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HITACHI
Hitachi Cable (Johor) Sdn. Bhd.
Zero Tolerance Policy For Corruption And Bribery
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Statement of Policy
HITACHI CABLE (JOHOR) SDN. BHD. (hereinafter referred to as Hitachi Cable) in line with its “Framework Handbook for Business Ethics” and principles of corporate governance, as a good corporate citizen hereby introduces this policy that sets out our commitment to ethical business conduct with all stakeholders including, investors, financiers, employees, suppliers and customers based on a policy on corruption and bribery. Any conduct in breach of the policy stated herein by any stakeholder shall be deemed a corrupt act and/or an act of bribery and shall entitle Hitachi Cable to take all necessary action including termination of contract with a stakeholder in order to enforce the policy stated herein.
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1. General Principle
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1.1 |
All gifts, hospitality and entertainment provided to or accepted from any government officials, customers, partners, principal, sub-contractors and suppliers (all collectively referred to as, “out-side parties”) having business dealings with Hitachi Cable shall be :
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i. |
connected to legitimate business, promotional activity or performance of any existing contract consistent with Hitachi Cable’s business practices;
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ii. |
appropriate to the business responsibilities of the employee involved; |
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iii. |
not given to improperly influence relationships or to obtain other special treatment; |
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iv. |
in compliance with all relevant laws and regulations, and accepted ethical business conduct, customs and practices;
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v. |
subject to employees obtaining approval from the Managing Director before accepting any gift, entertainment, hospitality offered by out-side parties;
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1.2 |
Where an employee is not sure as to wether a certain gift, hospitality or entertainment is legal or acceptable he/she shall refer to his/her immediate superior for guidance as to the right action to take. Prior aproval from the immediate superior must be obtained before incurring such expense or accepting such gift, hospitality or entertainment. Such approval shall only be given where justified by business necessity, in compliance with the law and the policy stated herein.
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2. Gifts
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2.1 |
Cash loans, bribes, payments to induce action or inaction, excessive entertainment or travel, substantial favours or benefits are deemed unacceptable business gifts and cannot be given or accepted.
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2.2 |
In offering or receiving any gifts, the requirements of clause 1.1 of this Policy must be adhered to.
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3. Hospitality
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3.1 |
Hospitality shall mean payments, gifts, offer or promise of anything of value such as lodging and traveling expenses are deem unacceptable.
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3.2 |
In offering or receiving any hospitality, the requirements of clause of this Policy must be adhered to, particularly clause 1.1, sub-clause v. on prohibition.
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4. Entertainment
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4.1 |
Entertainment shall mean, business courtesies, including meals, refreshments, parties and sports outings as well as nightclub, theatre, karaoke, and such other entertainment activity are deem unacceptable.
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4.2 |
In offering or receiving any entertainment, the requirements of clause 1.1 of this policy must be adhered to, particularly clause 1.1, sub-clause v.
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MANAGING DIRECTOR
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KAORU ARAKAWA
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21 MAY 2010 |
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