We Comply with All Applicable Export Control Regimes The Group complies with all applicable laws, regulations, trade sanctions and embargoes (collectively referred to as ECRs) governing the export of goods, services, software, technology, dual-use goods and information (“Controlled Items”) of all of the jurisdictions that the Group operates in. Export sales may also require compliance with extraterritorial laws like international sanctions lists issued by the U.S. The Group also strives to ensure that transactions undertaken by any party operating on behalf of the Group, including agents, distributors and resellers, comply with applicable ECRs. Strict adherence to this policy is required, except to the extent that a more stringent local law applies. 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 export control procedures to embed compliance into the day-to-day business processes, namely commodities classification, screening of customers or end-users, end-use destinations, end-use purposes and record keeping. Compliance with ECRs and the maintenance of an effective export 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 under the supervision of senior management and the EXCO. All violations are to be promptly recorded in a central database for management review and monitoring of corrective actions. Significant violations are reported to the RSC, where lessons learnt are distilled and shared. Business units comply with all record keeping regulatory and internal policy requirements that are applicable to their export activities. Records maintained shall be made available for inspection by government officials, upon reasonable notice. EXPORT REVIEW PROCESS The Group adopts a risk-based approach to monitor transactions. This includes procedures such as the review of sales transactions against sanctions, as well as due diligence screening of customers and end-users. 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, software, and hardware prior to sharing, transferring, releasing to a third party or dual-use. 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 the transaction 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 handbooks and video messages from the EXCO. To reinforce awareness and compliance of our Code of Business Conduct and Ethics, the Group mandates that all employees complete the e-learning module and selfattestation on a yearly basis. Our employees also receive regular training to reinforce awareness on the Group’s anti-corruption policies and procedures, and export control 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, irregularities and regulatory noncompliances. 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 breach or non-compliance. Read more about our Whistleblowing Policy and Procedures GOVERNANCE ETHICAL BUSINESS & REGULATORY COMPLIANCE 70 ST ENGINEERING SUSTAINABILITY REPORT 2022
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