Herbalife recognizes its responsibility to be a good steward of company resources and provide guidance to employees in making appropriate judgments when committing expenses. Accordingly, Herbalife employees are held to the highest stewardship and ethical standards and for the funds placed in their trust.
In addition, we must comply with some regulations, no matter locally or internationally. For tax consideration, local tax authorities’ rules might exert non-tax-deductible of lavish or extravagant meals or entertainments or gifts and/or categorized such expenses to be taxable benefits for the employee. Excessive expenses could lead to additional tax cost to the company and perhaps additional taxable income to the employee, etc. For FCPA consideration, Herbalife as a US listed company and our interactions with Government officials or public officers in each local entity in the world are under strict scrutiny.
This guidance applies to all individual meals, business entertainment meals and gifts whether or not conducted in the context of promoting employee morale or business or external networking. This excludes meeting meals approved in advance associated with planned internal business events and planned management meetings. This guidance applies to all payment mechanisms, including personal credit cards, direct invoice from vendor, Purchasing Card (PCard), petty cash, and employee expenses claim reimbursement.