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Carmedis Gift and Hospitality Policy

1. Purpose

Carmedis Limited is committed to conducting business with integrity, professionalism, and transparency. This Gift and Hospitality Policy establishes guidelines regarding the giving and receiving of gifts, entertainment, hospitality, and other benefits to ensure business decisions remain objective and free from improper influence.

2. Scope

This policy applies to all directors, employees, consultants, contractors, suppliers, and representatives acting on behalf of Carmedis.

3. Policy Statement

Employees and representatives of Carmedis must not offer, give, solicit, or accept gifts, hospitality, favors, or other benefits that could improperly influence business decisions or create the appearance of a conflict of interest.

Business relationships must be based on merit, quality, service, and value, not on personal benefits.

4. Acceptable Gifts and Hospitality

The following may be acceptable if reasonable and infrequent:

  • Promotional items of nominal value.
  • Modest business meals directly related to legitimate business activities.
  • Hospitality that complies with applicable laws and company policies.
  • Industry events, seminars, or training programs approved by management.

5. Prohibited Gifts

Employees and representatives must not:

  • Accept or offer cash or cash equivalents.
  • Accept gifts intended to influence a business decision.
  • Request gifts from customers, suppliers, or contractors.
  • Accept excessive entertainment or hospitality.
  • Accept personal discounts unavailable to the general public.
  • Offer gifts to government officials without prior written approval.

6. Conflict of Interest

Any gift or hospitality that may create an actual or perceived conflict of interest must be disclosed immediately to management.

7. Reporting Requirements

Employees must promptly report:

  • Offers of inappropriate gifts.
  • Attempts to influence business decisions through gifts or favors.
  • Any suspected violation of this policy.

8. Violations

Violations of this policy may result in disciplinary action, termination of employment, termination of supplier relationships, and where appropriate, referral to regulatory or law enforcement authorities.

9. Review

This policy shall be reviewed annually and updated as required to ensure compliance with applicable laws and best practices.

Effective Date: January 1, 2026
Approved By: Management, Carmedis Limited

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