Winrock is committed to competing solely on the merit of our people, programs, and projects.  We avoid any actions that create a perception that favorable treatment of outside entities by Winrock was sought, received or given in exchange for personal business courtesies.  

Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom Winrock does or may do business.

Winrock will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of Winrock or our partners, donors and funders or beneficiaries, or would cause embarrassment or reflect negatively on Winrock’s reputation.

Accepting Business Courtesies

Most business courtesies offered to us during our employment are offered because of our positions at Winrock. We should not feel any entitlement to accept and keep a business courtesy.

Although no employee may use their position at Winrock to obtain business courtesies, or ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that Winrock maintains or may establish a business relationship.

Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business, or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect Winrock’s reputation for impartiality and fair dealing.

The expected course is to refuse a courtesy from a supplier when Winrock is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain Winrock business.

Meals, Refreshments and Entertainment

Winrock employees may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:


Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the local marketplace, including:

If possible, share such gifts with others in the office. Lavish gifts may not be accepted. Employees may not accept compensation, honoraria or money of any amount from entities with whom Winrock does or may do business. Other honoraria or payments (such as jury duty fees) should be remitted to Winrock if the work was done while working for Winrock. Tangible gifts (including tickets to a sporting or entertainment event) that have an appreciable value in the local market may not be accepted unless approval is obtained from Chief of Party, Unit Director or equivalent.

Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Winrock. An employee may never use personal funds or resources to do something that cannot be done with Winrock resources. Accounting for business courtesies must be done in accordance with approved Winrock operating procedures.

Other than to our government customers, for whom special rules apply, we may provide nonmonetary promotional gifts such as company logo apparel or similar promotional items to our partners, donors or funder, or beneficiaries.  Further, Chief of Party, Unit Director or equivalent may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:

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