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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 CMA’s core values and not to indulge 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 a robust
anti-corruption clause.
Whistle-blowing Policy
Whistle-blowing policies and procedures are put in place
to provide employees of the Manager and parties with
dealings with CRCT with well defned, 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 aim of the whistle-blowing policy is to encourage the
reporting of such matters in good faith, with the confdence
that employees or external parties making such reports 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 Terrorist Financing
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
fnancing of terrorism. Under these guidelines, the main
obligations of the Manager are:
• customer due diligence;
• suspicious transaction reporting;
• record keeping;
• employee hiring; and
• staff training.
The Manager has developed and implemented a policy on
the prevention of money laundering and terrorist fnancing
and is alert at all times to suspicious transactions. Where
there is a suspicion of money laundering or terrorist fnancing,
the Manager performs thorough 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
Offce of the Commercial Affairs Department. In addition,
due diligence checks are conducted on Unitholders by
the Central Depository (Pte) Limited (CDP) and the stock
brokerages with whom the Unitholders open trading
accounts to trade in Units or shares. The CDP is a wholly
owned subsidiary of Singapore Exchange Limited. Likewise,
when placements of Units are made, the placement agents
would be the stock brokerages who would place the Units
with their account holders.
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 fve 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
licensed representatives to ensure they are updated and
aware of applicable anti-money laundering and terrorist
fnancing regulations, the prevailing techniques and trends in
money laundering and terrorist fnancing and the measures
adopted by the Manager to combat money laundering and
terrorist fnancing.
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