SingLand is fully committed to conducting business with integrity and upholding high ethical standards which are in compliance with all applicable laws and regulatory requirements for the prevention of bribery and corruption.
In line with this commitment to maintain high ethical standards which are integral to our corporate identity and our business, SingLand adopts a “zero-tolerance” approach against all forms of bribery and corruption as set out in this Anti-Bribery and Corruption Policy (“Policy”), which applies to the SingLand group of companies (“Group”).
All SingLand employees and directors, and all third parties who represent us, or who are our suppliers, contractors or other business partners are required to comply with this Policy and all relevant anti-bribery and corruption laws in Singapore and other relevant jurisdictions, and are prohibited from engaging in any form of bribery or corruption (including any activity which creates even the appearance of improper conduct).
A bribe or corrupt action includes the receiving, offering, promising, authorising or providing “anything of value” (whether by doing something or not doing something) to any person, company or organisation (including any government, regulatory authority or public body and their officials, officers or members) in order to secure, induce or keep an improper or unfair advantage.
“Anything of value” includes (but is not limited to) money and cash equivalents like gifts, services, employment offers, loans, travel and entertainment, charitable donations, sponsorships, business opportunities, favourable contracts, personal favours, or giving anything even if nominal in value.
The giving or receiving of bribes in any form and for any corrupt purpose is an offence under, inter alia, the Prevention of Corruption Act 1960 and the Penal Code 1871 of Singapore, whether or not the benefit or effect of the bribe is enjoyed by the person giving or receiving the bribe or by some other person. The bribery offence may be established notwithstanding that the person was not able to complete the corrupt act requested or to put the corrupt intention into action.
Responsibilities of Employees
- not give or offer to give or authorise, aid or abet the giving of, directly or indirectly, anything of value that could be considered to be a bribe;
- not request or accept or authorise, aid or abet the request or acceptance of, directly or indirectly, anything of value that could be considered to be a bribe;
- ensure that they read, understand and comply with this Policy as well as any future updates and other materials issued from time to time as part of SingLand’s efforts to educate, address and prevent corruption;
- avoid any activity that might lead to, or suggest, a breach of this Policy;
- report as soon as possible any suspected breaches of this Policy to their immediate supervisor(s) or otherwise lodge a report (which may be anonymous) to the Head of the Internal Audit department in accordance with SingLand’s whistleblowing policy which is available on the company’s website.
SingLand’s “zero-tolerance” policy on bribery and corruption extends to all third parties with whom the Group has business dealings and relations with. Contracts with third parties include anti-bribery and corruption clauses and the right to immediately terminate contracts where there are violations of such clauses by any third party.
Where practicable and/or appropriate, reasonable steps should be taken to perform proper due diligence on third parties prior to any dealings, engagement or appointment in accordance with the Group’s due diligence procedures to ensure business is done with reputable, honest and qualified third parties.
Consequences of Violation
Apart from potential criminal and civil liabilities involving imprisonment and/or a fine, individuals who are found to be in violation of this Policy shall be subject to appropriate disciplinary action, which may extend to immediate termination of employment or appointment. Disciplinary action will also be taken against individuals who have knowledge of such violations but conceal such information from the Group, or who take detrimental action against others who report such violations.
It is NOT a valid excuse or defence that:
(a) the individual did not intend to personally benefit from the corrupt act or practice, but did so for the benefit of some other person, including SingLand and/or any of the Group companies;
(b) the individual was acting on the instructions of his/her supervisor(s);
(c) the individual personally believes such acts or practices are necessary or justified in order for SingLand to remain competitive or profitable in a particular jurisdiction or industry, or in order to retaliate against the corrupt practices of others (e.g. its competitors); or
(d) the individual personally believes that such acts or practices are common or normal business acts in a particular jurisdiction or industry.
This Policy will be reviewed from time to time, as appropriate, for an assessment of its effectiveness and will be updated as needed to ensure its continued adequacy and effectiveness.
Updated as at 11 July 2023