ST Engineering Annual Report 2020

CORPORATE OVERVI EW PERFORMANCE REVI EW SUSTAINABI L ITY CORPORATE GOVERNANCE F INANCIAL REPORT We have zero tolerance for fraud and corrupt practices, and our Code of Business Conduct and Ethics (Code) forms the backbone of our commitment to ethical business conduct and regulatory compliance. We continue to focus onmeeting all relevant regulatory and customers’ requirements wherever we operate, including those relating to cybersecurity, data governance and protection and business continuity. Governance: Ethical Business & Regulatory Compliance In support of our Code and good corporate governance practices, we have established risk management and compliance policies and processes applicable Group- wide, including managing conflicts of interest, gifts and hospitality, and the appointment of intermediaries. Our conflict of interest policy provides guidance on the different types of conflicts, ranging from financial interest to employee relationships. All relevant 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 such conflicts. The Group has in place a gift and hospitality policy , setting out clear guidelines and principles on the giving and receipt of bona fide gift and hospitality items. This includes charitable donations and sponsorships, where the recipients are subject to appropriate due diligence before approval by senior management. The appointment and re-engagement of intermediaries (including agents) is 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 onboarding and ongoing screening against sanctions lists and negative media, mandatory anti- bribery and corruption training, 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. To reinforce our commitment to ethical business conduct and compliance with laws and regulations, we provide mandatory training on our Code and Anti- Bribery and Corruption (ABC) topics annually to relevant employees including all managers and those in high risk positions that frequently interact with business partners. We continuously assess our evolving employee pool and expect further adjustments in the number of relevant employees to be trained in 2021 given the reorganisation. 10 3 ANNUAL REPORT 2 02 0 / ANTI-BRIBERY AND CORRUPTION TRAINING Singapore Operations Global Operations 2020 2019 2018 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0 7,683 7,794 9,108 10,368 12,810 No. of relevant employees trained The training programme is conducted electronically. In 2020, we trained 98% of relevant employees, with training of the remaining 2% to be completed in 2021 upon completion of e-training module roll out. We also communicate our ABC policies and procedures to business partners, including new vendors and intermediaries. This year, we enhanced our e-learning, enrollment and reminders are now automated, and an overview of employees' learning histories are now provided. We also rolled out an e-learning module on Personal Data Protection Act to drive greater awareness. During the year, we engaged a consultant to review our enterprise risk management framework and the risk reporting process. This is to ensure that our risk management framework and internal control systems remain robust and aligned to current industry best practices. Our whistleblowing policy facilitates the in-confidence disclosures of possible impropriety or non-compliance. All stakeholders can report incidents through various reporting channels that are independently managed. These reporting channels can be accessed through our website at www.stengg.com. More information regarding our enterprise risk management framework and governance approach can be found in the Corporate Governance Report on pages 104 to 125.