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 [email protected]


  4. Policy Guidelines

    1. Visitors

      Generally, all Visitors are strictly prohibited from taking any photos, videos or audio recordings while they are present at the Group’s premises. For business associates which include suppliers, vendors, contractors, agents, service providers, consultants and advisers, capturing or receiving such media for business purposes may only be permitted under the specific circumstances outlined in Section 4.4 Exceptions.


    2. Auditors (Internal & External)

      Auditors are not permitted to take any photos, videos or audio recordings while on the Group’s premises. Capturing or receiving such media for audit records may only be permitted under the specific circumstances outlined in Section 4.4 Exceptions.


    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, videos or audio recordings while they are carrying out their duties in the Group’s premises. Employees of the Group shall notify 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. For guidance on the notification process to Authorities, please refer to Section 4.5.2.


    4. Exceptions

      The Group may grant exceptions for limited purposes, such as conducting business, 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. Visitors are required to submit a completed “No Photography & Videography Policy Request for Exceptions Form” as part of the approval process.

      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 photos, videos or audio recordings taken during their visit:

      4.4.1. Ownership and Confidentiality

      1. a. All photos, videos and/or audio taken during the visit remain the property of the Group.
      2. b.The photos, videos and/or audio may contain confidential, sensitive or proprietary information and agree to treat them as such.

      4.4.2. Non-Disclosure and Confidentiality

      1. a.The Visitor shall keep all photos, videos and/or audio 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.
      2. b.The Visitor shall not reproduce, use, exhibit, display, broadcast, distribute, publish, sell or create derivative works of any photos, videos and/or audio in any media including but not limited to print, broadcast, electronic, digital and social media, not to disclose such photos, videos and/or audio 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.
      3. c.The Group reserves the right to review, upon reasonable grounds, any photographs, videos or recordings captured using the Visitor’s device within its premises, as well as to assess how such content is being or will be used. This right also applies to any media or content provided to the Visitor by the Group.

      4.4.3. Indemnity

      1. a.The Visitor is solely responsible for any claims, damages or liabilities arising from the unauthorized use or publication of the photos, videos and/or audio taken during their visit.
      2. b.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 providing the “No Photography & Videography Policy” via hardcopy or a softcopy sent by email, as well as through signs displayed on the premises;
      2. ii.by providing a link to the Policy online via our website (ffmb.com.my/no-photography-and-videography-policy); or
      3. iii.by incorporating an excerpt of the Policy onto the Group’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 (including those conducting a raid or entering the Group’s premises due to an emergency), the Group shall endeavor to politely notify them of the Policy. A copy of the “Notice of Non-Disclosure of Photography and Videography for Authorities” should then 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 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 photos, videos and/or audio 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.