The Code of Business Conduct and Ethics is disseminated to employees globally in the form of handbooks and video messages from senior management. To supplement this Code, we have developed an e-learning module which is to be completed by all employees on a yearly basis. Read more about our Code of Business Conduct and Ethics LOBBYING & POLITICAL CONTRIBUTION Political contributions, donations or 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 of the jurisdictions where we operate in. They 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. CYBERSECURITY / DATA PRIVACY & PROTECTION ST Engineering understands the need for strong cybersecurity as digital technology and highly connected economies and businesses bring new vulnerabilities from a proliferation of cyber threats. We continue to strengthen our cyber resilience with a system of cybersecurity capabilities that comprises People, Process and Technology. We also equip our employees with relevant cybersecurity knowhow through internal campaigns to protect the Group from cyber threats. Our Personal Data Policy is available on our website. We have implemented policies and practices in our organisation to ensure we comply with applicable data protection laws and regulations. These policies describe the types of personal data we may collect from individuals, how we may use that information, and to whom we may share it with. They also prescribe the measures that we take to protect the security of the personal data entrusted to us. Read more about our Personal Data Policy ANTI-BRIBERY & CORRUPTION The Group has zero tolerance for fraud and corruption and has detailed policies and compliance procedures related to anti-bribery and corruption. Employees The Group has detailed policies for our employees, as well as training, compliance procedures and whistleblowing channels that are accessible to employees and external parties. Our Code is designed to ensure our employees uphold the highest standards of business ethics and integrity. Severe disciplinary actions will be taken in the event of any breach or non-compliance. Risks The Group’s operations are assessed for risks related to corruption as part of the Enterprise Risk Management framework. In addition, the Group’s R&A function and IA collaborate closely to examine potential corrupt practices in the planning and conduct of their reviews. The significant corruption-related risks as identified relate primarily to using third-party suppliers and intermediaries, corruption by employees, and gifts, hospitality, donations and sponsorships to business partners and public officials. Conflict of Interest 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 any conflict. Gifts and Hospitality The Group has a Gifts and Hospitality policy, setting out clear guidelines and principles on the giving and receipt of gifts and hospitality items. This includes charitable donations and sponsorships, where recipients are reviewed and subject to appropriate due diligence before approval by senior management. Intermediaries The appointment and re-engagement of intermediaries are governed by 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 119 CORPORATE OVERVIEW PERFORMANCE REVIEW SUSTAINABILITY FINANCIAL REPORT Read more about our Personal Data Policy CORPORATE OVERVIEW PERFORMANCE REVIEW SUSTAINABILITY FINANCIAL REPORT GOVERNANCE → Corporate Governance Report Read more about our Code of Business Conduct and Ethics 78 ST ENGINEERING SUSTAINABILITY REPORT 2021 OVERVIEW OUR SUSTAINABILITY APPROACH ENVIRONMENTAL SOCIAL GOVERNANCE AWARDS INDEX
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