I took a very similar presentation from the shadiest company I was ever employed by, specifically that "gifts and other favors" are generally guidelines to be followed by local customs. I.e. bribe away as long as you aren't in the United States. Weird as fuck for a company that solely does commerce in the United States to have murky guidance on this very clear issue.

My role here was very brief, they hired me for a licensed role and then paid me as a customer service rep, so I quit immediately after my first paycheck was about $3,000 short.