Gifts, Gratuities and Other Business Courtesies

Restrictions on Receiving Gratuities. Employees may, within limitations, accept meals, entertainment, non-cash gifts, discounts or promotional items (collectively, "gratuities") of modest value (generally less than $100 USD) when such acceptance is directly connected with business discussions. Such items must be lawful, unsolicited, infrequently provided and in accordance with customary and acceptable business practices. Acceptance of gratuities having a value greater than $100 USD is permissible only with written approval of the employee's Senior Vice President. Neither employees nor their family members may ever accept any gift of cash, cash equivalents, credit cards, loans or securities from any person or firm doing, or seeking to do, business with NS unless such activities meet the guidelines contained in this Policy and Code.

Restrictions on Offering Gratuities. Except for published or customary product discounts or other contractual incentives, NS employees are not to give, offer or promise, directly or indirectly, anything of value to any representative of a customer, potential customer, financial institution, government employee or other party in connection with any transaction or business that the company may have with such party, without the approval of the appropriate Senior Vice President. Meals and entertainment, such as golf outings, may be appropriate if they are infrequent, in accordance with customary and acceptable business practices and approved by the appropriate management. Employees must ensure that all expenditures are properly documented and aligned with the company Expense Reporting Guidelines.

Special Restrictions with Respect to Government Officials. Regardless of geographic location, no NS employee or consultant may give or offer anything of value to a foreign government official in order to obtain or retain business. The U.S. Foreign Corrupt Practices Act (FCPA) prohibits payments or gifts to government officials outside of the United States for the purposes of obtaining or retaining business, even if the payment or gift is legal in the host country. The FCPA applies to both domestic and foreign business operations of United States companies and imposes severe criminal and civil penalties against individuals and companies which violate this law. All the company employees - domestic and foreign – engaged in business transactions must comply with the FCPA in all respects.

Theft and Fraud

Honesty and integrity form the basis of the NS firm stance against theft and fraud. When employees commit theft or fraud against the company, everyone with a vested interest in the company is affected. NS does not tolerate theft or fraud of any kind and investigates and prosecutes offenders. Fraud is defined as an act or acts of deception that could result in gain, profit or advantage to an employee, or harm or loss to another person or entity. All employees are required to report suspected theft or fraudulent acts within the company using the methods described in the section “Guidance on Identifying and Resolving Issues.”

Confidential Information

The protection of confidential information is crucial to the success of the company. Aspects of our business are built on information: These are all information assets of the company. Confidential information can be presented or stored in many forms including, but not limited to: documents on paper, information passed on by voice, information on hard drives and other electronic storage media, charts and graphic presentations, audio and video tapes, and email. In any form, the confidential information must be protected. The company software confidential business information is entrusted to our employees and partners to enable them to do their jobs successfully. This confidential information belongs to the company and is to be used solely for company purposes. Keeping our proprietary business information and trade secrets confidential is essential for our success and growth.

Keeping our customers', suppliers' and partners' business information confidential is essential to maintaining our reputation and our relationship with them. It is the policy of the company to protect its confidential business information and that of other companies entrusted to the company software.

Disclosing Confidential Information Properly. Often the company business requires us to share confidential information with people outside our company. The company legal department has produced confidentiality agreements to use with vendors, customers, consultants, partners and contractors. Employees are responsible for ensuring these agreements are signed and properly executed before divulging confidential information to these outside parties. Confidential information can only be disclosed to people outside of the company when these agreements are in place.

Harassment

Each of the company employees has the right to be treated respectfully and without regard to race, color, creed, religion, national origin, sex, age, disability, sexual orientation, marital status, or veteran status. Behavior that unreasonably disturbs another person in his or her work because of abovementioned person’s features is harassment. Each of the company employees is personally responsible for maintaining a work environment that is free from discrimination. They should respect the rights and differences of others. Each of the company employees plays a critical part in creating a fair and diverse workforce. You should exercise good judgment in professional and personal relationships with co-workers, because each of us wants to work where we are respected and appreciated.

(Based on: current companies’ Codes of Business Conduct and Ethics)

III. Read and translate this text from English into Russian and be ready for its discussion on the basis of active vocabulary, key terms quiz, review and discussion questions.