Whistle-Blowing Policy
A whistle-blowing policy and other procedures are put in place to provide employees of the Manager
and parties who have dealings with the Manager 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.
Anti-Money Laundering and Countering the Financing of Terrorism Measures
As a holder of a Capital Markets Services licence issued by the MAS, the Manager abides by the
MAS’ guidelines on the prevention of money laundering and countering the financing of terrorism.
Under these guidelines, the main obligations of the Manager are:
(a) customer due diligence;
(b) suspicious transaction reporting;
(c) record keeping;
(d) employee screening; and
(e) staff training.
The Manager has developed and implemented a policy on the prevention of money laundering and
terrorist financing and is alert at all times to suspicious transactions. Where there is a suspicion of
money laundering or terrorist financing, the Manager performs due diligence checks on its
counterparties in order to ensure that it does not enter into business transactions with terrorist
suspects or other high risk persons or entities. Suspicious transactions are also reported to the
Suspicious Transaction Reporting Office of the Commercial Affairs Department.
Under this policy, the Manager must retain all relevant records or documents relating to business
relations with its customers or transactions entered into for a period of at least five years following the
termination of such business relations or the completion of such transactions.
All prospective employees of the Manager are also screened against various lists of terrorist
suspects issued by the MAS. Periodic training is provided by the Manager to its Directors and
employees to ensure that they are updated and aware of applicable anti-money laundering and
terrorist financing regulations, the prevailing techniques and trends in money laundering and terrorist
financing and the measures adopted by the Manager to combat money laundering and terrorist
financing.
Corporate Governance
52 | CapitaMall Trust Annual Report 2014
