CapitaLand Integrated Commercial Trust - Annual Report 2021

to all the Relevant Persons to inform them of the duration of the black-out period. The Manager also does not deal in CICT’s securities during the same black-out period. In addition, Directors and certain employees identified as “Key Insiders” are prohibited from dealing in the securities of CICT, except during the open trading window (being one calendar month commencing from the relevant date of announcement of CICT’s results), provided that they are not in possession of undisclosed material or price-sensitive information. Employees and Capital Markets Services Licence Appointed Representatives (CMSL Representatives) of the Manager are also required to give a pre-trading notification to the CEO and the Compliance department before any dealing in CICT’s securities. This policy also provides for the Manager to maintain a list of persons who are privy to price-sensitive information relating to the CICT Group as and when circumstances require such a list to be maintained. Directors and employees of the Manager are also required to refrain from dealing in CICT’s securities if they are in possession of unpublished price-sensitive information of CICT arising from their appointment as Directors and/ or in the course of performing their duties. As and when appropriate, they would be issued an advisory to refrain from dealing in CICT’s securities. Under this policy, Directors and employees of the Manager are also discouraged from trading 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. A Director is required to notify the Manager of his or her interest in CICT’s securities within two business days after (a) the date on which he or she becomes a Director or (b) the date on which he or she acquires an interest in CICT’s securities. A Director is also required to notify the Manager of any change in his or her interests in CICT’s securities within two business days after he or she becomes aware of such change. Dealings by the Directors are disclosed in accordance with the requirements in the SFA and the Listing Manual. In FY 2021, based on the information available to the Manager, save as disclosed in accordance with such requirements and other than the awards of Units in part payment of Directors’ fees, there were no dealings by the Directors in CICT’s securities. Code of Business Conduct TheManager adheres toanethics and codeof business conduct policywhichdealswith issues suchas 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 CLI Group’s intranet, which is accessible by all employees of the Manager. The policies that the Manager has implemented aim to help to detect and prevent occupational fraud in mainly three ways, as set out below. First, the Manager offers fair compensation packages, based on practices of pay-for-performance and promotion based on merit to its employees. The Manager also provides various healthcare subsidies and financial assistance schemes to alleviate the common financial pressures its employees may 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 Manager seeks to build and maintain the right organisational culture through its core values, educating its employees on good business conduct and ethical values. Fraud, Bribery and Corruption Risk Management Policy In line with its core values, the Manager is committed to doing business with integrity. This is reflected in its longstanding zero tolerance stance against fraud, bribery and corruption. Consistent with this commitment, various policies and guidelines are in place to guide all employees of theManager tomaintain the highest standards Annual Report 2021 199 Corporate Governance