1. What does the Policy cover?
This Sponsorship & Charitable Contribution Policy (“Policy”) sets out the responsibilities of Dufu Technology Corp Berhad (the “Company”) and its subsidiaries (the “Group”) and those who work for the Group on the requirement to observe and the minimum expected standards that must be applied, and it is not exhaustive. Additional requirements may be added by business units according to their specific business needs.
This Policy is related to and must be read in conjunction with several other Group policies. In the event of a contradiction between this policy and another Group policy, this policy must be taken as authoritative. If there is any uncertainty about requirements, then Compliance Officer must be consulted.
Contents:
2. Policy Statement
The Group recognizes it must balance its role as a good steward of its financial resources and its role as an important partner to the community that it serves. To help guide in that effort, this Policy offers guidelines and parameters to aid in responding to the many requests for charitable donations, event sponsorships and in-kind requests received by the Group’s staff.
3. Definition of Sponsorship and Charitable Contribution or Donation
Sponsorship is defined as a business relationship between the Group, as a provider of funds, resources or services and an individual, event or organisation which offers rights and association that may be used for marketing and advertisement purposes in return for the sponsorship investment. Sponsorship in the context of this Policy is specifically aimed at marketing or advertisement activities and not directly at corporate social initiative. Where the latter is also involved, then the Group’s charitable contribution or donation guidelines apply in addition. Sponsorship is a contribution in money or in-kind made by the Group to a third party or an external organisation in support of an event, publication or activity. Sponsorship typically involves the payment of a fee or a payment in kind, such as employee time or use of premises or company assets. Sponsorship is not a donation, for which nothing is to be received in return, but rather a mutually beneficial activity for marketing or advertisement purposes.
Charitable Contribution or Donation represent support given to a group or organization without the anticipation of benefit or tangible business return to the Group. As an important partner to the community, the Group recognizes that there are unmet needs that the Group as an employer can assist in supporting through financial donations and thus, these are given “for the love of mankind”. When donations are made, it must be on the basis that no commercial benefits are being sought in exchange, and there should be no intention or expectation that any such benefits may be forthcoming.
4. General
Sponsorship, Charitable Contribution or Donation (“Expenditure”) encompasses a wide range of activities including funding and in-kind support. When offering or providing either of them:
- It is important to consider the intention for the Expenditure and surrounding circumstances that may be related or seen to be related to the Expenditure. It is important to always consider the perception as well as the facts.
- If the intention is to gain an improper business advantage or to place undue influence on a person responsible for a decision, a service or a contract, then this Expenditure may not be given.
- If there is, or may be, a perception by any other party, that the Expenditure is to gain an improper business advantage, or to place undue influence on any person to secure a decision, a service or a contract, or to induce a person to breach a position of trust, then the Expenditure should not be given.
- Prior to any Expenditure being given, a due diligence must be completed. Such due diligence checks are directed at confirming the good standing of the organisation and ensure there is no risk of bribery or corruption in its activities. Records should be kept of the due diligence procedures and outcome of the review.
5. Giving Practices
1. The Human Resource team administers their respective business unit’s charitable contributions protocols. Monetary Expenditure remain an element of the Group’s giving strategy and must be documented in writing, including the intended recipient, eligibility criteria, endorsed by the relevant approval matrix and payment terms.
2. Requests for sponsorship or donations will be evaluated based upon the following criteria:
a) they meet the Group’s Sponsorship Guidelines and Approval Process;
b) they meet current funding capabilities;
c) they support the Group’s value and strategic objectives;
d) they provide for broad community impact;
e) priority will be given to requests by organizations that provide services in the Group’s service area in the State of Penang.
3. Priority will be given to requests that support youth wellness and education, the disadvantaged and overall community health initiatives. The Group reserves the right to deny any request, at its sole discretion. Funding in prior years does not guarantee continued funding in any subsequent year.
6. Restrictions on Charitable Contributions
The Group will not provide charitable contributions to:
• Individuals;
• Organizations whose primary purpose is to promote political views, influence legislation, or support candidates for public office;
• Organizations that discriminate on the basis of race, ethnicity, nationality, religion, gender, sexual orientation, age or disability;
• Any activities which could reasonably be seen to create a potential reputational risk for the Group.
The Group will not provide charitable giving in a manner that would:
• Be or create the appearance of a bribe, kickback or other corrupt practice.
• Directly procure the Group’s future business or otherwise be made with the intent to obtain or retain business, secure an improper advantage, or induce anyone to act improperly.
• Be inconsistent with applicable law and the Group’s policies.
7. Communication
We encourage any employee to speak to their direct reporting manager if they have any questions about this policy or if they are faced with a situation where they are unsure about how the policy should be applied. If the manager is uncertain of the requirements, then the Compliance Officer should be consulted for clarification.
If any employee is faced with a potential breach of the policy, they should immediately report the matter to their reporting manager. In the event that an employee may wish to report unethical behaviour confidentially, they are encouraged to lodge their complaint in accordance with the Group’s Whistle Blowing Policy where the reporting channel is as follows:
Name: Ms. Joyce Wong Ai May
Position: Chairman of Audit Committee (Independent Non-Executive Director)
Email: joycewong@dufu.com.my
Address: Dufu Technology Corp Berhad, 57-G Persiaran Bayan Indah, Bayan Bay, Sungai Nibong, 11900 Penang.
8. Record keeping
The Finance Team shall keep detailed and accurate financial and other records, and shall have appropriate internal controls in place to act as evidence for all payments made. The Finance Team is to compile and keep a written record of the amount and reason for charitable contribution or donations, sponsorships and expenses of similar nature by whatever name called, and understand that such expenses are subject to managerial review and ensured that relevant approval matrix has been obtained.
9. Monitoring, reviewing and enforcement
The Group’s Compliance Officer is responsible for monitoring the adequacy and operating effectiveness of this Policy and shall review its implementation on a regular basis, including assessing its suitability, adequacy and effectiveness.
Internal control systems and procedures designed to ensure the sponsorship payments or charitable contributions are subject to regular audits to ensure that they are effective in practice.
Any need for improvements shall be applied immediately. Employees are encouraged to offer their feedback on this Policy if they have any suggestions on how it may be improved. Feedback of this nature should be addressed to the Compliance Officer.
This policy has been updated and adopted by the Board of Directors on 1 November 2022.
To talk to our Compliance Officer:
Mr. David Khoo (Chief Financial Officer)
Tel: +604.616 1328
E-mail: davidkhoo@dufu.com.my
