Page 48 - ar2013

Corporate
Governance
against dealings in the CMT’s
securities (i) while in possession
of material unpublished price
sensitive information, (ii) during
two weeks before the release
of CMT’s results for the first
three quarters, and (iii) during
one month before the release
of CMT’s full-year results. The
Manager will also not deal in
the CMT’s securities during
the same period. Under these
guidelines, all Directors and
employees as well as certain
relevant executives of CMA
have been directed to refrain
from dealing in the CMT’s
securities on short-term
considerations. They are also
made aware of the applicability
of the insider trading laws at
all times.
(F) CODE OF BUSINESS
CONDUCT
The Manager 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 work place
harassment and grievances
are also in place.
All employees of the Manager
have each been given a printed
employee handbook which sets
out these policies clearly.
The Manager believes that the
policies it has implemented
help to detect and prevent
occupational fraud in mainly
three ways.
First, the Manager offers fair
compensation packages,
based on practices of
pay-for-performance and
promotion based on merit.
The Manager 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 Manager seeks to
build and maintain the right
organisational culture through
its core values, educating its
employees on good business
conduct and ethical values. The
Manager’s zero tolerance stance
against all types of fraud is also
regularly communicated at staff
communication sessions.
Anti-Corruption and
Bribery Policy
The Manager adopts a strong
stance against corruption
and bribery. In addition
to clear guidelines and
procedures for the giving
and receipt of corporate gifts
and concessionary offers, all
employees of the Manager are
required to make a declaration
on an annual basis where they
pledge to uphold the Manager’s
core values and not to engage
in any corrupt or unethical
practices. The Manager
believes that such an initiative
serves as a reminder to all
employees to maintain the
highest standards of integrity
in their work and business
dealings. The Manager’s stance
against corruption and bribery
is frequently reiterated by
Management during its
regular staff communication
sessions as well.
The Manager’s zero tolerance
policy towards corruption and
bribery extends to its dealings
with third party service providers
and vendors. Pursuant to such
policy, the Manager usually
requires that all agreements with
third party service providers
and vendors incorporate robust
anti-corruption and anti-bribery
provisions.
Whistle-Blowing Policy
Whistle-blowing policy and
procedures are put in place
to provide employees of the
Manager and parties with
dealings with CMT with well
defined, accessible and trusted
channels to report suspected
fraud, corruption, dishonest
practices or other impropriety
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.
On an ongoing basis, the
whistle-blowing policy is
covered during periodic
communications to employees
to promote fraud awareness.
Anti-Money Laundering and
Countering the Financing of
TerrorismMeasures
As a holder of a Capital Markets
Services licence issued by the
Clarity 46 CapitaMall Trust Annual Report 2013