When gifts and hospitality are overly abundant, they can be considered as a bribe and/or a conflict of interest. The value of such gifts and hospitality should not exceed the standard or customary standards in our industry. It is generally advisable to avoid them when contracts are being offered or granted. It is necessary to document all presents and entertainment in a dedicated register. With the exception of low-value gifts that are merely symbolic, such as promotional pens, calendars, and stationary, workers are prohibited from accepting any presents from customers, suppliers, or third parties associated with the Company. If declining a present could potentially cause offense or embarrassment, it is permissible to accept the gift and subsequently donate it to a charity selected by the Company. Prior authorization must be obtained from the Operations Manager or an individual of equal authority before taking any present. However, it is strictly prohibited to offer or receive cash as a gift under any circumstances.

‘Corporate Hospitality’ is described as the provision of accommodation, entertainment, or other forms of hospitality only for an employee because of their role as a representative of the Company. The following activities are excluded from the definition of Corporate Hospitality and do not necessitate any approval: Standard working lunches or refreshments offered during a business visit, hospitality provided at a company-sanctioned seminar or industry events such as our annual dinners or employee awards, as long as the hospitality is offered to all participants, complimentary seminars, talks, or workshops, provided they are free for all attendees, all other types of Corporate Hospitality must receive approval from the Operations Manager or equivalent before being accepted. It is important to keep in mind that market practices differ among countries, and what is considered normal and acceptable in one place may not be the same in another. If you have any uncertainty regarding the suitability of a gift or hospitality, please see the Company Secretary.