We Have Zero Tolerance for Fraud, Bribery and Corrupt Practices The Group has zero tolerance towards fraud, bribery and corruption, reinforced by our detailed policies and compliance procedures. Anti-Bribery and Corruption Risks The Group’s operations are assessed for risks related to bribery and corruption as part of the ERM framework. These risks may relate to third-party suppliers and intermediaries, corruption by employees, gifts & hospitality, donations & sponsorships to business partners & public officials. Our anti-bribery and corruption policy is included in our Code of Business Conduct and Ethics and is available to all our employees. Conflict of Interest Our Conflict of Interest policy provides guidance on the different types of conflicts, ranging from financial interest to stakeholder relationships. All employees are required to submit an annual declaration of conflict of interest. All declarations are subject to review by management, and employees are to comply with the recommended actions to address any conflict. Gifts & Hospitality The Group has a Gifts & Hospitality policy, setting out clear guidelines & principles on the giving and receipt of gifts and hospitality. This includes charitable donations and sponsorships, where beneficiaries and recipients are reviewed and subject to appropriate due diligence and approval by senior management. Intermediaries The appointment and re-engagement of all intermediaries are governed by a formal policy and procedures that entail a risk-based and thorough due diligence review process supported by independent, established service providers. The due diligence process includes (a) onboarding and ongoing screening against sanctions lists and negative media publicity, (b) mandatory anti-bribery and corruption training, and (c) compliance with our anti-bribery and corruption policy and clauses as part of the terms and conditions of the agreement. In addition, intermediaries are subject to due diligence checks by established, independent third-party service providers prior to and post appointment. Lobbying and Political Contributions Political contributions, donations and sponsorships must be approved by management in accordance with the Group’s approval limits policy and be made with the highest ethical standards and in compliance with all applicable laws. These must not confer a personal benefit and must not be given to gain a business advantage or to influence a business outcome or an official action. We Comply with All Applicable Export Control Regimes (ECRs) The Group complies with all applicable laws, regulations, trade sanctions and embargoes (collectively referred to as ECRs) governing the import and export of goods, services, software, technology, dual-use goods and information (collectively referred to as “Controlled Items”) of the jurisdictions that the Group operates in, including laws with extraterritorial application. The Group also strives to ensure that transactions undertaken by any party operating on behalf of the Group, including suppliers, agents, distributors, and resellers, comply with applicable ECRs. Strict adherence to this policy is required. Export Control The Group Export Control Policy is applicable to all our businesses. It aims to ensure that all our exports are not used for unauthorised purposes and comply with the applicable ECRs. Our businesses have put in place trade control procedures to embed compliance into the day-to-day business processes, namely commodities classification and screening of customers. Compliance with ECRs and the maintenance of an effective trade control system are supported by Export Control Officers who are appointed at the Group, regional, country and line of business levels. In the event of any violations, immediate reporting and corrective measures are to be carried out. All violations are promptly recorded in a central database for management oversight and monitoring of timely corrective actions. Significant violations and remediation measures are reported to the RSC. Additionally, lessons learnt are distilled and shared with target employees. 69 OVERVIEW OUR SUSTAINABILITY APPROACH ECONOMIC ENVIRONMENTAL GOVERNANCE INDEX SOCIAL
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