Page 25 - Code of Ethical Business Conduct

Code of Ethical Business Conduct 23

No employee or director will directly or indirectly accept or offer payments,
gifts, entertainment or other gratuities (regardless of size or amount) that
would have the effect or appearance of influencing the judgment of the recipient
in the performance of his or her duties. Gifts of cash or gift cards are prohibited.
It is not inappropriate under this policy to be the recipient of, or to offer, common
courtesies; sales promotional items of small value; occasional meals; reasonable
entertainment, recreation or tickets; or other items appropriate to a business
relationship, so long as it is appropriate as to time and place, can withstand public
scrutiny, does not influence or give the appearance of influencing the business
judgment of the recipient, is within the bounds of moderation and common
sense, and is either inexpensive or approved by a senior corporate officer or
division president.
Employees who make and supervisors who approve expenditures for meals,
refreshments, or entertainment must use discretion and care to ensure that such
expenditures are in the proper course of business and could not reasonably be
construed as bribes or improper inducements.
Relations with Government Employees

Federal, state and local government departments and agencies are governed
by laws and regulations concerning acceptance by their employees of
entertainment, meals, gifts, gratuities and other things of value from firms
and persons with whom those departments and
agencies do business or over whom they have
regulatory authority. Appropriate Gifts and
It is the general policy of Martin Marietta to Entertainment...
prohibit our employees from giving or offering to • Is a normal, infrequent
give any of these items to government employees. business courtesy to maintain
There are, however, permissible exceptions within good business relations
these laws and regulations such as distributing • Is not cash or more than
token business mementos and providing nominal modest value
refreshments during the conduct of business • Does not call recipient’s
discussions. Since these exceptions are narrowly objectivity into question
construed and subject to change or deletion, any • Creates no perception of
question concerning them should be referred to undue influence
the Company’s Legal Department. • Does not obligate you or
Martin Marietta to the gift
Martin Marietta employees may not make giver or other party
loans, guarantee loans, make payments or • Would not embarrass you or
give gifts of any value to federal, state or local Martin Marietta if the public
government employees. became aware of it
Martin Marietta employees may entertain • Is not paid to a government
socially any relatives or friends employed by employee
government agencies. It should be clear, however,