Our Group is committed to maintaining the best employment practices and the highest standards of openness, probity, accountability, integrity, corporate governance and to confidentially act with honesty at all times. To enable this, our Group is adopting an anti-corruption policy to provide guidance our employees in offering and accepting business courtesies with vendors and customers.
Our Group adopts a zero-tolerance policy towards any forms of corruption and bribery in our business. Our employees have to observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake not to engage in any corrupt or improper practices.
Policy on Accepting and Offering Business Courtesies
Our Company does not allow our employees to solicit or accept any benefits and business courtesies such as commissions, gifts in cash or kind, gifts that are more than nominal value of S$100, or any other service, favour or advantage of any description whatsoever, from any organisation, firm or individual with whom they deal with in the course of the employment.
Our Company does not allow our employees to promise or offer to give any benefits and business courtesies such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, to any individual of external parties with whom they deal with in the course of the employment.
Business Courtesy means anything of value, a favor, or a benefit provided free of charge or at a charge less than fair market value. A business courtesy may be a tangible or intangible benefit, including, but not limited to, such items as nonmonetary gifts, meals, drinks, entertainment, hospitality, services, recreation, door prizes, transportation, discounts, tickets, passes, sporting events, side excursions or outings etc.
In pursuance of the Anti-Corruption Policy, our Group has set below guiding principles on accepting and offering of business courtesies and guiding principles in dealing with vendors and suppliers.
| Activities | Guiding Principles |
|---|---|
| Offering of business courtesies | Ensure necessary and justifiable for the occasion Ensure appropriateness to local business customs and culture Ensure reasonable monetary value or frequency Do not cause embarrassment or adversely affect reputation of either party Would not be viewed as sexual harassment, or discriminatory Do not contravene applicable laws and regulations |
| Receiving of business courtesies | Ensure appropriateness to accept Ensure no undue influence on business dealings Ensure no conflict of interest Business courtesies such as meals and refreshment is unsolicited Declare business courtesies received above nominal amount of S$100 Do not accept frequent business courtesies from the same party Do not cause embarrassment or adversely affect reputation of either party Do not contravene applicable laws and regulations |
| Managing Business Relationships | Act with integrity and professionalism Make decisions/representation only when duly authorised Exercise discretion over frequency and place of business activities Maintain security and confidentiality of data and information used in business interactions Do not manipulate business relationship for personal gains and interests Do not offer nor provide kickbacks or bribes or favors Do not ask for or accept kickbacks or bribes or Do not contravene applicable laws and regulations |
In the events that an employee of our Group received an inappropriate business courtesy where it cannot be returned immediately, such as a gift, and/or the circumstances make it inappropriate to decline, it must be reported immediately to Human Resources using the “Declaration form for business courtesies and gift” in Appendix A and the business courtesy, if tangible, should be surrendered.
Conflict of Interest
Our Group has clear guidelines with regards to the conflict of interest. Each employee is required to declare any conflict of interest to the Company on an annual basis.
Whistle blowing
A whistle blowing policy and other procedures are put in place to provide our employees and parties who have dealings with us to report suspected fraud, corruption, dishonest practices or other improprieties in the workplace without fear of reprisal from internal and external sources.
Disciplinary
If our employees are established and/or reasonably suspected to have been involved in prohibited practices, depending on the severity, disciplinary actions will be taken including official warning, immediate dismissal of employment and/or referral to relevant law enforcement authorities.
