No Photography and Videography Policy

  1. Purpose

    The purpose of this No Photography & Videography Policy (“the Policy”) is to ensure the privacy, security, confidentiality of our employees, visitors, sensitive information within the premises & facilities of FFM Berhad and its subsidiaries (collectively referred to as “the Group”) are safeguarded and protected.


  2. Scope

    This No Photography & Videography policy applies to all individuals who enter the Group's premises, including but not limited to suppliers, contractors, customers, visitors, vendors, and any other individuals associated with or conducting business with and/or within our organization (collectively referred to as “Visitors” and individually as “Visitor”). The Policy is applicable to the use of any device that can capture any form of media including but not limited to:

    • Mobile phones
    • Audio and/or visual recording equipment
    • Camera equipment
    • Drones

    at all areas under our control, which includes but not limited to offices, meeting rooms, laboratories, manufacturing facilities, production areas, warehouses, storage areas and any other locations associated with our operations.

    This Policy is not applicable to external news media covered under our Media Policy & Guidelines, such as broadcast, electronic and print.


  3. Additional Guidance

    For additional guidance or if further clarification is required regarding the Policy, please contact FFM Corporate Affairs Department at CorporateAffairs@ffmb.com.my


  4. Policy Guidelines

    1. Visitors

      Generally, all Visitors are strictly prohibited from taking any audio recordings, photos or videos while they are present at the Group’s premises. For business associates which include suppliers, vendors, contractors, agents, service providers, consultants, and advisers who are required to have the photos or videos for the purpose of conducting business or providing services, it would be on the condition that the photos or videos are to be taken by the employees of the Group using the employees’ own devices. Should this approach not align with business associate’s requirements, Visitors may take photos/ videos under specific circumstances, as outlined in Section 4.4 Exceptions.


    2. Auditors (Internal & External)

      Auditors are not allowed to take any photos or videos while they are present at the Group’s premises save and except for circumstances where the photos are necessary for their audit records and on the condition that the photos or videos are to be taken by the employees of the Group using the employees’ own devices.


    3. Authorities

      Generally, governmental authorities and/or enforcement agencies (“Authorities”) such as Department of Occupational Safety & Health (DOSH), Fire and Rescue Department (BOMBA), Polis Diraja Malaysia (PDRM), Immigration Department of Malaysia etc. are prohibited from taking any photos or videos while they are carrying out their duties in the Group’s premises. Employees of the Group shall remind the officers of this Policy and offer to provide any necessary photos or videos upon request by the Authorities. However, care must be exercised when dealing with these Authorities as any individual obstructing a public officer from discharging his public functions may be charged under Section 186 of the Penal Code.


    4. Exceptions

      The Group may grant exceptions for limited purposes, such as audit, security, inspections, training etc. These exceptions will require prior written approval from the management of the respective locations unless under specific conditions such as cases involving Authorities. Written consent must be obtained in advance and contain details such as the purpose, duration, and extent of the recording.

      The exceptions are also subject to the relevant Visitor understanding, agreeing and undertaking to abide by the following terms and conditions regarding the use, publication, and sharing of any photographs or videos taken during their visit:

      • Ownership and Confidentiality
        • All photographs or videos taken during the visit remain the property of the Group.
        • The photographs or video recordings may contain confidential, sensitive, or proprietary information and agree to treat them as such.
      • Non-Disclosure and Confidentiality
        • The Visitor shall keep all photographs and/ or video recordings confidential and use them solely for the discharge of their duties and for the purpose in which they were present at the Group’s premises.
        • The Visitor shall not reproduce, use, exhibit, display, broadcast, distribute, publish, sell or create derivative works of any photographs and/ or video recordings in any media including but not limited to print, broadcast, electronic, digital and social media, not to disclose such photographs and/ or video recordings to, or procure reproduction etc., thereto, or from, any third party. Where disclosure to a third party is required, the Visitor undertakes to seek prior explicit written consent from the Group before such disclosure.
      • Indemnity
        • The Visitor is solely responsible for any claims, damages, or liabilities arising from the unauthorized use or publication of the photographs or videos taken during their visit.
        • The Visitor shall indemnify and hold the Group, its officers, employees, and representatives harmless from any such claims, damages, or liabilities arising out of the individual’s failure to observe any of the terms and conditions contained herein.

    5. Notification of the Policy

      4.5.1. Visitors

      The Policy may be communicated to Visitors:

      1. i. by way of “No Photography & Videography” notices or signs on the premises;
      2. ii.physically via a copy of the “Non-Disclosure of Photography and Video Recordings Notice” to the visitors (including Authorities);
      3. iii.providing a link to the Policy online; or
      4. iv.incorporating an excerpt of the Policy onto the site’s visitors slip

      and Visitors are deemed to be aware of and agree to the Policy by their continued presence at the Group’s premises. A copy of the Policy shall be maintained at the main guard house and Visitors may request to access the same.


      4.5.2. Authorities

      For authorities conducting a raid or entering the Group’s premises due to an emergency, the Group shall endeavor to politely notify them of the Policy. However, in case the Authorities require the photos or videos for their administrative or reporting purposes, then a copy of the Policy shall be extended to them and a note made in the Visitor Management System or Visitors Register to that effect.


    6. Employee’s Responsibility

      Employees are responsible for ensuring the enforcement of this Policy within their respective areas. If an employee witnesses a violation (whether by a Visitor or otherwise), they should promptly report it to their superior or the Risk Officer/ FFM Risk Management & Integrity Department.


  5. Consequence Of Breaches To The Policy

    If any Visitor is found to have breached the Policy, the Group reserves the right to do any one or more of the following:

    1. i.revoke the Visitor’s permission to be on the premises and request that the Visitor leaves the premises immediately;
    2. ii.request that the Visitor permanently delete the audio recording, photograph or video from their devices; and/or
    3. iii.if the recording or photograph has been published in the media, then the Group may request that the relevant party publish a retraction, correction or apology.

    The above are in addition to any other contractual rights or remedies which the Group may have or at law.


  6. Update And Review

    The Group reserves the right to review and amend the Policy as needed.