4.1. In respect of any gifts, hospitality and entertainment in the commercial context:-
a. The intention behind giving or receiving any gifts, hospitality or entertainment must always be considered first. It should never be for an improper motive to obtain or retain a business, or to obtain some form of benefit or advantage, whether it is for the business or for the individual employee;
b. If an employee is unsure of how to consider the intention behind any gifts, hospitality or entertainment offered, the employee must always disclose and refer the matter to the immediate supervisor or head of department (HOD) to obtain advice and also approval before proceeding;
c. All employees of the TP Group are not allowed to give or receive any bribe, benefit, gifts, hospitality or entertainment where it is for an improper purpose and can be deemed as a bribery, regardless of whether it is to benefit the employee individually or to benefit the business of any of the TP Group;
d. An employee must obtain prior clearance and approval from the immediate supervisor and/or head of department before giving or receiving any gifts, hospitality or entertainment to or from any person other than that fall under the policy refer clause 7 and clause 8;
e. Where it is difficult or inappropriate to decline the offer of a gift, hospitality or entertainment (i.e. when meeting with an individual of a certain religion/culture who may take offence), it may be accepted but it must be declared and/or surrendered firstly to the employee’s head of department and the compliance team, to assess the relevant circumstances and take the necessary steps, including returning the gift on the employee’s behalf, where appropriate or required to do so.
4.2. Any gifts, hospitality or entertainment provided by TP Group must always be of moderate and reasonable value and should never be given:-
a. With an intention to exert improper influence or create a perception of expectation for certain outcomes beneficial to the business of TP Group; or
b. Where it causes a conflict of interest.
4.3. All employees of TP Group should not give any bribe, benefit, gifts, hospitality or entertainment to person for improper purposes related with TP Group’s business in their personal capacity.