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Ascott Residence Trust
Annual Report 2015
Corporate Governance
(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 to 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 this 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 so 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 fullest 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 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 screening and representative screening; and
(f) training.
