Overview Leadership Portfolio & Performance Sustainability & Governance Financial Statements and Other Information Code of Business Conduct The Managers adhere 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 CLI Group’s intranet, which is accessible by all employees of the Managers. The scope of the code is also published on the Website and may be accessed at https://www.capitalandascotttrust.com/about-us/the-managers. The policies that the Managers have implemented aim to help to detect and prevent occupational fraud in mainly three ways, as set out below. First, the Managers offer fair compensation packages, based on practices of pay-for-performance and promotion based on merit to their employees. The Managers also provide various healthcare subsidies and financial assistance schemes to alleviate the common financial pressures their employees may 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 Managers seek to build and maintain the right organisational culture through their core values, educating their employees on good business conduct and ethical values. Fraud, Bribery and Corruption Risk Management Policy In line with their core values, the Managers are committed to doing business with integrity. This is reflected in their longstanding zero tolerance stance against fraud, bribery and corruption. Consistent with this commitment, various policies and guidelines are in place to guide all employees of the Managers to maintain the highest standards of integrity in their work and business dealings. This includes clear guidelines and procedures for the giving and receipt of corporate gifts and concessionary offers, and an annual pledge by all employees of the Managers to uphold the Managers’ core values and to not engage in any corrupt or unethical practices. The Managers’ zero tolerance policy on bribery and corruption extends to their business dealings with third parties. Pursuant to this policy, the Managers require that certain agreements incorporate anti-bribery and anti-corruption provisions. The Managers’ employees undergo training and adhere to CLI’s Fraud, Bribery and Corruption Risk Management Policy (FBC Risk Management Policy). The FBC Risk Management Policy reiterates the strong stance against fraud, bribery and corruption, and sets the overarching approach and standards in managing fraud, bribery and corruption risks in an integrated, systematic and consistent manner. The Managers’ stance against bribery and corruption is also reiterated by Management during their regular staff communication sessions. More details of CLAS’ fraud, bribery and corruption risk management can be found on pages 87 to 92 of this Annual Report and in CLAS’ Sustainability Report 2023 which will be published in May 2024. ANNUAL REPORT 2023 131
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