Sponsorship and Donation Policy

1. Purpose

This policy establishes clear principles and controls governing sponsorships and donations made by the Company to ensure that all contributions are:

• Conducted ethically and transparently;
• In line with the Company's Business Ethics Policy; and
• Compliant with applicable laws, customer requirements, and internal approval processes.

This policy aims to prevent any form of bribery, corruption, conflict of interest, or undue influence through sponsorships or donations.

2. Scope

This policy applies to:

• All employees, management, and directors of the Company;
• All forms of sponsorships, donations, or contributions made to customers, business partners, organizations, or events;
• Monetary and non-monetary contributions, including cash, goods, or services.

3. Definitions

Sponsorship: Financial or in-kind support provided for events, activities, or programs where the Company may receive legitimate visibility or recognition.

Donation: A voluntary contribution made without expectation of commercial return.

Contribution: Any sponsorship or donation, whether in cash or in kind.

4. Policy Principles

All sponsorships and donations must:

• Be for legitimate business, community, or social purposes;
• Never be offered, promised, given, or received as an inducement to secure business advantage, influence decisions, or obtain improper benefit;
• Be reasonable, proportionate, and justifiable;
• Not create any real or perceived conflict of interest;
• Be fully documented, transparent, and approved in accordance with this policy.

5. Prohibited Practices

The following are STRICTLY prohibited:

• Sponsorships or donations intended to influence business decisions, tender outcomes, pricing, or contract awards;
• Contributions requested or linked directly to sales targets, contract renewal, or preferential treatment;
• Cash payments made to individuals or personal bank accounts;
• Contributions to political parties, political candidates, or politically exposed persons, unless expressly permitted by law and approved by the Board;
• Any contribution that contradicts the Company's Business Ethics Policy.

6. Eligibility and Limits

Sponsorships and donations may only be made to:

• Registered companies or organizations;
• Recognized events or activities with legitimate purposes.

Contribution limits shall be determined based on internal guidelines, such as:

• A defined percentage of annual sales or profit margin; and
• A maximum cap per event or customer, as approved by Management.

Any contribution exceeding the defined limit requires higher-level approval.

7. Approval Process

All sponsorships and donations must be requested using the Contribution Request Form. The request must include:

• Purpose and description of the event or activity;
• Type and amount of contribution;
• Method of contribution (e.g. bank transfer, gift arrangement, or others);
• Confirmation that the contribution does not violate the Business Ethics Policy.

Approval Levels:

• Request by: Sales Team or relevant department;
• Review by: Accounts/Finance Department;
• Final approval by: COO and/or CEO.

No contribution may be made without written approval.

8. Method of Contribution

• All payments must be made to the organization's official bank account under its registered company name.
• Other non-cash contributions must be clearly documented.
• Cash payments are discouraged and, if unavoidable, must be justified and approved in writing.

9. Documentation and Record Keeping

All approved sponsorships and donations shall be properly recorded and retained for audit purposes. Records must include the approved form, supporting documents, and proof of payment.

Documentation shall be maintained in accordance with the Company's document control and retention requirements.

10. Monitoring and Compliance

• Compliance with this policy is subject to internal audit and management review.
• Any suspected violation must be reported in accordance with the Company's whistleblowing mechanism.
• Breaches of this policy may result in disciplinary action, including termination of employment.

11. Reference Documents

• Business Ethics Policy (SPC-Be i)
• Contribution Request Form (SPC-Sales-F03)
• Grievance Management Handbook (HR-M01)

12. Review and Revision

This policy shall be reviewed periodically or when there are changes in legal, regulatory, or customer requirements.

This policy is to be read together with and does not override the Company's Appendix 4 – Business Ethics Policy.