Governance Corporate Governance Together with various CLI policies and procedures, the FBC Risk Management Policy is available on CLI’s intranet and is accessible to the Manager’s employees. The policies implemented aim to help detect and prevent FBC by: • Offering a fair compensation package to employees, based on practices of pay-for-performance and promotion based on merit; and providing various healthcare subsidies and financial assistance schemes to alleviate the common financial pressures faced by its employees. • Documenting policies and work procedures which incorporate internal controls to ensure that adequate checks and balances are in place. Periodic audits are also conducted to evaluate the efficacy of these internal controls. • Building and maintaining the right organisational culture through its core values and educating its employees on business conduct and ethical values. In addition, the Manager also adopts the following CLI policies and guidelines, which call upon the Manager’s employees to observe ethical principles in the conduct of business activities which include: • Abiding by CLI’s Ethics and Code of Business Conduct Policies which deal with matters such as confidentiality, conduct and work discipline, corporate gifts and concessionary offers, including but not limited to setting out clear policies and guidelines on how to handle workplace harassment and grievances.1 This policy also stipulates that donations are not to be made to any political causes through CLI/CICT and/or CapitaLand Group’s philanthropic arm, CHF. • Abiding by the Anti-Money Laundering and Countering the Financing of Terrorism Policy; • Acting professionally and with integrity; • Practising fair competition; • Honouring contractual commitments made; • Ensuring that one does not make inaccurate or misleading statements; • Making decisions or representations only when duly authorised; • Ensuring appropriateness of frequency and venue when conducting business activities; • Maintaining security and confidentiality of data and information; • Ensuring that one does not manipulate business relationships for personal gains or interests. CLI’s zero-tolerance policy on FBC extends to all the Manager’s business dealings with third parties (including contractors, subcontractors, consultants, agents, representatives and others performing work or services for or on behalf of the Manager, Trustee and/or CICT). Pursuant to this policy, it requires that certain agreements entered by the Manager and/or Trustee incorporate anti-bribery and anti-corruption provisions. Whistleblowing policy A whistleblowing policy and other procedures, including grievance handling, are in place to provide the Manager’s employees and external parties who have dealings with the Manager or its authorised asset/property managers, with a well-defined, accessible and trusted channel to report grievances, suspected FBC, dishonest practices or other improprieties in the workplace. It also allows for the independent investigation of any reported incidents and the determination of appropriate actions for follow-up. The objective of the whistleblowing policy is to encourage the reporting of such matters – that employees or external parties making any report in good faith will be able to do so with confidence, that they will be treated fairly and to the furthest extent possible, be protected from reprisal if any. The Board, with the assistance of the ARC, as well as support from the Management, is responsible for the oversight and governance of FBC Risk Management. The ARC assesses the adequacy and effectiveness of the internal controls (including financial, operational, compliance and information technology controls) and risk management systems established by management to manage risks. 1 This includes the Securities Dealing Policy. It sets out prohibitions against dealings in CICT’s securities (i) while in possession of material unpublished price-sensitive information, (ii) during the one month preceding, and up to the time of announcement of the CICT’s results for the full financial year. Directors and/or employees are also required to refrain from dealing in securities of CICT and other relevant listed entities in the CLI Group if they are in possession of unpublished price-sensitive information of CICT and 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 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. 56 CapitaLand Integrated Commercial Trust
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