Page 24 - Code of Ethical Business Conduct

22 Martin Marietta
Entertainment, Gifts and

Payments

The sales of Martin Marietta products and services should always
be free from even the inference or perception that favorable treatment was sought,
received or given on the basis of the furnishing or receipt of gifts, entertainment,
favors, hospitality or other gratuities. Similarly, purchase of supplies, materials, and
services from vendors, suppliers, and subcontractors must be accomplished in a
manner that preserves the integrity of a procurement process based on a balance
of price, quality, and performance. Reported information should be accurate when
made and disclose all pertinent information in a way that is not misleading.
We specifically prohibit offering, giving,
soliciting or receiving any form of bribe or
What is a “Kickback” kickback. These are criminal acts.
or “Pay to Play”? The following guidelines should be observed in
relations with customers and supplier personnel.
A kickback or pay to play is
a form of corruption where
the employee gives preferen- General
tial treatment to a third party
in exchange for a payment, All approved expenditures for meals,
portion of sales or profits refreshments, entertainment and gifts must be
improperly given, rebated or
otherwise returned to the fully documented and recorded on the books
employee in exchange for of Martin Marietta in strict accordance with
making the deal. established policies and procedures. Our policy on
expenditures, as it is updated from time to time,
must be followed. Our policy currently requires
that expenditures must generally be paid for using the Martin Marietta-provided
payment card and evidence of the nature of the expense and attendees must be
documented on the expense report submitted each month.
Company personnel involved in procurement of goods and services must
comply with the Procurement Department Guidance for Acceptable Practices
with Suppliers.
You should report to your supervisor or the Ethics Office any instance in which
you are offered money, gifts or anything else of value by a supplier or prospective
supplier to Martin Marietta.
Relations with Non-Government Personnel

Furnishing meals, refreshments and entertainment in conjunction with business
discussions with non-government personnel is a commonly accepted practice. We
permit our employees to engage in this practice.