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CapitaLand Limited
Annual Report 2015
Overview
Sustainability
Business
Review
Portfolio
Details
Corporate
Governance &
Transparency
Financials &
Additional
Information
Dealings in Securities
The Company has devised and adopted a securities dealing policy for the Group’s officers and employees which
applies the best practice recommendations in the Listing Manual. To this end, the Company has issued guidelines to its
Directors and employees in the Group which set 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possession of material unpublished price-sensitive information, (ii) during the two weeks immediately preceding, and up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 financial statements for each of the first three quarters of its financial
year and, (iii) during the one month immediately preceding, and up to the time of the announcement of the Company’s
financial statements for the full financial year. Prior to the commencement of each relevant period, an email would be
sent out to all Directors and employees of the Group to inform them of the duration of the period.
Directors and employees of the Group are also prohibited from dealing in securities of the Company and/or other relevant
listed entities in the Group if they are in possession of unpublished price-sensitive information of the Company and/or these
other listed entities by virtue of their status as Directors and/or employees. As and when appropriate, they would be issued
an advisory to refrain from dealing in the relevant securities.
Under the policy, Directors and employees are also discouraged to trade on short-term or speculative considerations. They are
also prohibited from using any information with respect to other companies or entities obtained in the course of their employment
in connection with securities transactions of such companies or entities.
Code of Business Conduct
The Company adheres to an ethics and code of business conduct policy which deals with issues such as confidentiality,
conduct and work discipline, corporate gifts and concessionary offers. Clear policies and guidelines on how to handle
workplace 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 the Company has implemented aim to help to 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 financial assistance schemes to
alleviate the common financial 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 efficacy 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.
Bribery and Corruption Prevention Policy
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 zero tolerance policy towards bribery and corruption extends to its business dealings with third-parties.
Pursuant to this policy, the Company requires that certain agreements of the Group incorporate anti-bribery and anti-corruption
provisions.
Whistle-Blowing Policy
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 defined, 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 confidence that they will be treated fairly and, to the
extent possible, be protected from reprisal.
