2.13 | Meal and Entertainment Policy

This policy applies to full-time and contract employees of Sampoerna University;

• Any gift-giving to individuals on behalf of Sampoerna University.
• Provision of entertainment to an individual on behalf of Sampoerna University.
• Explanation/Suggestions on the University policy regarding the acceptance of meals, gifts, and entertainment from third parties including, but not limited to Vendors, Customers, and Public Officials.
• Acceptance of gifts of any kind or entertainment of business from a third party in connection with his position at the Sampoerna University.

2.13.1 | General provision for giving gifts and or entertainment to an individual

1. Employees are not allowed to give gifts in the form of cash or other monetary instruments that can be easily converted to cash, such as a bank check or share certificate.
2. Employees are not allowed to give a bribe to an individual in any situation.
3. Employees are not allowed to give gifts and or entertainment to an individual if such provision is illegal or violates other University policies.
4. Entertainment activities can be categorized as a gift if no university representative accompanies the entertainment receiver during the event.
5. Written approval must be obtained in advance by using the giving gift and or entertainment form before giving a gift and or entertainment.
6. Provide gifts and or entertainment to an individual must obtain approval in accordance with the applicable delegation of authorization.

2.13.2 | General provisions for the acceptance of gifts and or entertainment from the third party

2.13.3 | Personal Gift

1. To avoid a conflict of interest or appearance of a conflict of interest, at no time should an employee solicit personal gifts from a donor, current, prospective, or former student or parent, or others with whom there is a potential or existing business or professional relationship.
2. To avoid a conflict of interest or the appearance of a conflict of interest, members of the SU community are prohibited from accepting personal gifts and favours from a donor; current, prospective, or former student or parent; or others with whom there is a potential or existing business or professional relationship, in most circumstances detailed below:
3. Prohibited Personal Gifts
   Gifts valued in excess of IDR 1 Mio must be returned immediately.
4. Acceptable Personal Gifts
   • Gifts valued up to and including IDR 1 Mio, but if accepted, the individual should report the gift to their supervisor when received. The gift must be reported on the Conflict of Interest and Commitment Disclosure form.
   • Gifts of promotional items of nominal value and that are routinely distributed by vendors to clients (e.g. pens, notebooks, tote bags, etc.).
   • Modest gift baskets or nominal food items that are shared widely by colleagues.
   • Courtesy copies of professional materials and publications.
   • Courtesy payment for a modest business meal in accordance with other University policies

2.13.4 | Role and Responsibilities

Employees who give or receive gifts and or entertainment:

1. If the employee provides gifts and or entertainment, then the employee must fill out the form and obtain approval in accordance with the amount of the gift and or entertainment.
2. If the employee receives a gift and or entertainment, then the employee must fill out the form and gain approval in accordance with the amount of the value of gifts received no later than five working days after receipt of the gift.
3. If any conflict of interest in giving or receiving gifts and/or entertainment is found, report as early as possible to the relevant Manager.

Approver in accordance to Delegation of Authorization:

1. By giving consent to the giving or receiving gifts and or entertainment, the approver, according to DOA, shows that they have analysed the reasonableness and considered the consequences that may arise with the giving or receiving gifts and or entertainment.
2. Determine allocation of a gift received by employees:Kept by the respective employee:
   1. Utilized by the University
   2. Sold by the University
   3. Donated by the University
   4. Returned back to the sender

General Affairs Dept:

1. Procure gifts and or meals by first ensuring that the procurement of prizes and or entertainment has obtained sufficient appropriate approvals required by this policy.
2. Keep and maintain the gift that the University uses, and a gift will be sold by the University or the prize that the University will donate.

Human Resources Department:

1. Archive all original forms of giving or receiving gifts and or entertainment.
2. Conduct a periodic analysis regarding giving or receiving gifts and or entertainment. If required, based on the above analysis, make this policy amendment accordingly.

Finance and Accounting Department:

1. Keep records of the gifts that are used to the University, a gift that the University will sell, or the prize that the University will donate if the gift meets the elements as fixed assets.
2. Ensure that the payment or reimbursement of the cost of gift-giving and or entertainment has followed the appropriate and valid supporting payment document.

2.13.5 | Disciplinary Action

1. The University will not make a payment or reimbursement of the cost of gift-giving and or entertainment which are not provided with a form of gift-giving and or entertainment or payment or reimbursement exceeding five working days since the giving of gifts and or entertainment.
2. The University will not make a payment or reimbursement of the cost of gift-giving and or entertainment that exceeds the value indicated on the giving gift and or entertainment form.
3. Exclude from the discipline stated above if the employee can justify the excess value and obtain approval in accordance with the applicable DOA based on the total value of gifts and or entertainment.
4. The University will not make a payment or reimbursement of the cost of gift-giving and or entertainment that contain the following:
   • Food and or beverages that contain alcohol/ liquor;
   • Cigarette
   • Everything related to the things that immoral.
5. If the employee is proven, based on the facts, to commit fraud against the existing policy, the report will be followed up by the HR department. If deemed necessary, the HR department will enforce disciplinary action in accordance with the applicable University Regulation. Not limited to the provisions below, the following are examples of things that are categorized into acts of fraud:
   • Falsify proof of payment (receipts);
   • Doubling the cost;
   • Changing the information listed on the proof of payment for personal gain;
     Applying for cost reimbursement repeatedly/ double transaction (double charge) for the same specific transaction

2.13.6 | Special provision

Provisions that have not been regulated in this procedure or the application of special requests outside of the terms set out in this policy shall obtain prior approval from the BOD (Board of Directors), which shall be signed and approved by the VRARO & HR manager.