1- PURPOSE
The purpose of this policy is to outline the procedures and principles regarding gifts and hospitality received or given in the social interactions of Hilf al-Fudul Foundation employees with business partners and clients, to prevent conflicts of interest, and to ensure that the Hilf al-Fudul Foundation operates in full compliance with anti-corruption and anti-bribery laws in all countries where it conducts business relationships.
2- SCOPE AND CONTENT
Prepared within the framework of the Anti-Bribery and Anti-Corruption Policy and our Ethical Principles, this policy establishes the fundamental guidelines that Hilf al-Fudul Foundation employees must follow regarding gift acceptance, gift giving, and hospitality activities in their relations with clients and third parties.
3- DEFINITIONS
Gift: Products or services given between individuals who are in an existing or potential business relationship, without any material or moral compensation, for the purpose of business courtesy or appreciation.
Hospitality Activities: Invitations, entertainment, meals, corporate communication events, and training activities carried out between individuals within an existing or potential business relationship for representation and hosting purposes.
Third Party: Shareholders, subsidiaries, group companies, and both current and potential business partners, clients, suppliers, and companies providing support services are considered third parties within the scope of this policy.
Conflict of Interest: Employees must avoid any transactions or relationships that could harm the employer for their personal benefit. A conflict of interest may arise when this trust-based relationship is violated. It occurs when an employee’s personal interests conflict or appear to conflict with the interests of the Hilf al-Fudul Foundation or its clients. Every action and behavior must be evaluated in terms of whether it could be perceived by others as a conflict of interest, whether such perception could put us or the Hilf al-Fudul Foundation in a difficult position, and whether it could affect our impartiality or negatively impact the foundation, our clients, suppliers, or other stakeholders.
4- PRINCIPLES AND PROCEDURES OF THE GIFT POLICY
The principles and procedures of the gift policy outline the rules to be followed regarding the acceptance and giving of gifts, as well as the conduct of representation and hospitality activities.
5- Principles and Procedures to Be Followed in the Acceptance and Giving of Gifts
It is essential that the Hilf al-Fudul Foundation and its employees do not accept any gifts or benefits that could influence their impartiality, decisions, or behavior, and that they do not attempt to offer gifts or benefits to third parties or organizations that could create such an influence. The implementation principles defined below regulate the exchange of gifts between the Foundation’s employees and third parties or organizations with whom they have business relationships, and establish the principles to be applied in this regard.
a. Hilful Fudul Foundation is an important client for suppliers and service providers (hereinafter referred to as “Suppliers”). Suppliers may only be selected based on the principle of competition. All employees, especially those responsible for procurement, may receive unethical or inappropriate offers from suppliers or other business partners. Any attempt by suppliers to influence the purchasing decisions of Hilful Fudul Foundation employees through gifts, assistance, or donations must not be tolerated.
b. Such attempts may benefit the employee personally or a third party. Suppliers should be advised not to influence the Foundation’s employees in this manner and must be warned if they violate this condition. In cases of serious or repeated violations, the business relationship should be terminated.
c. Employees of the Foundation are prohibited from accepting any benefits or gifts, whether of economic value or not, that affect or may affect their impartiality, performance, or decision-making while performing their duties. (Examples include loans, commissions, securities or other valuables, employment opportunities, exemption from debt or obligations, or any other service that provides an advantage.)
d. Foundation employees may accept or offer gifts or hospitality, or agree to be subject to special treatment, only under the following conditions:
1. It aligns with the Foundation’s business objectives,
2. It complies with applicable laws and regulations,
3. Public disclosure of the gift will not put the Foundation in a difficult position,
4. The receipt of the gift or hospitality will not have a reasonable or potential influence on a contract decision the supplier is relying upon.
e. Subject to the conditions specified in clause “d”, the following gifts and invitations may be accepted depending on the circumstances:
1. Foundation employees may give and receive entertainment, hospitality, and meals within acceptable business standards.
2. Symbolic gifts such as plaques or mementos (excluding cash) received during seminars or similar events attended on behalf of the Foundation may be accepted.
3. Promotional items (e.g., pens, calendars, notebooks, coffee mugs, etc.) and other gifts of minimal value may be accepted.
4. Invitations to business meals may occasionally be accepted if the purpose is business-related (e.g., within the scope of a business meeting) and the meal’s value is appropriate to the attendee’s position within the organization.
5. Invitations to sports events, concerts, cultural events, trade fairs, or conferences (once or twice per year per business partner) may be accepted only under the following conditions:
5.1 There must be a direct business purpose (not directly related to an ongoing contract negotiation),
5.2 The employee is accompanied by a person with whom they have a business relationship,
5.3 The ticket price is appropriate to the invitee’s position in the country. Such invitations require the employee’s supervisor’s approval. Spouses or friends should not be included, and any offers by the inviting company to cover travel or accommodation expenses must be declined.
f. Under no circumstances should a gift exceeding a value of 25 USD be accepted. In such cases, the gift should be politely declined, citing the Hilful Fudul Foundation Gift Giving, Acceptance, and Hospitality Policy.
g. The total value of gifts accepted from various sources within a calendar year must not exceed 100 USD. Foundation employees must complete the Gift Acceptance Declaration Form (Annex-1) for every accepted gift valued up to 25 USD and submit it to the Hilful Fudul Foundation Board of Directors.
h. Cash gifts, precious metals such as gold or diamonds, or easily convertible items, as well as discount vouchers, must never be accepted. If a gift is refused or returned after being received, a Gift Return Declaration Form (Annex-2) must be sent to the giver. The form should also be submitted to the Hilful Fudul Foundation Board of Directors for informational purposes.
i. Low-value gifts such as chocolates, flowers, or promotional items, or those with primarily symbolic rather than monetary value, are not subject to this policy. However, such gifts should not be accepted repeatedly, regardless of type or giver.
j. Acceptance of any gift or benefit that is explicitly or implicitly linked to a favor or exchange is strictly prohibited.
k. Offering, receiving, or proposing bribes and/or commissions is strictly prohibited under all circumstances.
l. The types of gifts and promotional materials to be distributed by the Foundation to members, donors, and third parties with whom it maintains business relationships must be approved by the Board of Directors. Once approved, separate authorization for distribution is not required.
m. In line with the conditions stated in clause “d”, the Foundation may accept suitable products and services as gifts and, with the Board of Directors’ knowledge and approval, may give gifts or services appropriate to the recipient’s culture and ethical values.
n. In exceptional cases where local cultural norms require mutual gift exchange beyond the limits set by the Foundation’s policy, such gifts may be accepted only on behalf of the Foundation and with the Board of Directors’ approval. In all cases, gift exchanges must be conducted in accordance with local cultural practices.
6- Gifts to Public Authorities and Government Officials
The rules specified in Section 5 also apply to public authorities, government officials, and third parties associated with them. Foundation employees must avoid giving any promotional gift to a government official that could influence their decisions while performing official duties. Therefore, all employees are prohibited from engaging in any action or taking any measure that could exert such pressure. As a principle, offering, promising, authorizing, or giving money, gifts, assistance, or donations—either directly or indirectly—to public authorities or government officials is strictly prohibited. Exceptions are subject to prior approval by the authorized Foundation representative and the Ethics Officer. Invitations to standard business meals for government officials require prior approval from the employee’s supervisor. Payments, non-cash equivalents, invitations, gifts, donations, or assistance made to secure or expedite the routine actions of government officials or private sector employees (also known as facilitation payments) are strictly prohibited at all times.
7- Principles and Procedures to Be Followed in Hospitality Activities
a. When Hilful Fudul Foundation employees organize entertainment events or host meals for representation and hospitality purposes, the principles established by the Hilful Fudul Foundation regarding the exercise of representation and hospitality authority must be applied.
b. If Hilful Fudul Foundation employees or any party authorized by the Hilful Fudul Foundation host an event, guests are responsible for their own travel and accommodation expenses unless otherwise explicitly stated in the invitation. In necessary, reasonable, or justifiable cases (such as training activities or corporate communication events), expenses may also be covered by the Hilful Fudul Foundation.
c. Hospitality activities organized by employees working on behalf of and representing the Hilful Fudul Foundation must be conducted openly, in good faith, and without conditions. It must be ensured that such activities do not create the impression that they could influence responsibilities or decision-making processes on the hosted party’s side.
d. Employees acting on behalf of and representing the Hilful Fudul Foundation may participate in entertainment and meal events for representation and hospitality purposes, provided that such events are acceptable, reasonable, and modest by business standards.
e. Travel and accommodation expenses incurred by Hilful Fudul Foundation employees or any authorized party for business-related invitations or events shall be covered by the Hilful Fudul Foundation, unless otherwise stated in the invitation. In necessary, reasonable, or justifiable circumstances (e.g., training activities or corporate communication events), such expenses may also be covered by the inviting party.
f. Hospitality activities accepted by employees acting on behalf of and representing the Hilful Fudul Foundation must be conducted openly, in good faith, and without conditions. It must be ensured that such hospitality does not create the impression that it could influence the Hilful Fudul Foundation’s responsibilities or decision-making processes.
8- Reporting Policy Violations
a. If there is an opinion or suspicion that an employee or a person acting on behalf of the Hilful Fudul Foundation has acted contrary to this Policy, it must be reported to the Ethics Representative and the Ethics Committee. Matters related to the Code of Ethics are periodically reminded to Foundation employees.
b. The Hilful Fudul Foundation promotes an honest and transparent approach and supports any employee or person acting on behalf of the Foundation who, in good faith, raises sincere concerns, and it keeps such reports confidential. No employee may be subjected to pressure or retaliation due to a report made to the Ethics Representative and/or the Ethics Committee regarding a suspected Code of Ethics breach; no change to role or place of duty may be made for this reason without the written approval of the Ethics Committee.
c. If the reporting person is subjected to such treatment, they must inform the Ethics Committee. Firms supplying goods or services and business partners are also expected to regularly remind their employees of the role of the Foundation’s Ethics Representative and to encourage reporting should such situations arise.
9- Policy Violations
In cases where actions are found or suspected to be contrary to the policy, the matter shall be reviewed by the Hilful Fudul Foundation Ethics Representative and the Ethics Committee, and appropriate measures shall be taken if any misconduct is identified.
