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<back to Code of Conduct
Exhibit A
Foreign Official Hospitality Guidelines
All hospitality offered on behalf of TriMas Corporation and/or
its subsidiaries (collectively TriMas or the Company) must be
directly related to the Company’s business, i.e., the sale
of its products and services, or otherwise directly in support
of the Company’s business interests. Hospitality in all
cases must be reasonable in amount, must be offered in good
faith only in connection with the promotion, demonstration or
explanation of company products or services or the execution
or performance of a contract with a foreign government or agency
thereof, and must be lawful under applicable local law. In no
event may any hospitality be offered or provided in return for
any favor or benefit to the Company.Note: Frequency of hospitality must be carefully monitored,
as the cumulative effect of frequent hospitality may give rise
to the appearance of impropriety. Hospitality for an individual
should not exceed twelve events in any calendar year. Where
additional hospitality is anticipated, the Legal Department
shall be consulted and prior written approval shall be obtained.
Unless otherwise provided in these Guidelines, in the case of
plant visits or similar activities by foreign government officials
or employees which will involve the Company paying airfare or
lodging expenses for such officials, the Company shall send
invitations or itineraries, or both, to the foreign officials
to inform them, to enable consultation with superiors, and to
afford them the option to decline. The Company also will obtain
prior written approval or confirmation from the invitee’s
superior or other authorized official or prepare a file memorandum
of relevant conversations in this regard. If this is not practical
in connection with very senior invitees, the Legal Department
shall obtain a written legal opinion from in-country counsel
that specifically addresses the particular circumstances of
the visit. In the case of plant visits that are specifically
required by the terms of a contract with a foreign government
customer, prior written approval or confirmation from the invitee’s
superior or other authorized official is not required, but all
hospitality expenses related to any such visit shall be subject
to these Guidelines. In no case will payment or reimbursement
be made directly to the individual official incurring the expense.
Such payment or reimbursement shall be made to the foreign government
or agency involved.
Refreshments, meals or mementos of reasonable value and otherwise
in accordance with these Guidelines which are furnished in connection
with trade shows, association meetings, official governmental
functions, or ceremonial, commemorative or celebratory functions
such as ship launchings, airplane rollouts, deliveries or demonstrations
are permissible. For such events or occasions to which foreign
government officials or employees from three or more countries
are invited, in-country counsel opinions will not be required
with respect to the foreign government officials’ or employees’
participation, provided the refreshments, meals or mementos
to be offered are of reasonable value and otherwise strictly
in accordance with these Guidelines, and are not offered improperly
to influence any official decision. However, notification of
such events shall be made in writing to the Legal Department
at least 15 days in advance of such event. The notification
shall generally describe the event, the per person cost of the
refreshments, meals and mementos offered, and any other relevant
aspects of the event.
Cash gifts to foreign officials are not permitted under any
circumstances. Per diem payments are similarly prohibited, except
where expressly provided for in a written contract with a foreign
government customer. In such case, per diem payments shall be
paid strictly in accordance with the contract requirements.
Any such payment shall be made by check, rather than cash. Whenever
feasible, the check for per diem payments should be made payable
to the foreign government customer, rather than to any individual
foreign official. Any such per diem payment shall always be
accompanied by appropriate documentation accurately recording
the amount and nature of the payment in accordance with the
contract requirement.
Unless otherwise provided in these Guidelines, product models
or pictures of little or no intrinsic value bearing the company
logo or other items of small dollar value (less than U.S. $100)
that are distributed for advertising or commemorative purposes
are permitted. Gifts valued at $100 or more must have the prior
written approval of the Legal Department. Whenever appropriate,
a gift should be made to the customer organization, and not
to an individual.
Use of Company aircraft to transport foreign officials is prohibited
unless prior written authorization is obtained from the Legal
Department. Other transportation may be approved, after legal
review, on a case-by-case basis.
Prior written approval by the Legal Department is required for
any hospitality offered to the spouse and/or children of a foreign
official.
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