circumstances?, Is it purely entertainment with no business purpose? Will the third party be in attendance?, Are we in contract negotiations or upcoming contract renewal?, Is it something that's given frequently?, Is there any reason, other than a legitmate business reason, for it?, Is it in the form of cash or a cash equivalent (e.g. gift card, gift certificate, credit card) which is strictly prohibited to be given or received?, Does the giver expect something in return, such as a favor?, Does it violate the recipient's rules, customs, and policies?, Will it be inaccurately recorded in our books and records?

If you answered “yes” to any of the questions, STOP and seek additional guidance. If you answered “no” to all of the questions, then it may be OK to give or accept the item of value.

A woman sitting on the floor in front of a laptop on a table, holding a gift card

Our Core Values In Action

Q: I’m hosting an event where government officials will be in attendance, and I want to provide lunch to everyone at the event. I don’t want to violate our policies. What should I do?

A: You should seek guidance from the Ethics Office. The rules that apply to giving business courtesies to government officials can be complex. Remember, seek assistance with government officials regarding anything of value (even under US$100). In general, if you’re unsure of what to do in a given situation, you should always ask the Ethics Office for guidance before proceeding.

Additional Resources Available:

Business Gifts and Entertainment Policy

Employee Gifts, Prizes and Awards Policy

Travel, Entertainment and Business Expense Reimbursement Policy

Visit our Business Gifts and Entertainment page on FIS & me for more information including how to register business gifts and entertainment in our COI Disclosure application (within our Business Gifts and Entertainment FIS & me page). Reach out to the FIS Ethics Office if you’re still unsure.