(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 workplace harassment and grievances are also in place.
The policies and guidelines are published on CL’s intranet which is accessible by all employees of
the Manager.
The policies that the Manager has implemented aim to 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 to its employees. 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.
Bribery and Corruption Prevention Policy
The Manager adopts a strong stance against bribery and corruption. 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. This serves as a
reminder to all employees to maintain the highest standards of integrity in their work and business
dealings.
The Manager’s zero tolerance policy towards bribery and corruption extends to its business dealings
with third parties. Pursuant to such policy, the Manager requires that certain agreements incorporate
anti-bribery and anti-corruption provisions.
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;
Corporate Governance
42 | CapitaRetail China Trust Annual Report 2014
