Anti-Corruption and Bribery Policy


1.                POLICY STATEMENT

1.1            It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

1.2           We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of Singapore, including the Prevention of Corruption Act (Chapter 241) (“PCA”), in respect of our conduct both at home and abroad.


2.                ABOUT THIS POLICY

2.1             The purpose of this policy is to:

(a)               set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

(b)               provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues.

2.2             Under the PCA, it is an offence for a person to:

(a)               corruptly solicit, receive, or agree to receive for himself or any other person; or

(b)               corruptly give, promise or offer to any person whether for the benefit of that person or of another person,

any gratification as an inducement to or reward for:

(i)                 any person doing or forbearing to do anything in respect of any matter or transaction whatsoever, actual or proposed; or

(ii)               any member, officer or servant of a public body doing or forbearing to do anything in respect of any matter or transaction whatsoever, actual or proposed, in which such public body is concerned.

2.3            These prohibitions explicitly apply to actions by agents.

2.4            Any person found guilty of an offence shall be liable on conviction to a fine not exceeding S$100,000 or to imprisonment for a term not exceeding 5 years or to both. If it is proven that any matter or transaction is in relation to contract or a proposal for a contract with the government, the punishment would be a fine of S$100,000 or imprisonment not exceeding 7 years or to both. As an employer if we fail to prevent bribery we can face a fine and damage to our reputation. We therefore take our legal responsibilities very seriously.

2.5            In this policy, third party means any individual or organization that you may come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

2.6            While we may amend it from time to time, compliance with this policy is a condition of your contract with us.



This policy applies to all persons working for us or any Group Company or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.



4.1            The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2       The managing director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.

4.3            Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

4.4            You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the managing director.



5.1            Bribery is receiving, offering, promising, authorizing, giving, accepting or soliciting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

5.2            An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value. This includes the discharge of or protection from obligations or liabilities.

5.3            A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organization of any kind.

5.4            Corruption is the abuse of entrusted power or position for private gain.

5.5            This Policy covers bribery between private persons and bribery involving public servants.


6.                 WHAT YOU MUST NOT DO

6.1             It is not acceptable for you (or someone on your behalf), at any time, place, country, or situation, to:

(a)             give, promise to give, or offer, a payment, gift, hospitality, contract, release or protection from any obligation or liability with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

(b)             give, promise to give, or offer, a payment, gift, hospitality, contract, release or protection from any obligation or liability to a government official, agent or representative to “facilitate” or expedite a routine procedure;

(c)              give or accept a payment, gift, hospitality, contract, release or protection from any obligation or liability during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;

(d)             accept a payment, gift, hospitality, contract, release or protection from any obligation or liability from a third party that you know or suspect is offered with the expectation that we would provide a business advantage for them or anyone else in return;

(e)             accept payment, gift or hospitality from a third party that is unduly lavish or extravagant under the circumstances.

(f)               offer or accept a payment, gift, hospitality, contract, release or protection from any obligation or liability to or from officials or representatives of any government, any department of the government or a public body, or politicians or political parties;

(g)              threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or

(h)             engage in any other activity that might lead to a breach of this policy.



7.1            We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.

7.2            Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in Singapore, but are common in some other jurisdictions in which we operate.

7.3            Kickbacks are typically payments made in return for a business favour or advantage.

7.4            You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the managing director.



8.1            While offers of gifts and hospitality in a commercial setting may be commonly regarded as a means to create goodwill and cultivate or improve working relationships, You must recognise that there is a serious risk that such gifts and hospitality may fall within the realm of corruption, or be used to facilitate corruption, or may be perceived as or may give the appearance of corruption. As such, we take a very strict view of gifts and hospitality which could fall afoul of the corruption prohibitions and, in order to address these risks and issues, requires you to comply with our policy on gifts and hospitality.

8.2            As a general rule, you are prohibited from offering, providing or receiving, direct or indirectly, any gifts and hospitality in connection with your job or work for us or any of the Group Companies, save as is expressly permitted under and in strict compliance with our policy on gifts and hospitality. In particular, no gift or hospitality may be offered, provided or received for the direct or indirect purpose of, or otherwise in connection with, the gaining of an unfair advantage with the Group Company’s business partners, including its customers, contractors or suppliers, or which would fall afoul of any applicable anti-bribery or anti-corruption laws.


9.                  DONATIONS

9.1              We do not make contributions to political parties.

9.2              We do not make charitable donations.


10.             RECORD-KEEPING

10.1         We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

10.2         You must declare and keep a written record of all payments, hospitality or gifts given or received, which will be subject to managerial review.

10.3         You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

10.4         All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal transaction of any kind.



11.1         You must ensure that you read, understand and comply with this policy.

11.2         The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

11.3         You must notify the managing director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out in clause 16.


12.              HOW TO RAISE A CONCERN

12.1         You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.

12.2         If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify the managing director as soon as possible.

12.3         If you are unsure about whether a particular act constitutes bribery or corruption, raise it with the managing director.


13.              PROTECTION

13.1         Individuals who refuse to accept or offer a bribe, or who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

13.2         We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the managing director immediately.



14.1          Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

14.2         Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.


15.              BREACHES OF THIS POLICY

15.1          Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

15.2          We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.



The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only. If you encounter any of these red flags while working for us, you must report them promptly to the managing director:

(a)               you become aware that a third party engages in, or has been accused of engaging in, improper business practices;

(b)               you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;

(c)                a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

(d)               a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

(e)               a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

(f)                 a third party requests an unexpected additional fee or commission to “facilitate” a service;

(g)               a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

(h)               a third party requests that a payment is made to “overlook” potential legal violations;

(i)                 a third party requests that you provide employment or some other advantage to a friend or relative;

(j)                 you receive an invoice from a third party that appears to be non-standard or customized;

(k)                a third party insists on the use of side letters or refuses to put terms agreed in writing;

(l)                 you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

(m)             a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or

(n)               you are offered an unusually generous gift or offered lavish hospitality by a third party.


17.              CONTACTS


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