CapitaLand Integrated Commercial Trust - Annual Report 2023

Material Risk Key Mitigating Actions Fraud, Bribery & Corruption Any form of fraud, bribery and corruption that could be perpetuated by employees, third parties or collusion between employees and third parties. • Foster a culture of ethics and integrity. • Adopt a zero-tolerance stance against fraud, bribery and corruption (FBC) across our businesses. • Communicate our commitment to integrity from the top through policies and practices, such as FBC Risk Management Policy, Whistle- blowing Policy, Ethics and Code of Business Conduct Policies and Anti- Money Laundering and Countering the Financing of Terrorism Policy. • Adopt e-learning modules to raise awareness and train employees on ways to avoid or prevent non-compliant behaviour. Investment & Divestment Deployment of capital into loss-making or below- target return investments due to wrong underwriting assumptions or poor execution. Inadequate planning to identify suitable divestment opportunities. • Evaluate all investment and divestment proposals against a rigorous set of criteria which includes potential for growth in yield, rental sustainability and potential for value creation. • Board reviews and approves all major investment and divestment decisions. • Rigorous review of key financial assumptions and key sensitivity analysis are undertaken. Third-party consultants are engaged and independent valuation is conducted, where required. • Identify potential risks associated with proposed projects and issues that may affect smooth implementation or attainment of projected outcomes at the evaluation stage and devise action plans to mitigate such risks as early as possible. • Integrate sustainability in real estate life cycle from the earliest stage of our investment and redevelopment processes. Regulatory & Compliance Non-compliance with applicable laws, regulations and rules, relating to fund management, tax, data protection & privacy, financial crimes and sanctions in the major economies and key markets in which CICT Group operates. • Maintain a framework that proactively identifies the applicable laws, regulations and rules, assesses the regulatory & compliance risks, and embeds compliance risk mitigation measures into day-to-day operations. • Leverage in-house specialised teams in CLI such as legal, compliance and tax, and external consultants to provide advisory services and updates on changes to laws, regulations and rules. • Rely on CLI's established group-wide policies and procedures to address the requirements of the applicable laws, regulations and rules such as Personal Data Protection Policy, Anti-Money Laundering and Countering the Financing of Terrorism Policy, Global Sanctions Compliance Policy and Tax Strategy. • Adopt e-learning modules to raise awareness and train employees on ways to avoid or prevent non-compliant behaviour. Overview Leadership Performance Framework Other Information ANNUAL REPORT 2023 131

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