1.1 The Company conducts its business in an honest, ethical and fair manner, free from all aspects of Bribery and Corruption and takes a zero-tolerance approach to Bribery and Corruption.
1.2 This Anti-Bribery and Corruption Policy (“Policy”) has the objective of:
1.3 The Policy provides for Company’s basic principles in preventing and fighting Bribery and Corruption and should be read together with Company’s other related guidelines, processes, procedures and policies.
This Policy shall apply to all Employees, Directors, and Business Associates of the Company.
3.1 Policy means this Anti-Bribery and Corruption Policy.
3.2 Bribery means the offering, promising, giving, agreeing to give, accepting or soliciting of an undue advantage of any value (whereby the advantage could be financial or non-financial), directly or indirectly, and irrespective of location(s), in violation of applicable law, as an inducement or reward for a person acting or refraining from acting in relation to the performance of that person’s duties.
3.3 Business Associates means an external party with whom Company has, or plans to establish some form of business relationship, and can include vendors, suppliers, contractors, agents, consultants, joint venture, joint venture partners, distributors, dealers, resellers, outsourcing providers, sub-contractors, advisors, representatives, intermediaries and investors of Company and where relevant, clients or customers of Company.
3.4 Compliance Function is led by SIA in consultation with Legal.
3.5 Conflict of Interest is where business, financial, family, political or personal interests could interfere with the judgment of persons in carrying out their duties for Company, leading to the interests of Company being undermined or Company being put at a disadvantage.
3.6 Corruption is where a party obtains, attempts to obtain a personal benefit or a business advantage through improper or illegal means. Corruption can be classified as grand, petty and political, depending on the amounts of money lost and the sector where it occurs. Corruption can include Bribery, extortion or kickbacks.
3.7 Directors means members of the Board of Directors (or the equivalent) of Company.
3.8 Employees means the employees of Company.
3.9 Facilitation Payment is an illegal and/or unofficial payment made in return for services that the payer is legally entitled to receive without making such payment.
3.10 FA means the finance/accounting function of Company.
3.11 Family Member means spouse, children, parents, siblings or any other person who has a relationship with the relevant Employee in question in a manner that could influence the impartiality of such Employee in the course of his/her work duties.
3.12 GEHT means gifts, entertainment, hospitality, travel and other benefits.
3.13 HOD means Head of Division.
3.14 HR means Human Resource function of Company.
3.15 LBGM means the Local Board of General Management of Company.
3.16 Legal means the legal function of Company.
3.17 Public Official is a person holding a legislative, administrative or judicial office, whether by appointment, election or succession, or any person exercising a public function, including for a public agency or public enterprise or any official or agent of a public domestic or international organisation, or any candidate for a public office.
3.18 SIA means the strategic internal audit function of Company.
3.19 CEO means the President & CEO of Company.
4.1 Company has zero tolerance for any form of Bribery or Corruption whether direct or indirect. This is regardless of where such acts are committed, and therefore includes conduct outside of the laws of the country that they conduct business in that may amount to Bribery or Corruption, regardless of whether the conduct is accepted as business practice.
4.2 Employees, Directors and Business Associates are prohibited from soliciting, receiving, procuring, offering, or giving Bribes in any form, and are required to adhere to the laws of the country that they conduct business in.
4.3 Employees and Directors who are found to be in breach of any applicable laws dealing with Bribery and Corruption, this Policy, or Company’s other applicable policies that directly or indirectly deal with Bribery and Corruption shall be subject to disciplinary action including but not limited to dismissal of employment.
4.4 Business Associates who are found to be in breach of any applicable laws dealing with Bribery and Corruption, this Policy, or Company’s other applicable policies that directly or indirectly deal with Bribery and Corruption shall be subject to appropriate action including but not limited to termination of a business relationship.
5.1 The Compliance Function shall be responsible for matters relating to Bribery and Corruption in Company.
5.2 The scope of responsibilities of the Compliance Function include:
6.1 There is an expectation for Employees, Directors and Business Associates not to act in conflict of Company’s interest when they represent Company in any dealing or transaction.
6.2 Conflicts of Interest is not a form of Corruption. However, it could create the risk of Bribery or Corruption occurring. Therefore, extra precautions should be taken by Employees, Directors and Business Associates to avoid any actual or perceived Conflict of Interest. Employees should declare any actual or potential Conflict of Interest in accordance with the company’s policies, processes and forms. Conflict of Interest that should be declared include where the Employee, Director or Business Associates or their Family Members have a personal or financial interest in a transaction outside of the formal arrangement or agreement with Company.
Facilitation Payments are strictly prohibited.
8.1 The offering, giving or receiving of GEHT must be conducted in line with Company’s related policies and procedures.
8.2 Business Associates should also take care to ensure that they are mindful of Company’s policies and procedures relating to GEHT. This includes where they are giving GEHT to Employees or Directors, and where they are receiving GEHT in their capacity as a Business Associate.
8.3 Care must be taken to ensure that no GEHT is given or received, including to or by Family Members that will or will appear to influence objective and fair business decisions. GEHT that can appear to influence business decisions are often those that are lavish in nature or beyond standard business courtesies.
9.1 Donations and sponsorships by Company to any party, including for any corporate social responsibility or scholarship in Company’s name shall adhere to the relevant Company policies.
9.2 Generally, the following shall apply:
9.3 Any suspected or actual issues of concern should be recorded and escalated immediately to the Compliance Function for their further action.
10.1 Commissions, introducer fees, discounts or other similar payments or benefits shall be based on the terms of conditions for employment with Company, the terms of engagement with a Business Associate and/or or internal policies and procedures (as may be applicable).
10.2 Such payments shall be reflected accurately in records maintained by FA.
10.3 Employees, Directors and Business Associates are prohibited from making any secret profits from their role with Company.
11.1 Procurement shall be conducted in accordance with Company’s procurement related policy and procedures.
11.2 As part of Company’s controls, the following general principles should be adhered to:
11.3 For any matter that falls outside the scope of the procurement policy & procedures, appropriate checks should be conducted by the Head of Division and FA to ensure payments are supported by sufficient and relevant documents in the engagement of a Business Associate for the work. Basic checks should be conducted to ensure that the selection is free from Conflict of Interest, the business and service run by the candidate is legitimate, and the candidate is not subject to any allegation or convictions relating to Bribery and Corruption.
12.1 Any dealings with any third parties that are external to Company, such as regulatory authorities or Business Associates, must be conducted in a transparent manner, arms-length manner, free from external influence.
12.2 The Business Associate(s), transaction or project should be periodically monitored by the respective business functions in the Company for Bribery and Corruption. Employees should continuously communicate and have engagement sessions with the Business Associates who represent them, particularly to regulatory authorities, and where possible obtain minutes/record/report of the Business Associates correspondences with regulatory authorities.
12.3 To assist with ensuring Company’s compliance with its Anti-Bribery and corruption obligations, Business Associates are expected to cooperate with Company. Business Associates should generally:
13.1 In managing existing Employees, HR shall ensure that:
13.2 Recruitment of Employees is to be conducted in accordance with Company’s policies, internal processes and procedures relating to recruitment, including ensuring:
14.1 Any suspected, attempted or actual breaches of this Policy, or of Company’s policies and procedures dealing with Bribery and Corruption should be reported via Company’s confidential reporting line, www.ethicspoint.com
15.1 Company shall implement both financial controls and non-financial controls in place to detect and prevent Bribery and Corruption from occurring.
15.2 Policies and procedures should capture the following controls:
Company recognises the importance of ensuring all persons representing them are aware of their stance on Bribery and Corruption as well as their obligations.
16.1 Policies and procedures shall be accessible by Employees and Directors. Employees are required to read and be familiar with the various documents and their amendments.
16.2 Training on Company’s Anti-Bribery policies and procedures shall be conducted periodically.
17.1 Company requires accurate, timely and reliable records to be maintained. Documents in Company shall be maintained by the respective division involved in the function relating to the document, in accordance with any written procedures. Such procedures are to ensure that records are kept in a secure, accurate and accessible manner.
17.2 The following records must be maintained in accordance with the Company’s Data Retention Guidelines or by applicable law, whichever is the longer:
Last Update & Approval: 12 September 2024
