Sets clear limits on what may be given and accepted, so that hospitality never becomes improper influence.
Scope
This policy applies to all directors, employees and contractors, and to anything of value given to or received from a counterparty.
Principle
Gifts and hospitality are permitted only where they are modest, infrequent, given openly, proportionate to the occasion, and could not reasonably be seen as intended to influence a decision.
Thresholds
A gift or instance of hospitality with a value up to HKD 1,000 may be given or accepted without prior approval, and is recorded in the gifts register. Anything above HKD 1,000, and anything given to or received from a public official regardless of value, requires prior written approval from a director.
Never permitted
Cash or cash equivalents, including vouchers and gift cards, must never be given or accepted. Nothing may be offered or accepted during a live tender, negotiation or award decision involving that counterparty.
Travel and accommodation
Travel or accommodation for a counterparty may be paid only where it is directly connected to a legitimate business purpose such as a site visit, and only with prior approval from a director.
Register
The company maintains a gifts and hospitality register recording the date, the parties, the nature of the gift or hospitality, its approximate value and the approval given. The board reviews the register at least annually.
Reporting a concern
Concerns about any matter covered by this policy may be raised with any director or by email to compliance@inbox.case.sg. Reports made in good faith attract no adverse consequence.