SUSTAINABILITY REPORT 2023 61 GOVERNANCE ORGANISATIONAL CAPITAL Substantiated cases are reported quarterly to the CLI Audit Committee and shared with the risk champions regularly. Actions taken can include the termination of employees’ contract, and/or reporting to the appropriate external authorities. In FY 2023, there were no substantiated cases of FBC, significant instances of non-compliance with laws and regulations and cases involving anti-competition or money laundering behaviour within CLCT. More details of CLCT’s FBC practices can be found on page 142 of CLCT’s Annual Report 2023. ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM MEASURES As a holder of a Capital Markets Services Licence issued by 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) evaluation of risk; (b) customer due diligence; (c) suspicious transaction reporting; (d) record keeping; (e) employee and CMSL Representative screening; and (f) training. The Manager has in place a policy on the prevention of money laundering and terrorism financing and remains alert at all times to suspicious transactions. Enhanced due diligence checks are performed on counterparties where there is a suspicion of money laundering or terrorism financing. Suspicious transactions will also be reported to the Suspicious Transaction Reporting Office of the Commercial Affairs Department. Under this policy, all relevant records or documents relating to business relations with the CLCT Group’s customers or transactions entered into must be retained for a period of at least five years following the termination of such business relations or the completion of such transactions. All prospective employees, officers and CMSL Representatives of the Manager are also screened against various money laundering and terrorism financing information sources and lists of designated entities and individuals provided by MAS. Periodic training is provided by the Manager to its Directors, employees and CMSL Representatives to ensure that they are updated and aware of applicable anti-money laundering and countering of terrorism financing regulations, the prevailing techniques and trends in money laundering and terrorism financing and the measures adopted by the Manager to combat money laundering and terrorism financing. OTHER ETHICAL MANAGEMENT ISSUES As a CLI-listed REIT, CLCT is committed to best practices and complies with the relevant legislations and requirements. Marketing activities relating to shopping malls and office spaces, such as advertisements and promotions (A&P), are generally guided by external A&P consultants, and are in compliance with local marketing requirements as stipulated by CLI. TRAINING CLI implemented initiatives to ensure that all employees understand CLI’s core values and principles that shape the way the company works and functions. This is a compulsory component in the onboarding training for new employees as part of the CLI Immersion Programme (CIP), an employee orientation from various countries. For existing employees, there are dedicated training courses in Singapore where specific examples and applications of CLI core values in the workplace are shared. This training component is also offered in China for CLCT employees who are based there. In 2023: ▶ 98.1% of CLCT employees attended training pertaining to Fraud, Bribery & Corruption and Whistle Blowing ▶ 85.1% of CLCT employees attended Cybersecurity training to acquire and refresh their knowledge on how to detect potential cyber breaches, especially with the increased reliance on digital services.
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