Business units are required to comply with all regulatory and internal policy requirements that are applicable to their trade activities, including proper record-keeping. Records maintained are made available for customer audit and inspection by government officials, as applicable. Export Review Process The Group adopts a risk-based approach to monitor its transactions. This includes procedures to review sales transactions against sanctions, as well as due diligence screening of customers. To ensure that the transaction is eligible for export, the relevant team carries out: i. Pre-export reviews. We review the classification of the export item including technical data, technology, software, and hardware prior to sharing, transferring, releasing to a third party. An assessment will also be conducted to ascertain that the classification of export and re-export items, transactions and activities are correct. Additionally, an assessment will be made on whether additional due diligence is required if any “red flags” or diversion risks are detected; ii. ECRs, Licenses and Authorisation reviews. We review the status of the transaction under the applicable ECRs and determine if all the necessary licenses or authorisations have been obtained; iii. Destination, party and end-use review. We review all transactions against all applicable destination, party and end use restrictions. We Empower our Employees to Uphold Business Ethics and Integrity The Group has detailed policies for our employees, as well as training and compliance procedures that are accessible to employees. Our Code of Business Conduct and Ethics is disseminated to employees globally in the form of digital handbooks and video messages from the EXCO. To reinforce awareness and ensure compliance with our Code of Business Conduct and Ethics, the Group mandates that all employees complete the e-learning module and self-attestation on a yearly basis. Our employees also receive annual training to enhance awareness on the Group’s anti-corruption policies and procedures, and trade compliance. Targeted training is provided for employees whose job functions entail greater involvement with Controlled Items. Whistleblowing channels have been established for our employees and other stakeholders to report any potential violations of our Code of Business Conduct and Ethics, policies and regulatory non-compliances. Our whistleblowing channels provide our employees and other stakeholders a platform to raise concerns, in confidence, about possible improprieties in business conduct, financial reports or other matters, without the fear of reprisal. No form of retaliation to the informant (internal or external) is tolerated for any report made in good faith. Appropriate disciplinary actions will be taken in the event of any findings of breach or non-compliance of our policies or any regulations. Read more about our Whistleblowing Policy and Procedures on our website. GOVERNANCE ETHICAL BUSINESS & REGULATORY COMPLIANCE Risk Culture Survey In 2024, Group R&A launched a risk culture survey to assess the current risk-related attitudes, behaviours, and awareness across the Group. The feedback received will be used to further enhance our well-established risk management strategies and culture. Identified action plans will be progressively implemented to build on our strengths and ensure continuous improvement. 70 ST ENGINEERING | SUSTAINABILITY REPORT 2024
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