CHARITABLE DONATIONS AND SPONSORSHIPS POLICY AND PROCEDURES

1. OBJECTIVES

   1. PPB Group¹ aspires to make positive contributions to the communities in which we operate. These contributions may come in the form of money (financial), or donations-in-kind, including our time, resources, and/or other forms of donation or sponsorship. Nevertheless, these donations and sponsorships may be misused by certain parties as vehicles for bribery and corruption.
   2. This Policy and Procedures sets out rules to ensure that PPB Group is supporting legitimate and reputable charities and organizations.
   3. The Group’s CSR Task Force and PPB Group Berhad’s Risk Management & Integrity Department (“PPBHQ RMID”) will review this policy regularly and if needed, may amend it at any time to reflect business developments or changes to international or national laws and regulations.

2. DEFINITIONS

   Under this Policy, the terms below have the meaning assigned to them:

   1. Charitable donations - the provision of cash, venues, equipment, Personnel time or other benefits to a charity, or an individual or organisation nominated by or connected with a charity.
   2. Political donations - the provision of cash, venues, equipment, personnel time or other benefits to a political party, or an individual or organisation nominated by or connected with a member of a political party.
   3. Sponsorship - the provision of cash or other benefits to an individual or organisation in return for or to assist that individual or organisation in performing an act (e.g. an individual running a race, or an organisation holding a sporting or cultural event or a conference).
   4. Corporate Social Responsibility (“CSR”) - where PPB Group provides benefits to a community or institution (e.g. building a school, or providing medical equipment to a hospital).
   5. CSR Task Force comprises of representatives from PPB Group Berhad and the Group’s respective Business Units (“BUs”).

3. CHARITABLE CONTRIBUTIONS

   1. In general, all charitable donations and sponsorships (including CSR programmes) for external parties are allowed if they are requested for legitimate reasons and are permitted by the law(s) and regulations. All donation and sponsorship requests are subjected to PPB Group’s policies to ensure consistency and uniformity across the organization.
   2. Beneficiaries of contributions donated by PPB Group are non-profit charitable organisations, legal entities, or individuals.
   3. Charitable donations and sponsorships can only be made to legitimate organizations which have been registered with the Malaysian Registrar of Societies (“ROS”) or certain government agencies. These may include, but are not limited to:
   1. Associations
   2. Clubs
   3. Societies
   4. Social enterprises
   5. Institutions
   6. Non-Government Organizations (NGO)
   7. Schools and universities
   8. Others, as recommended by the Sustainability Department (PPBHQ)/ Corporate Affairs Department (FFM Group)/ Public Relations and Branding Department (GSC Group) or the Marketing Communications Department (PPB Properties) (as the case may be), which have been subjected to due diligence and approved by the Head of Company (“HOC”)/ Chief Executive Officer (“CEO”)/ Group Managing Director (“Group MD”).
   4. Requests may be made for activities related to the following, as per the CSR programme:
   1. Education
   2. Environment
   3. Healthcare
   4. Sports
   5. Cultural
   6. Welfare
   7. Disasters, e.g. fire, flood, or landslide
   8. Others, as recommended by the Sustainability Department (PPBHQ)/ Corporate Affairs Department (FFM Group)/ Public Relations and Branding Department (GSC Group) or the Marketing Communications Department (PPB Properties)/ CSR Taskforce (as the case may be), which have been subjected to due diligence and approved by the HOC/ CEO/ Group MD.

4. LIMITATIONS

   1. No Political Donation Policy
      1. The Group maintains a strict No Political Donation Policy. This means that the Group’s funds, or resources (e.g. property or equipment), must not be used, either directly or indirectly, to fund any political party, political campaign, political officials, political candidates, or their representatives². The Group’s funds must also not be used to make political payments under the guise of charitable donations.
      2. PPB Group’s Personnel are required to notify their Business Associates³, or other third parties of the Group’s No Political Donation Policy.
      3. In addition to the above, the Group also does not make contributions or donations to organisations whose policies or activities are not in line with the Group’s values.
   2. Conflict of Interest
      1. A Conflict of Interest is a personal connection that interferes with a Personnel’s ability to perform their duties in a fair and impartial manner. It occurs when a Personnel’s private interests interfere or are not aligned with the interests of the Group, or where the family members or friends of a Group employee receives improper benefits because of that relationship.
      2. Where the Group receives requests for donations or sponsorships from third parties, the Personnel who is either proposing or approving the donations, SHALL disclose their relationship⁴ with the third party (if any). Personnel should complete the Conflicts of Interest Declaration Form which needs to be approved by the HOD. If necessary, HOD may consult either the HOC, or the CEO, or the Group MD before the award is made. Regardless of whether that conflict of interest is actual, potential, or perceived, they must not take part in making a decision that could be perceived to be affected by that conflict.
      3. If the conflict involves HOC, a declaration should be made to the CEO. If the conflict involves the CEO/ Group MD, a declaration should be made to the Board of Directors (“BOD”) Chairman. For more information on managing Conflict of Interest, please refer to the Conflict of Interest Policy and Procedures.
   3. Charitable donations and sponsorships that are made to secure business deals are PROHIBITED, no matter what form they take, whether they are given directly or indirectly.
   4. Donation or sponsorship request can also be made by a Business Associate, or other third parties during a sensitive period . In such circumstances, the request SHOULD NOT be entertained before, during or soon after a contract negotiations or significant event such as during audit, or inspection, in order to avoid any negative perception of a bribe.
      
      Alternatively, Personnel may consult the Risk/ Integrity Officer, or Head of Risk/ Integrity or PPBHQ RMID regarding donation or sponsorship request received during sensitive period.
   5. For clarity, where the Group makes a charitable donation or sponsorship to an organization’s (recipient) event, and the recipient in return invites the Group to attend/ join the said event, Personnel are allowed to do so, subject to prior permission from the HOD. Corporate gifts or other door gifts of reasonable value which is given to all attendees is permitted. For more information, please refer to the No Gift Policy and Procedures and the Gift Exception Guidance.

5. AUTHORISATION OF CHARITABLE AND SPONSORSHIPS ACTIVITIES

   1. Budget relating to charitable donations and sponsorship is approved by the PPB Group Berhad’s Board of Directors (“PPB Group BOD”). A CSR Plan will go through the preliminary review by the CSR Task Force. Subsequently, the CSR Task Force will then present the Group CSR budget to the PPB Group’s Sustainability Steering Committee for approval-in-principle, prior to obtaining final approval from the PPB Group BOD.
   2. In terms of recipients, it will be based on the recommendation by Sustainability Department (PPBHQ)/ Corporate Affairs Department (FFM Group)/ Public Relations and Branding Department (GSC Group) or the Marketing Communications Department (PPB Properties) (as the case may be), which have been subjected to due diligence and approved by the HOC/ CEO / Group MD.
   3. For festival donations and sponsorships, i.e. Chinese New Year, Hari Raya Aidilfitri, etc., approval shall be obtained from the Sustainability Department (PPBHQ)/ Corporate Affairs Department (FFM Group)/ Public Relations and Branding Department (GSC Group) or the Marketing Communications Department (PPB Properties) (as the case may be) and/ or HOC/ CEO/ Group MD, in accordance with the respective entities Financial Authority Limits (“FAL”).
   4. No charitable donations and sponsorships can be made to individuals, unless approved by either the Sustainability Department (PPBHQ)/ Corporate Affairs Department (FFM Group)/ Public Relations and Branding Department (GSC Group) or the Marketing Communications Department (PPB Properties) (as the case may be) and the CEO/ Group MD, in accordance with the FAL.
   5. The Group may also at times receive offers for sponsorship, e.g. as part of their marketing/ promotion strategy, whereby a manufacturer offers to sponsor their products or equipment as part of the Group’s CSR programme. Any offers of sponsorship that the company receives shall be assessed to ensure the legitimacy of the offer, and that there are appropriate controls in place to prevent a sponsorship from influencing the Group’s decision-making. Personnel must also obtain written approval from his/ her HOD and HOC/ CEO/ Group MD.
   6. Please refer to the respective Business Units CSR Policy for detailed information on managing donations and sponsorship requests.

6. DUE DILIGENCE

   All requests for charitable donations and sponsorships shall be subjected to proper due diligence by the Sustainability Department (PPBHQ)/ Corporate Affairs Department (FFM Group)/ Public Relations and Branding Department (GSC Group) or the Marketing Communications Department (PPB Properties) (as the case may be). The due diligence check is necessary to determine the legitimacy of the request(s), including the legitimacy of the requestor and the beneficiary.

7. ACCOUNTING AND RECORD-KEEPING

   1. For PPB Group HQ, all requests for donations and sponsorships, both financial and in-kind, must be made to the Sustainability Department. For other BUs, the written request is to be made to either the Corporate Affairs Department (FFM Group)/ Public Relations and Branding Department (GSC Group) or the Marketing Communications Department (PPB Properties) (as the case may be).
   2. All payments shall be made directly to the charitable organization or requestor’s (individual) official bank account. No third-party payment, whether to an individual or another organization, is allowed.
   3. Where the sponsorship to the beneficiary involves a third party, e.g. contractor/ vendor/ service providers, payment shall be made directly to the third party for the work done or goods/ service provided.
   4. All transactions shall be recorded and documented accurately.




Footnote

1. “PPB Group” or “the Group” refers to PPB Group Berhad and its subsidiaries.

2. Representatives here includes spouse and family member.

3. For purposes of this Policy and Procedures, the term “Business Associates” includes, but not limited to, suppliers, vendors, contractors, agents, service providers, consultants, advisers, distributors, joint venture, or partners consortia parties, and any other third party acting for or on behalf of PPB Group.

4. Relationship here refers to relationship with closely related persons, i.e. close relatives or close associates. Please refer to the Conflict of Interest Policy and Procedures for more information.