60 CAPITALAND CHINA TRUST GOVERNANCE ORGANISATIONAL CAPITAL Together with various CLI policies and procedures, the FBC Risk Management Policy is published on CLI’s intranet and is accessible by 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, these various policies and guidelines call upon the 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. Clear policies and guidelines on how to handle workplace harassment and grievances are also in place. Donations are not to be made to any political causes through CLI and/or the Group’s philanthropic arm, CapitaLand Hope Foundation (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; ▶ Not making 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; ▶ Not manipulating business relationships for personal gains or interests. CLI’s zero-tolerance policy on FBC extends to our business dealings with third parties (including contractors, subcontractors, consultants, agents, representatives and others performing work or services for or on behalf of CLI). Pursuant to this policy, it requires that certain agreements of the Company incorporate anti-corruption provisions. Employees Supply Chain / Partners Communication/ Signing of Code of Conduct ▶ FBC Risk Management Policy ▶ Annual declaration through the "CLI Pledge" to uphold CapitaLand's core values, and not to engage in any corrupt practices ▶ Relevant training ▶ FBC Risk Management Policy ▶ CLI Supply Chain Code of Conduct. and anti-corruption clause in key contracts Feedback Channels ▶ Whistle-blowing reporting ▶ Whistle-blowing reporting A whistle-blowing policy and other procedures, including grievance handling, are in place to provide CLCT’s employees and external parties who have dealings with the Company, 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 determination of appropriate actions for follow up. The objective of the whistle-blowing 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.
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