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1. General Principles
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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. |
of nominal value and as infrequent as possible; |
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ii. |
connected to legitimate business, promotional activity or performance of any existing contract consistent with Hitachi Cable’s business practices;
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iii. |
appropriate to the business responsibilities of the employee involved; |
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iv. |
not given to improperly influence relationships or to obtain other special treatment; |
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v. |
in compliance with all relevant laws and regulations, and accepted ethical business conduct, customs and practices;
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vi. |
subject to employees being prohibited from accepting hospitality offered by out-side parties; and
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vii. |
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 |
Gifts which includes but is not limited to hampers and corporate gifts, having value not in excess of RM 100.00 shall be considered of nominal value.
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2.2 |
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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2.3 |
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 that are reasonable in amount and appropriate under the circumstances.
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3.2 |
In offering or receiving any hospitality, the requirements of clause 1.1 of this Policy must be adhered to, particularly clause 1.1, sub-clause (vi) on prohibition.
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4. Entertainment
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4.1 |
Entertainment shall mean, business courtesies, including but not limited to meals, refreshments, parties and sports outings as well as nightclub, theatre, karaoke, and such other entertainment activity.
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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 (vii) on approval.
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