Positioning for the Future | 43
(c) reviews the Group Finance Manual which contains policies, procedures and guidelines such as mnancial authority
limits, capital and liquidity management, interest rate and foreign exchange management. The Group Finance
Manual and any updates, after being endorsed by the FBC, is subject to approval by the Board.
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The Company has devised and adopted a securities dealing policy for the Group’s ofmcers and employees which
applies the best practices recommendations in the Listing Manual. To this end, the Company has issued guidelines to
Directors and employees in the Group, which sets out prohibitions against dealings in the Company’s securities (i) while
in possession of material unpublished price-sensitive information, (ii) during the two weeks immediately preceding, and
up to the time of the announcement of, the Company’s results for each of the mrst three quarters of its mnancial year
and, (iii) during the one month preceding, and up to the time of announcement of, the Company’s results for the full
mnancial year.
Directors and employees of the Group are also prohibited from dealing in securities of other relevant listed entities in
the Group while in possession of unpublished price-sensitive information of these other listed entities by virtue of their
status as Directors and/or employees. Under these guidelines, they are also directed to refrain from dealing in the
relevant securities on short-term considerations. They are also regularly reminded of the laws against insider trading.
Code of Business Conduct
The Company adheres to an ethics and code of business conduct policy which deals with issues such as conmdentiality,
conduct and work discipline, corporate gifts and concessionary offers. Clear policies and guidelines on how to handle
work place harassment and grievances are also in place.
The policies and guidelines are published on the Company’s intranet, which is accessible by all employees.
The policies it has implemented aim to help detect and prevent occupational fraud in mainly three ways.
First, the Company offers fair compensation packages, based on practices of pay-for-performance and promotion
based on merit to its employees. The Company also provides various healthcare subsidies and mnancial assistance
schemes to alleviate the common mnancial pressures its employees face.
Second, clearly documented policies and work procedures incorporate internal controls which ensure that adequate
checks and balances are in place. Periodic audits are also conducted to evaluate the efmcacy of these internal controls.
Finally, the Company seeks to build and maintain the right organisational culture through its core values, educating its
employees on good business conduct and ethical values.
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The Company adopts a strong stance against bribery and corruption. In addition to clear guidelines and procedures
for the giving and receipt of corporate gifts and concessionary offers, all employees of the Group are required to
make a declaration on an annual basis where they pledge to uphold the Company’s core values and not to engage
in any corrupt or unethical practices. This serves as a reminder to all employees to maintain the highest standards of
integrity in their work and business dealings. The Company’s stance against bribery and corruption is also reiterated
by Management during its regular staff communication sessions.
The Company’s [ero tolerance policy against bribery and corruption extends to its business dealings with
third-parties. Pursuant to such policy, the Company requires that certain agreements of the Group incorporate
anti-bribery and anti-corruption provisions.
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A whistle-blowing policy and other procedures are put in place to provide the Group’s employees and parties
who have dealings with the Group with well demned, accessible and trusted channels to report suspected fraud,
corruption, dishonest practices or other improprieties in the workplace, and for the independent investigation of any
reported incidents and appropriate follow up action. The objective of the whistle-blowing policy is to encourage the
reporting of such matters - that employees or external parties making any reports in good faith will be able to do so
with the conmdence that they will be treated fairly, and to the extent possible, be protected from reprisal.
Corporate Governance & Transparency
