Cuckoo International (MAL) Sdn Bhd (“CUCKOO”) is committed to conduct its business with integrity.

In line with its commitment of No Gift Policy, CUCKOO has developed its Gift, Entertainment and Corporate Hospitality Guidelines For Business Associates and Customers (“Guidelines”). As a customer or party who has or will have business dealings with the Group including but not limited to vendor, supplier, agent, representative, consultant, intermediary, adviser, contractor, sub-contractor, joint venture partner, outsourcing provider and/or party acting on behalf of CUCKOO (collectively known as “Business Associates and Customers”), you are obliged to comply with the terms of this documents for your activities involving CUCKOO. This Guidelines shall be read with CUCKOO’s Anti-Bribery and Corruption Policy (“ABC”). In the event of discrepancy between the provisions in this Guidelines and ABC, the provisions in ABC shall prevail.

1. CUCKOO condemns any form of bribery or corruption. Business Associates and Customers shall take all necessary measures to prevent corrupt practices in the dealing with CUCKOO.
2. In addition, Business Associates and Customers shall, at all times: –
   1. not to offer or provide, directly or through any intermediaries, any bribe, gift, reward, consideration, favour or any other advantage, whether material or immaterial (“Advantages”) to any representative of CUCKOO for the purpose of: –
      1. influencing them to act contrary to CUCKOO’s interest; or
      2. obtaining or rewarding favourable treatment by CUCKOO with respect to the terms, conditions, price or performance of a contract;
   2. not to offer or provide Advantages which might be considered a bribe under international legislation, to a government official, either in Malaysia or any other country;
   3. not to collude with other parties to preclude or compromise dealings with CUCKOO. The Business Associates and Customers also undertake to report to CUCKOO, through its official reporting channels stipulated below, any such attempts made by others to involve the Business Associates and Customers in acts of collusion against CUCKOO or any attempt of corrupt practice; or
   4. not to instigate third parties to perform actions pertaining to the above.
3. Business Associates and Customers will ensure that all their employees, sub-contractors oand agents are aware of and comply with the provisions in this document.
4. Business Associates and Customers shall ensure that they adhere to the following –
   1. Gift
   • Gifts are anything of value (such as money or cash equivalent vouchers, goods, services, loans, tickets, and prizes) given to the business associates or customers without any expectation of anything in return or without any intention to influence someone to act improperly.
   • Any gift provided or received must be unsolicited and not affect, or be perceived as affecting, business judgment. Gifts should only be offered to CUCKOO’s representative / employeein connection with a customary business or cultural occasion subject to strict adherence of CUCKOO’s policies and compliance of all laws and regulations. Cash, loans, kickbacks or the equivalent advantages are absolutely prohibited.
   • Gifts provided must not exceed RM150 and in any event, must not be provided more than 3 times a year to CUCKOO’s representative/employee.
   • No gift must be received from or given to government officials on CUCKOO’s behalf.
   2. Entertainment & Corporate Hospitality
      • Entertainment is generally defined as the provision of an external event or activity which can pleasurably occupy a person. This may include the provision of meals, transportation, and accommodation.
      • Corporate Hospitality is generally defined as events or activities organised by an organisation which involves the entertainment of employees and third parties for the benefit of that organisation. This may include the provision of meals, transportation, and accommodation in connection with such corporate events or activities.
      • Entertainment and Corporate Hospitality including meal and any form of hospitality provided or received must be unsolicited and not effect or be perceived as affecting business judgment.
      • Meals, entertainment and hospitality should only be offered to and/or received from CUCKOO representative dealing with Business Associates and Customers in their role in CUCKOO and is for purposes supported by CUCKOO and may only be offered in conjunction with legitimate business meetings, conferences or events hosted, supported or sponsored by CUCKOO. They may never be provided on a stand-alone basis.
      • Entertainment, meal and hospitality provided must not exceed RM150 (for non-management), RM250 (for managers), RM350 (for senior managers), RM500 (for directors) and in any event, must not be provided more than 3 times a year to CUCKOO’s representative/employee.
      • All requests must be made by well-established organisations on their official letterhead to CUCKOO regardless of value.
   3. Facilitation Payments & Kickbacks
   • “Facilitation Payment” is a payment or other provision made to an individual in control of a process or decision to secure or expedite the performance of duties, for example payments to expedite the issuance of a visa, license, permit or approval, or clearing of goods through customs.
   • Kickbacks are typically payments made in return for a business favour or advantage.
   • Business Associates and Customers must never make or use third parties to make an unofficial payment in order to secure or expedite routine administrative actions, such as customs clearances, visas, permits or licenses.
   • Any form of kickback is prohibited.
   • If you receive a request for a facilitation payment, you must immediately report such request to CUCKOO.

Please report any suspected instances of corruption or attempted corruption in matters or dealings relating to CUCKOO and its employees so that CUCKOO may take steps to address this urgently via email to whistleblowing@cuckoo.com.my or complete the whistleblower form online through CUCKOO website.