During the holiday season, Rockwell Collins' gratuities and business courtesies policy is especially relevant to our employees, customers, suppliers, and vendors. This policy is in place to ensure the integrity of our business transactions is never questioned. Further, it is in place to prevent situations that could put a customer or supplier in a position that would violate the law or the policies of their employer.

There is a difference between gratuities and business courtesies:

• Gratuities: anything of value given voluntarily and not in return for or in anticipation of a reciprocal service or courtesy. Examples include money, goods, services, or use of a facility or property.
• Business courtesies: reasonable accommodations related to marketing, procurement, or other business activities. Examples include lodging, meals, transportation, and entertainment.

According to our policy at Rockwell Collins, employees are not allowed to accept gratuities or business courtesies of significant value from external sources.

There might be times when a customer, supplier or vendor offers one of our employees a gift or business courtesy that cannot be accepted under our policy. In situations such as this, our guidance is to express that while the gesture is appreciated, it would be inappropriate to accept. Employees should explain that the purpose of our gratuities and business courtesies policy is to avoid even the appearance of impropriety in all of our business transactions.

When vendors, customers, or suppliers have questions about whether or not it is acceptable to offer a gift or business courtesy to a Rockwell Collins employee, they are encouraged to refer to our Standards of Business Conduct or to contact the Rockwell Collins Ombudsman.

Additionally, our employees are not to offer a gratuity or business courtesy to one of our suppliers, customers, or vendors that would violate our policy.

If you have questions about whether accepting or offering an item is a violation of our policy, or if you have accepted or offered a gratuity or business courtesy and think you might have violated our policy, contact the Ombudsman at (319) 295-7714.