We focus on good governance practices and foster a responsible and transparent corporate management to deliver the best values to our customers.
Whistleblowing Policy
This whistleblowing policy gives us all the opportunity, reassurance and confidence to disclose information or concerns that we may have about the conduct of others in the business or the way in which the business is run. All employees including other individuals performing functions in relation to the company, such as agency workers and contractors, are encouraged to use it.
This policy sets out the ways in which you can raise any concerns that you have and how those concerns will be dealt with.
Summary
- Disclosures will be investigated thoroughly, promptly and confidentially.
- Anyone who raises genuine concerns is considered to be a valuable asset to our company.
- You will be protected from dismissal or victimization if you follow the whistleblowing policy when making a disclosure.
- If you believe you have suffered a detriment after making a protected disclosure you can raise a grievance via the grievance procedure.
- If misconduct is found as a result of an investigation under this procedure the disciplinary procedure will be used, in addition, to any external measures.
- Maliciously making a false allegation is a disciplinary offence.
Treating Customers Fairly
Our employment policies and procedures have been reviewed to ensure that they align and support Treating Customers Fairly. In our employment policies and procedures, we seek to demonstrate the values and principles outlined in our Code of Conduct, Which provides a strong foundation for our work on ensuring that we treat our customers fairly.
Core Values
0.1 Direct
Be direct, focus on what’s necessary as long as customers interests and needs are preserved.
0.2 Honesty
Authenticity and honesty are key to convince and change the mindset of customers.
0.3 Caring
We understand what customers are facing; therefore, we need to speak with care and empathy.
0.4 Courageous
Expand our comfort zone in the pursuit of challenging status quo, mediority.
0.5 Truthful
Disrupt industry and change customers narrative towards insurance with authentic, pure insurance products.
0.6 Empathetic
Solving customer’s problems and ensuring their meets are fulfilled are our main priorities.
Our core value underpins everything we do. In particular with regards to the whistleblowing policy we aim to:
Act lawfully and do what is right
- Understand and comply with legal requirements
- Act professionally and with integrity
We play vigorously but fair
- We set ourselves high standards and demand a lot of ourselves
- We maintain and preserve proper business records and follow accurate, complete and fair reporting to meet our legal and financial disclosure obligations
We make decisions using the right standards
- In making a decision we ask: is it legal / the right thing to do?
- Look for objective information to make informed decisions.
Whistleblower Protection Act 2010
An Act to combat corruption and other wrongdoings by encouraging and facilitating disclosures of improper conduct in the public and private sector, to protect persons making those disclosures from detrimental action, to provide for the matters disclosed to be investigated and dealt with and to provide for other matters connected therewith.
- a criminal offence
- a miscarriage of justice
- an act creating risk to health and safety
- an act causing damage to DearTime Assets or the environment in general
- a breach of any legal/statutory obligations or company policies and procedures including its authority limits
- concealment of any of the above
Is being, has been or is likely to be, committed. It is not necessary for you to have proof that such an act is being, has been or is likely to be, committed – a reasonable belief is sufficient. You have no responsibility for investigating the matter – it is the organisation’s responsibility to ensure that an investigation takes place.
Each of the categories listed above involve some form of malpractice or wrongdoing and they are collectively referred to in the statutory provisions as the “relevant failures”.
Our policy covers a wide range of suspected or actual behaviours which cause concern and some specific examples include:
- fraud or other wrong doing
- financial irregularities
- breaches or omissions that could lead to a breach of DearTime Code of Conduct, internal compliance rules and legal or regulatory obligations
- unethical behaviour
- theft/misuse of company property or information
- abuse of expenses
- dishonesty
If you make a disclosure, you have the right not to be dismissed, or subjected to victimisation, because you have made the disclosure.
Internal Procedure for Reporting Concerns
If you are considering whistleblowing, you are encouraged to first raise your concerns with your line manager.
If you do not feel confident about disclosing information to your line management, you can contact your Compliance Officer to discuss your concerns.
The Compliance Officer is as follows:
You can raise concerns by making a report via email and sending it to any of the following Compliance Officers:
- Jon Ng (CEO) – jon.ng@deartime.com
- Confidential email – whistleblowing@deartime.com
Any email sent to the Compliance Officer is duly indicated as “whistleblowing” and will be dealt strictly within the provisions of this policy.
Investigation of Reported Concerns
All concerns reported will be investigated thoroughly, promptly and in ways which protect your identity if this is what you wish.
You are advised to make your disclosures in writing and to provide sufficient details which include the following:
- the type or description of improper conduct;
- the name of individuals who have committed or are involved in the improper conduct; and
- the ‘how’, ‘what’, and ‘where’ in relation to the improper conduct including supporting documents or evidence, if any.
You are encouraged to provide their identities or contact details to facilitate Compliance to clarify or obtain further information for purposes of further investigation into the improper conduct. Any person who elect to remain anonymous is advised that no whistleblower protection will be accorded and DearTime’s ability to investigate the alleged improper conduct is limited to the extent of the contents of the report received.
You will be notified once the investigation has been completed unless the report was submitted anonymously.
Prescribed Regulators
If you don’t believe the concern can be dealt with internally or on conclusion of the investigation, you don’t reasonably believe that the appropriate action has been taken you should report the matter to the appropriate authority which includes:
BNMLINK (Walk-in Customer Service Centre)
Ground Floor, D Block
Jalan Dato’ Onn
50480 Kuala Lumpur
BNM TELELINK (Contact Centre)
Bank Negara Malaysia
P.O. Box 10922
50929 Kuala Lumpur
Tel: 1-300-88-5465
Operating Hours: 9.00 a.m. – 5.00 p.m. (Monday – Friday)
You are protected if you reasonably believe that the subject matter properly falls within the prescribed person’s remit, the disclosure is made in good faith and that the information and any allegation in the information are substantially true.
Where you can find out more
To find out more, or if you have any questions, you can talk to your manager or your Compliance Officer and you can seek advice and information on company policies from Compliance.
What our whistleblowing policy is not for
It is not to be used to:
- Act maliciously or make deliberately false allegations
- Seek personal gain
- Disagree with decisions made by management
- Challenge practices and policies with which you disagree where there are other channels open to you (e.g. line management, grievance procedure, harassment & bullying policy, and UFS or Unite).
You should be aware that the policy will apply where a disclosure is made in good faith and where you reasonably believe that the information disclosed and any allegation contained in it are substantially true. If any disclosure is made in bad faith (for instance, in order to cause disruption within the organization), or concerns information which you don’t substantially believe is true, or if the disclosure is made for personal gain, then such a disclosure will constitute a disciplinary offence.
Please remember that DearTime regards anyone who raises genuine concerns as an asset to our business.
Exclusion from Protection
Potential whistleblowers are also reminded that there may be instances wherein their protection would be revoked or excluded. The whistleblower protection does not extend to the following disclosures and will be revoked pursuant to section 11 of the Whistleblower Protection Act 2010:
- where the disclosures of improper conduct which are –
- frivolous or vexatious;
- principally questioning the merits of government policy, including policy of a public body;
- known to the whistleblower to be false or untrue; or
- made solely or substantially to avoid dismissal or other disciplinary action;
- where the whistleblower has participated in the improper conduct so disclosed;
- where the whistleblower commits an offence under the Whistleblower Protection Act 2010; or
- where the disclosures of improper conduct which contain information specifically prohibited from being disclosed under any written law such as the Official Secrets Act 1972.
Any person who makes a disclosure of improper conduct, knowing or believing that any material statements in the disclosure is false or untrue commits a criminal offence under the Whistleblower Protection Act 2010.
FAQ
I have suspicions that a colleague has not followed the correct FSA procedure when dealing with a customer, what should I do?
In the first instance you should raise your concerns with your Manager. If you do not feel confident about disclosing information to your line management you can contact your Compliance Officer to discuss your concern.
Compliance Officers:
- Jon Ng (CEO) – jon.ng@deartime.com
- Confidential email – whistleblowing@deartime.com
After making a disclosure I believe I have suffered a detriment – can I make a formal complaint?
Yes, you should do this by getting in touch with our Company Secretary (osem@quadrantbiz.co) to send your grievance/complaint to the Chairman of the Audit Committee.
I am concerned that I may suffer repercussions if I do report an incident, how can the Company ensure this will not happen?
If you do make a disclosure in good faith and where you reasonably believe that the information disclosed and any allegation contained in it is substantially true, you have the right not to be dismissed or subjected to victimisation for making the disclosure and DearTime will consider disciplinary action if it is found that this has happened as a result of the disclosure being made.
If I do report an incident, will I be kept informed with developments?
You will be advised once any investigation has been completed.
What should I do if I feel an incident has not been dealt with appropriately by the Company?
If you feel this is the case, you can report your concerns to the appropriate authority which could include Bank Negara Malaysia.
Where can I find out more about Whistleblowing?
The Whistle-blower Protection Act 2010 is available online at here.
Client Charter
Ensure that relevant, accurate, balanced and timely information is made. Read more.
Anti Fraud Policy
DearTime Berhad’s vision is covering every human life directly with life insurance, and restoring the quality and quantity of life for those in times of need. Given this, the company has no appetite for Fraud be it internal or external. In this respect we have in place the following anti-fraud measures:
- A comprehensive Anti-Fraud Policy
- “whistle blowing policy”. If you have information on or suspect of fraudulent practices, regardless of who it may be within DearTime Berhad, or any of our partners, or our Policyholders or Suppliers please let us know immediately via our secure email whistleblowing@deartime.com. We ensure full confidentiality of information provided and immediately investigate issues raised.
- Where appropriate and necessary conduct checks with a licensed credit referencing agency and a record of any such search on an insured will be retained in the file. This information may also be exchanged with other insurers through various authorized and approved databases to ensure accuracy, mindful of the Data Protection Act. This information can also be disclosed to regulatory authorities in response to formal requests.
- Our Compliance team investigate all fraudulent cases
- We maintain close working relationships with the following enforcement authorities including Bank Negara Malaysia :-
- Polis Diraja Malaysia
- Malaysia Communication and Multimedia Commission
- Ministry of Domestic Trade, Co-operatives and Consumerism
- Securities Committee Malaysia
- Cyber Security Malaysia
- In Dealing with Fraudulent Cases – We are guided by our internal policy and procedure and our staff who are well trained to detect the possibility of fraud. We will handle all fraud investigations expeditiously and swift and tern action will be taken if indeed there is evidence of fraud. DearTime would not hesitate to take legal action against fraudsters who target the company, its staff or customers.
Anti-Bribery & Anti-Corruption (ABAC) Statement
DearTime Berhad’s (“DearTime or the Company”) Mission, Vision, and Values
Mission
Covering every human life directly with life insurance and restoring the quality and quantity of life for those in times of need.
Vision
Closing insurance penetration gap and democratizing insurance industry by making life insurance products and processes affordable, simple, and accessible to everyone through fully digital means for a complete and effortless digital insurance experience.
Corporate Values
Push Humanity Forward
- Solve people’s problems
- Advance humankind into the future.
- Cultivate staff creativity & innovation.
Uphold Equality & Human Rights
- Everyone deserves life insurance.
- A healthy, happy life is meant for all
- Every staff deserves a chance.
Foster Love & Kindness
- Promote social & charitable living.
- Be the catalyst for love & kindness.
- Happy staff, happy customers.
Be Transparent Always
- Practice highest level of transparency.
- Internalise integrity and honesty.
- Open communication between staff.
Anti-Bribery & Anti-Corruption Policy
The Anti-Bribery & Anti-Corruption (“ABAC”) Policy seeks to provide guidance, support the effective implementation of “adequate and proportionate procedures” to Bribery and Corruption (“B&C”) risks for DearTime. The Policy is aligned with the Prime Minister’s Office (PMO) issuance of the Guidelines on Adequate Procedures, which sets out the principles as follows:
- Top Level Commitment
- Risk Assessment
- Undertake Control Measures
- Systematic Review, Monitoring and Enforcement
- Training and Communications
This Policy aims to set out best practices on policies, procedures, and processes for each Principle which in aggregate would support the effective implementation of adequate procedures to prevent or mitigate the occurrence of B&C practices.
The requirements of this Policy are also to facilitate DearTime in observing and supporting its risk appetite statements, which are:
Statement 5 – DearTime has a very low appetite for reputational risk exposure that impacts the company’s reputation and/or brand. Steps to minimize the likelihood of adverse reputational impact should always be taken.
Statement 6 – DearTime will promptly take action to address customers complaints and regulatory concerns.
Statement 11 – DearTime has zero appetite for internal fraud activities.
Statement 12 – DearTime has a strong compliance culture especially in ensuring that customer’s interests are safeguarded at all timeT
Scope
This Policy relates to the all-insurance related activities within DearTime and applies to all Employees and Associated Persons.
Definitions
For the purpose of this Policy, the following definitions will apply: –- Bribery and Corruption is defined as offering (or agreeing to give), soliciting, or accepting (or agreeing to accept) bribes and other improper financial advantages. Employees and/or Associated Persons of DearTime must not provide “anything of value” (financial or otherwise) to obtain or retain any business or advantage.
- “Employees” include directors, all employees (whether temporary, fixed-term or permanent) and interns.
- “Anything of Value” extends beyond cash or cash equivalents to include:
- Improper gifts and entertainment
- Travel and/or lodging
- Charitable and political contributions
- Employment or internships for clients, government officials, or their related persons.
- “Associated Persons” of DearTime include business partners, contractors, consultants, suppliers, vendors, and any person with whom the Company is doing business with or anticipates doing business or performing a service for or on behalf of the Company.
- “Bribery” refers to the act of corruptly authorizing, giving, agreeing to give, promising, offering, soliciting, receiving, or agreeing to receive any gratification.
- “Corruption” means an act of giving or receiving of any gratification or reward in the form of cash or in kind of high value for performing task in relation to his/her job description.
- “Gratification” as defined under the MACC Act, as amended from time to time, and shall include but not limited to:
- money, donation, gift, loan, fee, reward, valuable security, property, or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;
- any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
- any payment, release, discharge or liquidation of any loan, obligation, or other liability, whether in whole or in part;
- any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction, or percentage; e) any forbearance to demand any money or money’s worth or valuable thing;
- any other service or favour of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and
- any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding bullet points.
Policy Statement
- DearTime has a zero-tolerance position for bribery and corrupt (B&C) activities.
- DearTime is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, and is committed to implementing and enforcing systems that ensure corruption and bribery is prevented.
- In particular, the Board of Directors and Senior Management of DearTime do not condone or consent to any Associated Persons:
- corruptly soliciting, receiving, or agreeing to receive any gratification whether for him/herself or for any other person; or
- corruptly giving, agreeing to give, promising, or offering to any person any gratification whether for the benefit of him/herself or of another person, as an inducement to or reward for:
- obtaining or retaining business for DearTime; or
- obtaining or retaining any advantage in the conduct of business for or affairs of DearTime or for any other person; or
- doing or forbearing to do anything in respect of any matter or transaction in the conduct of business for or affairs of DearTime.
- DearTime treats any violation of the ABAC Policy seriously and will undertake necessary actions including but not limited to, review of employment or appointment, disciplinary actions, dismissal, stop third party contractors/service providers from further business dealing etc., as well as report to the relevant authorities any wrongdoings, consistent with the requirements of the relevant laws and regulations.
Roles and Responsibilities
- DearTime shall develop, implement, and maintain this DearTime ABAC Policy.
- Board:
- The Board is responsible for providing oversight and establish “tone-from-the-top” for maintaining highest level of corporate integrity and ethics, compliance with applicable laws and regulatory requirements on anti-bribery and corruption.
- Senior Management Team (SMT):
- SMT is responsible for developing and maintaining this DearTime ABAC Policy with the support of the Chief Risk and Compliance Officer.
- SMT is responsible to ensure that all Employees and Associated Persons of DearTime practices the highest level of integrity and ethics.
- SMT is responsible to ensure all Employees and Associated Persons of DearTime complies fully with the applicable laws and regulatory requirements on anti-corruption.
- SMT is responsible to ensure that key B&C risks within the Company is adequate managed.
- SMT is responsible to ensure that the DearTime ABAC Policy is approved by the Board.
Principles of the Bribery and Corruption Program
The section sets out the principles of TRUST in alignment with the Prime Minister’s Office (PMO) issuance of the Guidelines on Adequate Procedures: –
- Top Level Commitment
- The Board and SMT must establish a strong ‘tone from the top’ to convey its commitment to zero tolerance for bribery and corruption.
- SMT must ensure that the Board is made aware of their B&C exposure and the effectiveness of its B&C program via any appropriate methods or channels e.g. reporting, attestation etc.
- DearTime shall have a framework by which individual deficiencies in B&C control execution are assessed and rectified.
- DearTime shall have an effective whistleblowing mechanism to promote culture of integrity and transparent communication.
- Risk Assessment
- DearTime shall consider whether B&C risk should be assessed as a standalone document, or whether the assessment should be part of a larger family of risks (e.g., non-financial risk, conduct risk, financial crime risk, etc.). This shall depend on factors which may include the size, complexity, and business/products of DearTime and its B&C risk assessment may be for the DearTime as a whole, or may be conducted based on business line/unit, function level.
- The B&C risk assessment shall be undertaken on a periodic basis, or a trigger basis, or a combination of both. Potential triggers include materially relevant audit findings, changes in underlying business and significant changes in control execution.
- Undertake Control Measures.
- Policies and Procedures are important tools to establish clear rules, guidelines, and standard operating procedures to mitigate B&C risk.
- The following are some important elements of DearTime’s B&C program:
- Definitions – relevant terms and corresponding definitions as prescribed in the MACC Act or any other relevant acts or standards. Example of key terms may include “Corruption,” “Bribe” (or “Gratification”), “Facilitation Payment,” “Public Official” (which may be defined to effectively include employees of Government Linked Companies as well as foreign officials) and “Associated Person.”
- Prohibitions – DearTime prohibits the offer, promise, or payment of bribes by its employees, and its Associated Persons. DearTime also prohibits the offer, promise, or payment of facilitation payments, although consideration may be given to circumstances of duress such as physical danger.
- Gift, entertainment, hospitality, and travel (collectively, “G&E”) – G&E can play an important and appropriate role in ordinary and customary business relations, including the opportunity to discuss business-related matters in less formal settings, the recognition of holidays and other cultural events, and the expression of ordinary social courtesies. Please refer to Appendix 1: Guidelines on G&E for DearTime’s policy on G&E.
- Sponsorship/Charitable Payments – Due diligence must be conducted on recipients of sponsorship or charitable payments to ascertain that they are of good standing. Please refer to Appendix 1 for additional guidance and Appendix 2: Gifts, Benefits and Sponsorship Declaration Form. For the avoidance of doubt, this does not include DearTime’s Charity Insurance or Thanksgiving.
- Political Contributions – No political contributions are permitted.
- Use of Third Parties including business partners – DearTime shall ensure that third parties are subjected to B&C controls to mitigate DearTime’s exposure of B&C risk. This includes due diligence of the third party, document verification, relevant contractual provisions, and periodic refresh of the controls.
- DearTime seeks to ensure that a conflict of interest does not affect the interests of DearTime, its shareholders, clients and other stakeholders through identification, prevention and management of the conflict of interest. All Associated Person shall declare any personal interest he/she or persons connected to the Associated Person may have in any DearTime’s decision or matter he/she is involved in.
- Internal and external parties to DearTime are encouraged to raise concerns in relation to real or suspected corruption/bribery incidents or inadequacies of the ABAC Policy at the earliest opportunity. The concerns can be raised via an email to the following email address anonymously; whistleblowing@deartime.com.
- DearTime also practices other control measures via its financial controls, where payments are governed by the relevant authority limits and approvals.
- DearTime shall maintain adequate records of provision and receipt of G&E, charitable payments, and political contributions, including a description of cost and nature of the expenditure, the business purpose, the details pertaining to the giver and recipient and (where applicable) evidence of any approvals.
- Systematic Review, Monitoring and Enforcement
- DearTime shall ensure regular reviews are conducted to assess the performance, efficiency, and effectiveness of the B&C program and that the program is enforced effectively.
- B&C-related risks should be incorporated into DearTime’s overall internal audit program, whichwill be designed with DearTime’s needs, risks, and structure in mind, with due escalation of the outcome of the audits to the Board Audit Committee for oversight (upon licensing).
- DearTime shall take appropriate disciplinary action against Employees and/or Associated Persons found to be non-compliant with the ABAC Policy.
- Training and Communications
- DearTime shall develop and disseminate internal and external training and communications relevant to its B&C program, in proportion to its operation, covering policy content, its commitment, training, reporting and whistleblowing channels and consequences of non-compliance.
Other Related Policy, Regulations and Act
- Financial Services Act 2013
- Islamic Financial Services Act 2013
- BNM/RH/PD 028-9 Compliance
- BNM/RH/PD 028-15 Operational Risk
- BNM/RH/GL 013-5 Risk Governance
- S17A (5) Malaysian Anti-Corruption Act (MACC) 2009
- Guidelines on Adequate Procedures to Section 17A (5) MACC 2009- Prime Minister’s Department (PMO)
Other Matters
Any material amendments or material exceptions to this policy will require Board approval. The materiality of the amendment or exception shall be determined by the CEO. For any amendment deemed non-material (e.g., typo, structural change to wording while maintaining meaning etc.) the CRCO (or the equivalent) has the right to make the change at any time with or without notice.
For exceptions to the policy which are deemed non-material or where compliance to the policy will be inconsistent with the policy intent, exceptions may be granted at the discretion of the CEO supported by exception requests made in writing.
Appendices
Appendix 1: Guidelines on G&E
- Unless expressly permissible and, when required, pre-approved by the CEO provided in these Guidelines, DearTime and its Associated Persons, shall not give, agree to give, promise or offer, solicit, accept or use, directly or indirectly any gifts such as gratuity, favour, loan, hospitality and/or entertainment, or anything of monetary value to/from a person or corporation, at any time, in the course of their official duties or in connection with any of DearTime’s operations or any transaction DearTime intends to enter or is a party to.When and where pre-approval is required by these Guidelines, the requesting employee shall use the Gifts, Benefits and Sponsorship Declaration Form to submit his/her application for approval. There are circumstances where the Guidelines do not require pre-approval, but disclosure of gifts, entertainment or sponsorship for the senior management’s knowledge and oversight. Under these circumstances, the Gifts, Benefits and Sponsorship Declaration Form shall be used for disclosure purposes.
- The prohibition shall include, but not limited to:
- Gift which is part of an attempt or agreement to do anything in return;
- Gift which is being made to influence the Board of Directors’ or officer’s actions as such;
- Gift which could create the appearance of a conflict of interest;
- Gift in the form of cash, cash vouchers or e-vouchers of any amount;
- Receive sponsorship in any form for any of the internal programs, activities, and affairs of DearTime such as annual dinner, anniversary commemorations and other similar events;
- Business trip sponsored by consultants, suppliers, customers, business partners etc. unless justified and pre-approved by the CEO;
- Arranging or accepting entertainments during business dealings unless justified and pre-approved by the CEO; and
- Facilitation (or grease) payments which are payments outside published fee schedules, no matter how small, made to the public officials or persons of influence to expedite or “facilitate” performance of non-discretionary, routine governmental actions (e.g., obtaining a license, processing government papers, tax matters etc.). Under no circumstances may any of DearTime’s employee make facilitation payments in any form although consideration may be given to circumstances of duress such as physical danger.
- There are situations whereby the provision and receiving of gifts and entertainment are permitted which are as follows:
- Gifts that may be received or given in the customary and normal course of business, as may be determined, and approved by the CEO:
- Gift giving to a Public Official: If the fair market value of a gift provided to a Public Official is less than RM100 and meets all the requirements of this Policy, no pre-approval is required, but the requesting employee providing the gift or entertainment must complete the Gifts, Benefits and Sponsorship Declaration Form for disclosure purposes prior to giving the gift or entertainment. If the fair market value of the gift or entertainment provided to a Public Official is equal to or more than RM100 or does not meet all the other requirements of this Policy, approval from CEO is required before such gift or entertainment can be provided to the Public Official.
A Public Official is any domestic and international government official, including with no limitation to: (1) any elected or appointed officials; (2) employees of any executive, legislative, or judicial department, agency, or instrumentality of any government, from the local level to the national level, regardless of rank or authority; (3) persons acting in an official capacity on behalf of any government official or entity, whether paid or unpaid; (4) officers and employees of political parties; (5) candidates for political office; (6) officers and employees of state-owned or state controlled business, school, hospital, or other entity; (7) Royalty, even with simple ceremonial functions; and (8) officers and employees of public international organizations or any departments or agency thereof (such as, the United Nations, the Red Cross, and the World Bank). - Gift giving to a commercial entity: Any gift or entertainment to be given to a commercial entity with the fair market value that is more than RM400 requires pre-approval on the Gifts, Benefits and Sponsorship Declaration Form even though all other requirements and conditions in this Policy have been met. If the fair market value of a gift provided to a commercial entity is less than RM400 and meets all the requirements of this Policy, no pre approval is required, but the requesting employee providing the gift or entertainment must complete the Gifts, Benefits and Sponsorship Declaration Form for disclosure purposes prior to giving the gift or entertainment.
- Receiving Gifts: Employee shall report any gift, entertainment, or sponsorship he/she is offered or has received on the Gifts, Benefits and Sponsorship Declaration Form. CEO may make the following decisions with respect to the gift, entertainment or sponsorship reported to him/her: 1) permitting the employee to receive or keep the gift or benefit; (2) permitting the employee[s] to receive the offered sponsorship; (3) collecting the gift and redistribute it to all employees especially suitable for food items); (4) collecting the gift from the employee for the benefit of the company; (5) directing the employee to reject the gift and return it to the giver, or reject the offer of benefit or sponsorship; or (6) other decisions the CEO deems appropriate and consistent with DearTime’s Mission, Vision and Values.
- Gift giving to a Public Official: If the fair market value of a gift provided to a Public Official is less than RM100 and meets all the requirements of this Policy, no pre-approval is required, but the requesting employee providing the gift or entertainment must complete the Gifts, Benefits and Sponsorship Declaration Form for disclosure purposes prior to giving the gift or entertainment. If the fair market value of the gift or entertainment provided to a Public Official is equal to or more than RM100 or does not meet all the other requirements of this Policy, approval from CEO is required before such gift or entertainment can be provided to the Public Official.
- Gifts or tokens offered or given as symbol of kinship or partnership during gatherings or conferences to which DearTime is a participant, host, or sponsor;
- The acceptance and retention of certificates, plaques, cards, thank you notes or other written forms of souvenir or mark of courtesy;
- The acceptance of seminar bags and contents, and partaking of moderately priced meals and beverages that Board of Directors, officers, and employees obtain at events, such as conferences and seminars, and which are offered equally to all members of the public attending the event;
- Working lunches or dinners with suppliers or other stakeholders of DearTime, if such lunches or dinners are inevitable during official business. Such lunches or dinners should, however, be of
modest value not beyond what is normal or customary in the sector or business where DearTime operates, especially in dealing with potential suppliers or customers; - Product samples of nominal value given by suppliers or potential suppliers if giving such samples are allowed under part of the standard procedures of DearTime;
- 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);
- Gifts from DearTime to external institutions or individuals in relation to the company’s official functions, events, and celebrations (e.g. commemorative gifts or door gifts offered to all guests attending the event);
- Gifts from DearTime to employees and directors and/or their family members in relation to an internal or externally recognised company function, event, and celebration (e.g. in recognition of an
employee’s/director’s service to the company); - Token gifts of nominal value normally bearing DearTime or company’s logo (e.g. t-shirts, pens, diaries, calendars, and other small promotional items) 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. and deemed as part of the company’s brand building or promotional activities; and - Charitable donations or gifts to external parties as part of DearTime’s corporate social responsibility activities, either monetary or gifts in-kind, including DearTime’s Charity Insurance and Thanksgiving.
- Gifts that may be received or given in the customary and normal course of business, as may be determined, and approved by the CEO:
- Gifts received such as flowers, food or other perishable items shall be declared and the handling of such gifts shall be determined by the CEO or the CRCO in alignment with clause 3 (a) (iii) of this Guideline.
