E-SPIN Group is committed to conduct its business in the highest standard of integrity and good governance.
The objectives of the No Gift Policy are to avoid a conflict of interest and demonstrate E-SPIN’s commitment to provide equal treatment to all individuals or organisations that we are in contact with for our business.
E-SPIN Group may never pressure you to give a gift, or to contribute toward a gift, to anyone. The premise of giving gifts is an ancient way to express gratitude, appreciation and respect. For some countries and cultures to keep practicing it, it is nothing right or wrong. Giving in itself is fairly innocuous and it is based upon the philosophy of reciprocity which is commonly articulated by phrases such as “what goes around comes around” or “what you sow, you will reap”. While gifts are often given as a gesture of goodwill, overly generous business gifts tend to put pressure on the recipient to extend more than just goodwill to the giver. Thus, not surprisingly, the line between sincere giving and bribery is becoming increasingly distorted.
Due to modern interpretation and the act of gift giving, may contribute to bribery direct or indirectly. Gifts, even those of nominal value, can create the perception of undue influence. Because of this potential grey area and increasing difficulty to draw the line between a gift and a bride for each case. A gift is something of value given without the expectation of return; but a bribe is the same thing given in the hope of influence or benefit. Gifts and bribes can be monetary, actual items or they can be tickets to a sporting event, entertainment, travel, rounds of golf or restaurant meals. For our end, we perceive it is unethical and some country laws and regulations consider it illegal to accept gifts or invitations to any events where the intent is to buy favour. So, as our valuable business partners from supplier vendors, channel partners to end customers, please help us to enforce the policy for the best interest for all the parties.
In this regard, employees of E-SPIN Group shall not solicit or receive any gifts from current or potential vendors, agents and business partners, either directly or indirectly which may influence the employee’s judgement in a decision-making process or put the employees in a position of conflict.
Employees are required to professionally inform current or potential vendors, agents and business partners of this No Gift Policy, and the reasons E-SPIN Group has adopted the No Gift Policy.
Employees will request current or potential vendors, agents and business partners to respect E-SPIN Group’s No Gift Policy and not to purchase and deliver any gift for our employees, their family members, a department, an office, employee’s residence or the company, at any time, for any reason.
Any violation of this No Gift Policy may result in disciplinary action, including but not limited to, termination of employment.
If an employee receives a gift:
- If feasible, the gift is returned to the current or potential vendor, agent and business partner.
- If not feasible to return the gift, the gift must be raffled off to all employees. Proceeds from the raffle will be donated to charities that have been approved by E-SPIN Group. If employees are uninterested in the raffled item, the gift will be donated to the designated charities.
- Plants or flowers will be displayed in the lobby, or at another central location where all employees may enjoy their presence.
- Gifts of food that may arrive during the holidays, and at other times of the year when gift giving traditional, belong to the entire employees even if addressed to a single employee. Under no circumstances an employee may take a food gift home; food gifts must be shared with and distributed to all employees.
If any employee has questions about and / or needs clarification of any aspect of this No Gift Policy, the employee should check with his / her supervisor. If the supervisor is uncertain, Human Resources is the arbiter of the No Gift Policy to ensure consistent treatment across E-SPIN Group.
Any exceptions to the No Gift Policy may be made only with the permission of the Chief Executive Officer of E-SPIN Group of Companies.