Introduction and Objective
Section A: Anti-Bribery and Corruption Policy
Policy and Procedures
- where a third party has close family, personal or business ties with government officials or authorities or their employees and officers;
- where a third party requests for payment in cash or for no records to be made of payments and/or refuses to sign a formal contract or to provide an invoice or receipt for the payments made;
- where a third party requests for payments of unexpected additional fee or commission or reimbursements of extraordinary or vague expenses, whether or not to ‘facilitate’ a service;
- where a third party requests for payments to ‘overlook’ potential legal or regulatory violations;
- where you receive invoices which appear to be non-standard, or the payment request exceeds what is stated in the invoice, or the invoice indicates payment for a fee or commission which appear large given the services stated to have been provided;
- where a third party demands lavish entertainment, hospitality or gifts before commencing or continuing contractual negotiations or provision of services; and
- where you are offered an unusually generous gift or lavish hospitality by a third party.
- Every employee shall have an unfettered right to file a genuine and bona fide complaint and shall not be restricted in the exercise of such right.
- Any complaint alleging obstruction or reprisals shall be received, reviewed and investigated in the same manner as any complaint alleging improprieties.
- The procedures for the receipt, retention and treatment of a complaint are set out in Appendix A and shall be fully complied with.
- Every complaint may be sent to or lodged in the manner to Designated Person, Head of Audit and Risk Management Committee.
- The identity of concerned employees who have lodged complaints shall be kept confidential anonymity.
- A Complaints Register shall be maintained or caused to be maintained for the purposes of recording details of all complaints received, including the date of such complaint and the nature of such complaint. The Complaints Register shall be made available for inspection upon any request of the Audit and Risk Management Committee.
- Designated Person will conduct an initial review of the report received and recommend the remedial, disciplinary or other action to be taken action taken by the Company. All investigations shall be reported to the Audit and Risk Management Committee for their attention and further action as necessary.
- Upon receipt of any Complaint, the Audit and Risk Management Committee may determine to commence or conduct further investigations or review and to take such remedial, disciplinary or other action as it deems appropriately. The Company reserves the right to take such action as the Audit and Risk Management Committee deems appropriate against any such Employees.
- In the event that if an employee is inconsistent or in conflict with the procedures will be charged with disciplinary action, up to and including dismissal or termination of contract in compliance with local and national laws, regulations, rules, directives or guidelines the extent of such inconsistence.
Section B: Procedures for Reporting Anti-Bribery and Corruption
The Group will uphold all laws relevant to counter bribery and corruption in all the jurisdictions in which the Group operates. For the Group’s businesses and operations in Singapore, Company is bound to observe all relevant and applicable laws which include but are not limited to the Prevention of Corruption Act of Singapore, Chapter 241, the Anti-Corruption Law 2013 of Myanmar, and any other anti-corruption laws in countries, in which the Group operates or does business.
- offering, promising or giving financial or other advantage to induce a person to perform an activity improperly, or to reward them personally for doing so; or
- requesting, agreeing to receive, or accepting a financial or other advantage personally to perform an activity improperly, or being rewarded personally for doing so.
- money, gift, loan, fee, reward, commission, valuable security or other property or interest in property of any description, whether movable or immovable;
- any contract, office or employment;
- any payment, release, waiver, discharge or liquidation of any loan, debt, obligation or other liability, whether in whole or in part; and
- any other service, favour or advantage of any description.
Reporting Policy and Procedures
b. Publication of these Procedures
The Company shall disseminate and publish these Procedures to all Employees together with all updates and clarifications.
c. Authority to receive Complaints
All Complaints, other than reports involving any Director, member of senior management (having designation of “Head/Chief/Managing Director of a Division” and above) shall be addressed to the Director, Risk Management and Assurance (the “Risk Management and Assurance Director”) who shall be authorised to receive and act on all Complaints received by or on behalf of the Group.
|Risk Management & Assurance, Financial Management Departmentemail@example.com|
|Mr George Thiafirstname.lastname@example.org|
|Mr Adrian Chanemail@example.com|
|Ms Wong Su Yenfirstname.lastname@example.org|
|Dato Timothy Ong Teck Mongemail@example.com|
|Professor Annie Kohfirstname.lastname@example.org|
- the identity of the Employee, in the opinion of the Audit and Risk Management Committee, is material to any investigation;
- it is required by law, or by the order or direction of a court of law, regulatory body or by the Singapore Exchange or such other body that has the jurisdiction and authority to require such identity to be revealed;
- the Audit and Risk Management Committee is if the opinion that it would be in the best interests of the Group to disclose the identity;
- it is determined that the Complaint was frivolous, in bad faith, or in abuse of these policies and procedures or lodged with malicious or mischievous intent; or
- the identity of such Employee is already public knowledge by reason other than disclosure under this paragraph 4.c.
- conduct its own investigation or review;
- instruct the internal auditors or external auditors other professionals to conduct further investigations or review;
- instruct management to take such remedial, disciplinary or other action as it deems appropriate;
- engage such third parties as the Audit and Risk Management Committee may determine, to commence or conduct further investigations or review;
- engage such third parties as the Audit and Risk Management Committee may determine to take such remedial, disciplinary or other action as it deems appropriate; and/or
- take any other action as Audit and Risk Management Committee may determine in the best interests of the Group.
The Company reserves the right to take such action as the Audit and Risk Management Committee deems appropriate against any such Employee.
c. Abuse of Policies and Procedures
The Group may, upon determination by the Audit and Risk Management Committee, take or cause to be taken such action as is appropriate against any Employee who has made a Complaint frivolously, in bad faith, in abuse of the policies and procedure herein or lodged with malicious or mischievous intent.