GIFT AND HOSPITALITY POLICY - Version 1.0

Registration No. 199101010894 Gift and Hospitality
 

Gratification can sometimes be disguised as gifts or hospitality. However, in genuine circumstances, these may be misinterpreted as bribes. Hospitality would include meals and entertainment. The Group must ensure that the giving and receiving of gifts or hospitality will not distort its business relationships, create a conflict of interest or be construed as gratification. Conflict of interests may arise by the giving or receiving of favours or special treatment to which no financial value can be attached. Such special treatment can encourage a ‘payback’ expectation and can distort a professional relationship.

The Group recognizes that customary business or cultural occasions do involve the giving of gifts and extension of hospitality particularly during festive seasons and commemorative occasions. The giving of gifts and/or hospitality is practiced then and at times it is not possible or even offensive to refuse the gift or hospitality. Gifts/hospitality received or given must not carry any corrupt or criminal intent and must not to be perceived to give rise to any effect on actions or decisions. It must also not carry any expectation of any specific favour or improper advantage from the intended recipients.

This policy clarifies the circumstances where gifts/hospitality may be accepted or given:

Receipt of gifts/hospitality

1. The receipt of gifts/hospitality must be in an open and transparent manner and must not be solicited.

2. Employees should not accept gifts/hospitality or any other consideration of a value greater than:

- RM500.00 – Senior Managers and above

- RM300.00 – Assistant Managers and above

- RM150.00 – Administrative Assistants and above

from any person having business relationship with the Group without having first obtained the permission of the Head of Department/Branch Head.

The Group should not accept gifts/hospitality or any other consideration of a value greater than RM1,000.00.

3. All gifts above the consideration value will have to be reported via the Gift Declaration Form within 5 working days of the receipt. All gifts from anonymous/unknown givers are to be reported. The Head of Department/Branch Head shall have to liberty to determine the disbursement of such gifts.

4. Acceptance of hospitality should be exercised with discretion. Excessively generous hospitality given to any one individual and/or his personal associates may be liable to misinterpretation. Hospitality given to any employee by clients, while the employee is carrying out his duties or by virtue of his/her position in the client’s organization (eg. Staff from Procurement Department, Marketing Department etc) and where the hospitality is enjoyed without discrimination may be accepted.

5. Corporate gifts of modest value bearing the logo or brand of the giver, hereinafter defined as branded goods (eg pens, mugs, diaries, calendars, mousepads, baseball caps, t-shirts, key chains, bags etc) whether given personally or received may be retained unless these are regarded as inducement or reward.

6. Gifts, food or festive hampers given in celebration of festive seasons are to be declared. Where the gift hampers are of excessive value or contains luxury items, such hampers are to be returned with a note.

7. Items given out openly at fairs, trade events, conference, media event, annual general meeting etc where the item is given out without discrimination and not exclusively to any one particular employee may be accepted.

8.Gift certificates, discount coupons, cash vouchers or equivalent received as part of external parties, clients’ promotional or family days of values not exceeding the limits set in this policy may be retained. The balance should be surrendered to the Group or shared amongst team members and the Gift Declaration Form is to be completed and submitted.

9. If employees are invited to attend a meeting, present a speech or paper or submit a written article in any associations, societies, foundations or commercial conference, all speaking fees, article fees and honoraria should be declared and should be paid over to the Group, who has the discretion to allow the employee to retain the sum.

Giving of Gifts/Hospitality

The provision of gifts/hospitality from the Group is permitted as follows:

1. The Group does not regularly make charitable donations to organisations. Should a payment to a charitable organization or education fund be made, the prior approval of the Group’s Senior Management is required. A donation or payment must never be made to the order of any individual without prior approval from the Group’s Senior Management.

2. Corporate gifts given to other commercial organisations or individuals in relation to the Group’s official functions, events, celebrations, conferences, seminars, trainings, workshops, exhibitions (in the form of commemorative branded goods or door gifts) offered to all guests or employees attending the event;

3. Exchange of gifts at company-to-company level. Thereafter the gift is treated as the Group’s property;

4. Gifts to employees and/or their relative in relation to employee events or company celebrations, eg performance rewards, long-service awards, competition prizes etc;

5. Sponsorships of education fund, sports event, anniversary celebrations, milestone events, office/factory openings of amounts not exceeding RM5,000 in any one year to any one person/party.

This policy is adopted on 1 June 2020.