GHEDS Policy

PURPOSE
1. GLIDE TECHNOLOGY SDN. BHD. (hereinafter referred to as “GTSB” or “Company”) is committed to ensuring zero-tolerance against all forms of bribery and corruption. In line with this commitment, GTSB has developed its Gift, Hospitality, Entertainment, Donation, and Sponsorship (“GHEDS”) Policy. The Policy is intended to elaborate upon its principles and provide guidance to employees and directors concerning gift, hospitality, entertainment, donation, and sponsorship that may arise in the course of business which could be potentially misused as a form of bribery and corruption.
2. The Policy is established to govern the acceptance, evaluation, and recognition of all types of gift, hospitality, entertainment, donation, and sponsorship.
3. GTSB requires directors, employees, members, consultants, vendors, contractors, external agencies, or any parties with a business relationship with GTSB (“Business Associates”) to abide by this Policy. This is to avoid the misuse of gift, hospitality, entertainment, donation, and sponsorship for either party in on-going or potential business dealing between GTSB and external parties as gift, hospitality, entertainment, donation, and sponsorship can be regarded as a bribe that may tarnish GTSB's reputation or violate anti-bribery and corruption laws.
SCOPE
1. The scope of this Policy applies to all GTSB's employees (permanent, contract or part-time), directors, members, consultants, vendors, contractors, external agencies, Business Associates, or any other parties engaged with GTSB (“Third Parties”) who receive, provide, authorise, accept, value, or record gift, hospitality, entertainment, donation, and sponsorship.
2. This Policy explicitly excludes employee welfare, commemorative gift, and non-business relationship related item, including but not limited to employee benefit and perk, honorary gift, milestone achievement gift, marketing-related item, and free merchandise printed with Company's logo.
3. For the purpose of this Policy, the GTSB's top management and its employees will be collectively referred to as “Personnel”.

DEFINITIONS

Term	Definition
Gift	A tangible item given from one individual to another, with the intention of creating or enhancing work and business relationships. This includes, but is not limited to: cash shares lottery tickets travelling facilities entertainment expenses services club memberships any form of commission jewellery decorative items hampers or any other items of value
Hospitality	Taking care of an individual and anticipating needs in circumstances related to business. This includes, but is not limited to, business-related travel expenditures, accommodation, and corporate and social events or activities used to network, promote goodwill, and build business relationships.
Entertainment	An act of hospitality intended to foster good working and business relationships. Examples include, but are not limited to: leisure, social or sport events functions or occasions meals or refreshment
Donation	An unconditional gift or voluntary contribution of monetary value from GTSB to organisations, individuals, societies, or any parties requiring cash or in-kind contributions. Donation initiatives may originate within GTSB or be made in response to external requests.
Sponsorship	An undertaking by GTSB to pledge monetary value to support external efforts that are expected to provide a favourable return on investment.
Due diligence	Verifying the identity of the recipient; ensuring the appropriateness of the charity or recipient organisation; and confirming the cause aligns with GTSB objectives.

POLICY
1. GTSB personnel are required to exercise proper judgement in accepting and providing gifts, entertainment and hospitality and act consistent with the general principles set out below:
  1. Uphold high standards of integrity;
  2. Exercise reasonable care and proper judgement;
  3. Avoid conflicts of interest;
  4. Refrain from misuse of position, title or any authority associated with GTSB for personal gain;
  5. Comply with applicable laws, regulations and GTSB policies and procedures.
2. Receiving and Providing of Gift
  1. Employees are not permitted receiving any gifts, including sponsorships, from contractors, vendors, suppliers, friends, business partners, or donors if related to the implementation of official duties, or if the form, amount, or value of the gift does not align with its intended purpose.
  2. Any gift offered shall be politely declined and returned without offending or disrupting the business relations with the other party, with the explanation that acceptance of the gift is not permitted under the GTSB's policy.
  3. If an external provider still insists on giving a gift even after explanation of the Gift Policy or it is offensive or not practical to refuse the gifts, the personnel must immediately inform his or her superior and Integrity Officer. A duly completed Gift and Hospitality Declaration Form (Attachment 1) shall be submitted to Integrity Officer.
3. Gift Exemptions
  1. Exchange of gifts at the company-to-company level (e.g. gifts exchanged between companies as part of an official company visit/courtesy call and thereafter said gift is treated as company property).
  2. Gifts to external institutions or individuals in relation to the GTSB's official functions, events and celebrations (e.commemorative gifts or door gifts offered to all guests attending the event).
  3. Gifts to the employees and/or their family members in relation to an internal or externally recognised GTSB function, event and celebration (e.g. in recognition of an employee's).
  4. Token gifts of nominal value normally bearing the GTSB logo (e.g. diaries, calendar, pens, mugs or other small promotional items) or that are given out equally to members of the public, delegates, customers, partners and key stakeholders attending events such as conferences, exhibitions, training, trade shows etc. deemed as part of the GTSB's brand building or promotional activities.
  5. Gifts to external parties who have no business dealings with the GTSB (e.g. monetary gifts or gifts in-kind to charitable organizations).
  6. A perishable item (e.g., festive cookies, delicacies during festive season or fruits)
4. The gifts provided or received shall not exceed an estimated value of RM 1,000.
5. The provision of gift shall be recommended by the HOD and approved by the CEO.
6. Providing or receiving Gift for amount < RM 500
  1. The gift shall be declared in Gift and Hospitality Declaration Form and submitted to the Integrity Officer (IO) to evaluate and make decision on the gifts as per clause 4.6
7. Providing or receiving Gift for amount > RM 500 ~ RM1,000
  1. The gift shall be declared in Gift and Hospitality Declaration Form and submitted to the CEO to evaluate and make decision on the gifts as per clause 4.6
8. Receiving Gift for amount > RM1,000
  1. Where the value of gifts received exceeds the monetary threshold of RM1,000 or could not be determined, GTSB personnel shall declare the gift received by completing the Gift and Hospitality Declaration Form and submit it to CEO.
  2. Upon declaration of receipt, Integrity Officer/CEO to make decision on the gifts offered/received based on, but not limited to, the following options:
    - Donate to charity;
    - Register as company property for general use;
    - Display in common area; or
    - Share the gift with all employees
  3. In making decisions, the IO/CEO shall consider the following:
    - The acceptance of the gift does not violate any regulations under the Malaysian Anti-Corruption Commission Act 2009;
    - The acceptance of the gift does not raise suspicion that the staff has used their position to obtain the gift;
    - The frequency with which the staff receives gifts;
    - The relationship between the staff and the person or party offering the gift; and
9. Receiving of Entertainment and Hospitality
  1. Where there is a business purpose in connection with GTSB, occasional acceptance of an appropriate and moderate level of entertainment provided by external parties is recognized as a lawful way of creating goodwill and enhancing business relationships. Receiving entertainment confines to only occasional meals which are not lavish.
  2. GTSB's personnel should always exercise proper care and judgement in determining the appropriateness of the entertainment provided by an external party to protect GTSB's reputation from allegations of impropriety or undue influence.
  3. The family members of GTSB's personnel by no means can accept entertainment in exchange for the exercise of GTSB authority or conversely to the disadvantage of GTSB.
  4. GTSB strictly prohibits its personnel from soliciting hospitality nor are they allowed to accept hospitality in any form. There is concern that acceptance of hospitality particularly from a repetitive source and/or where a considerable degree of hospitality is involved may expose the individual and the GTSB to allegations of impropriety or undue influence.
10. Providing of Entertainment and Hospitality
  1. To encourage good business relationships, GTSB recognizes that providing moderate entertainment is a common practice in the business setting for building rapport with external clients
  2. GTSB personnel should be mindful when providing entertainment, as perception is often more important than fact. They must always exercise proper care and judgment to ensure compliance with local anti-bribery and corruption laws
  3. Providing or offering entertainment to exert undue influence for any future benefit or outcome is strictly prohibited. Entertainment is limited to occasional, non-lavish meals. Whether provided directly or indirectly through an intermediary, such actions may be construed as bribery and conflict with established principles.
  4. GTSB personnel are required to comply with established policies and procedures and to track expenses incurred during entertainment activities.
  5. GTSB strictly prohibits its personnel and agents from providing hospitality in any form, except for official business purposes, when dealing with external parties.
11. Dealing with Public Official
  1. Providing gifts, entertainment, or hospitality to government officials or their family members is strictly prohibited, except for the entertainment provisions outlined in Paragraph 4.9 of this Policy. Reasonable due diligence should be exercised, especially when arrangements involve government officials.
  2. GTSB personnel must adhere to and be aware of prevailing laws and regulations to ensure compliance. They should conduct reasonable due diligence when dealing with local and foreign public officials to prevent violations.
12. Political Contribution and Facilitation Payment
  1. GTSB does not make donations or contributions to political parties, nor will it reimburse its personnel for any political contributions made in their personal capacity.
  2. Any form of facilitation payment, whether by GTSB or by individuals performing services for or on behalf of GTSB, intended to facilitate or expedite any routine procedure, is not permitted.
  3. Any request for facilitation payments received during business activities by GTSB personnel or associated individuals must be immediately declined and reported to the Integrity Officer for an official report.
  4. Facilitation payments are permissible only when an individual's safety is compromised, such as in situations requiring a payment to ensure safe passage.
13. Donation and sponsorship
  1. GTSB recognizes that providing donations and contributions can pose a bribery risk, as these payments to third parties may lack tangible returns and could be used as a cover for bribery
  2. In accordance with this Policy, all donations and contributions are subject to the following criteria:
    - They must be made to a legitimate recipient
    - They must not be made directly or indirectly to influence, or be reasonably perceived as influencing, business transactions or obtaining an advantage;
    - They must comply with applicable laws and regulations; and
    - They must not be made before, during, or immediately after contract negotiations
14. To avoid any doubt, donations and contributions are strictly prohibited in the following situations:
  1. Any request for donation or contribution includes a direct or indirect suggestion, hint, understanding or implication of an expected or desirable outcome;
  2. Any donation or contribution that is illegal or in violation of applicable laws; or
  3. Any donation or contribution that is excessive or could tarnish the reputation of GTSB
15. Charitable contributions, donations and sponsorship made by GTSB to community or charities shall be evaluated in accordance with this Policy to ensure compliance prior to endorsement and made in good faith. In addition, it must be supported with valid documentation and approved by the CEO.
16. GTSB shall conduct due diligence to ensure that the recipients of any charitable contribution, donations or sponsorship are legitimate. The following factors to consider include, but are not limited to:
  1. The proposed recipient has no affiliations with government officials, or the relatives/ close members are involved
  2. The funds are not intended personal interest; or
  3. There is no risk of perceived improper and undesired impact to the Company
17. All requests must be made by registered organizations on their official letterhead to GTSB regardless of value.
REPORTING
1. Any Personnel who knows of, or suspects of, a violation or potential violation of this Policy shall report their concerns through the whistleblowing channel set out in the GTSB Whistleblowing Policy.
PENALTIES
1. Any violation of this GHEDS Policy may result in disciplinary action, including but not limited to termination of employment.
REVIEW OF POLICY
1. Modification may be necessary for various reasons, including maintaining compliance with laws and regulation and accommodating organizational changes within the Company. Therefore, this Policy shall be reviewed in its entirety on an annual basis or as needed to ensure the continued relevance and appropriateness of its contents.