Employees or members of their immediate families (spouse, mother, father, son, daughter, brother, sister or any of these step- or in-law relationships, whether established by blood or marriage including common law marriage) should not provide, solicit or accept cash or its equivalent, entertainment, favors, gifts or anything of substance to or from competitors, vendors, suppliers, customers or others that do business or are trying to do business with Vintedge.
Loans from any persons or companies having or seeking business with Vintedge, except recognized financial institutions, should not be accepted. All relationships with those who Vintedge deals with should be cordial, but must be on an arm’s length basis. Nothing should be accepted, nor should the employee have any outside involvement, that could impair, or give the appearance of impairing, an employee's ability to perform his/her duties or to exercise business judgment in a fair and unbiased manner.
This Policy does not prohibit normal and appropriate gifts, hospitality, entertainment and promotional or other similar business expenditure to or from Third Parties. However, the key determining factor for appropriateness of the gift or hospitality and/or its value would be based on facts and circumstances under which such gift or hospitality is provided.
The practice of giving gifts and hospitality is recognized as an established and important part of doing business. However, it is prohibited when they are used as bribes. Giving gifts and hospitality varies between countries and sectors and what may be normal and acceptable in one country may not be so in another. To avoid committing a bribery offence, the gift or hospitality must be:
• Reasonable and justifiable in all the circumstances
Intended to improve the image of Vintedge , better present its products and services or establish cordial relations
• Intended to improve the image of Vintedge , better present its products and services or establish cordial relations
The giving or receiving gifts or hospitality is acceptable under this Policy if all the following requirements are met:
• It is not made with the intention of influencing a Third Party to obtain/ retain business or a business advantage or to reward the provision or retention of business or a business advantage or in explicit or implicit exchange for favors/ benefits or for any other corrupt purpose
• It complies with local laws and customs
• It is appropriate in the circumstances. For example, in Singapore it is customary for hampers to be given during Christmas or Chinese New Year
• Taking into account the reason for the gift or hospitality, it is of an appropriate type and value and given at an appropriate time
• It is given openly, not secretly and in a manner that avoids the appearance of impropriety
If you have any question or doubt about whether a gift, meal or entertainment or is appropriate, seek guidance from your supervisor.