“The Company’s directors, management and staff members are prohibited from supporting or accepting corruption of all sorts, for one’s own direct or indirect benefits, or for one’s family members, friends, acquaintances, regardless whether one is the receiver, giver or offerer of the bribes; financial or non-financial, to individuals, government officers, or private sector organizations that deal businesses with the Company.”
Anti-Corruption Practical Guidelines
- All members of the organization must abide by the Anti-Corruption Policy and Business Code of Conduct, not getting involved in corruption both directly and indirectly.
- Staff members must not neglect when witnessing potential acts of corruption. They are advised to notify their immediate supervisors, Corporate Affairs Manager or the responsible person and cooperate in fact-finding processes. Should questions arise, please consult with one’s immediate supervisor or the responsible person.
- The Company ensures fairness and protection for staff members who deny to commit or notify corrupt acts. The person will not be subject to disciplinary measures related to demotion, punishment or any negative outcomes, even if such acts may cause the Company to lose business opportunities.
- Those who get involved in corruption will be subject to disciplinary measures or punishment as stated in the Company’s regulation.
Facilitation Fees Policy
Staff members are strictly prohibited from paying facilitation fees to representatives of other companies or government officers in all cases, as this poses high risk for bribery, defamation and violation of the anti-corruption policy.
It must be proven that the donation serves to aid the society and community. The donation must genuinely be for public causes, with documented evidence, and not to serve as the excuse for giving or receiving bribes, or for corruption purposes.
Any donations made on the Company’s behalf must have the receipts or tangible evidence that is coherent with the Company’s regulation, to ensure that the donations do not serve as excuses for dishonesty or corruption.
- A memo or statement of intent must be written, specifying details of the activities or donations, amount, and purposes.
- The request will be reviewed by one’s immediate supervisor and the Corporate Affairs Department.
- Evidence or related documents; letter of appreciation, donation receipts, pictures, etc., have to be compiled by the requestor and submitted to the Finance and Accounting Department to keep for records.
Financial Support Policy
The provision of financial support must be provable that it serves to facilitate successful completion of the activity or the project, to promote the business, the Company’s brand, or to serve operational objectives in a transparent and lawful manner. It should not serve as the excuse for bribery, whereby approval procedures have been concisely determined, allowing for inspection and verification of the documented evidence.
Gift and Reception Policy
Directors, management, staff members and hired workers must not call for, receive or give gifts, host a reception, provide services or privileges of any kinds to persuade decisions or cause negligence of duties, or in ways that suggest giving or receiving bribes, either directly or indirectly, to individuals, business partners, private sector organizations or related parties, unless as a gesture to express goodwill in a feasible manner; not too frequent, suitable for the occasion, with appropriate pricing or value and in accordance with the customs, not against the regulations, Code of Conduct, the Company’s rules and relevant laws.
Reception or hospitality fees must be directly relevant to the activities that serve the Company’s business, for instance, transportation fees, accommodation fees, food and beverage, entertainment fees, sports and recreation fees. They should be related to the business or serve as commercial practices. The spending should be reasonable and does not affect decision making, cause negligence of duties or lead to conflicts of interest.
The receiving of gifts, receptions, hospitality or other benefits to build good relationships or nurture positive commercial practices, and must not interfere with decision making or negligence of one’s duties, with the following guidelines:
- Receiving gifts in the form of cash or cash equivalents, cheques, shares and real estates are prohibited.
- Promotional premiums such as calendars or diaries can be received as personal gifts.
- In case the gifts are premiums given by one organization to another, such gifts are to be regarded as the Company’s assets and should be brought to the Corporate Affairs Department to control distribution of gifts in future occasions.
- The Corporate Affairs Department compiles and summarizes the report to the management on how gifts are used for public benefits or charitable causes, for instance, for donation or as prizes given to staff members.
Purchasing & Procurement
The Company ensures that the procurement of goods and services are carried out fairly and transparently. There are supplier selection, registration and evaluation procedures in place. The Company reserves the rights to terminate relationships with suppliers, service providers or contractors who get involved in corruption or bribery.
Human Resource Management
The Company has identified the practices in human resources management to encourage staff members to perform their duties honestly, transparently and without corruption.
There are clear procedures regarding recruitment, selection, promotion, training, performance evaluation and compensation. Staff members joining the Company must accept and cooperate in the anti-corruption policy by signing on the Business Code of Conduct.