Every quarter, Cluster Presidents and Presidents of the business areas will review their respective dashboard of key business risks with the RSC by rotation. During these engagements, emerging trends, critical uncertainties, areas for improvement and action plans are thoroughly discussed and addressed. In 2022, there were no significant regulatory non-compliances. We Are Guided by Our Code of Business Conduct and Ethics Our Code of Business Conduct and Ethics forms the foundation of the Group’s commitment to ethical business conduct and regulatory compliance. It was developed based on key principles guided by the Group’s Core Values namely, Integrity, Value Creation, Courage, Commitment and Compassion. These principles guide our employees on areas such as: 1. Workplace conduct – such as non-discrimination, and workplace safety and health 2. Security over information and assets – such as the importance of confidentiality of information entrusted to the company 3. Business conduct – such as zero tolerance for corruption and bribery, avoidance of potential conflicts of interest, as well as awareness of anti-trust and anti-competitive behaviour 4. Social responsibility – such as caring for the environment and engaging our communities 5. Reporting concerns – such as our policy on whistleblowing View our Business Code of Conduct and Ethics All reporting lines, responsibilities and accountabilities are clearly defined in our businesses. Employees are able to reach out to their direct line manager or R&A business partners for clarifications, and guidance on our Code of Business Conduct and Ethics. Employees are informed about the consequences of violating the standards in our Code of Business Conduct and Ethics. Employee misconduct may result in disciplinary action which may be reflected in their performance appraisal and can impact their renumeration. Employee misconduct of a serious nature may also result in termination. We Have Zero Tolerance for Fraud and Corrupt Practices The Group has zero tolerance towards fraud 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. 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. 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 employee 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 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 reengagement 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 lists and negative media publicity (b) mandatory anti-bribery and corruption training (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 thirdparty service providers prior to and post appointment. LOBBYING AND POLITICAL CONTRIBUTIONS 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 the Group operates in. These must not confer a personal benefit or be given to gain a business advantage or to influence a business outcome or an official action. The Group's lobbying contributions and expenses in the United States are reported to the Senate and is accessible via their website (https:// lda.senate.gov/system/public/). OVERVIEW OUR SUSTAINABILITY APPROACH ECONOMIC ENVIRONMENTAL SOCIAL GOVERNANCE INDEX 69
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