Overview Leadership Portfolio & Performance Sustainability & Governance Financial Statements and Other Information The Managers have in place a policy on the prevention of money laundering and terrorism financing and remain 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 Stapled 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 REIT 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 REIT 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 REIT Manager to combat money laundering and terrorism financing. Global Sanctions Compliance The Managers are committed to carrying on business in accordance with the highest ethical standards. This includes complying with applicable sanctions laws and regulations. The international nature of CLAS’ business means that the transactions CLAS engages in may be subject to unilateral sanctions imposed by relevant authorities. To help ensure that the Managers and its directors, employees and officers and other third parties acting on its behalf or any entity within CLAS fully complies with all sanctions applicable to CLAS’ business activities, the Managers are subject to a policy to comply with sanctions. The policy sets out the sanctions risk appetite and the risk management framework to help directors, employees and third parties identify the areas where breaches of applicable sanctions laws might arise and to support them in making the right decisions in line with the corporate position as stated in the policy and in the process establish a consistent approach for the Managers’ response to sanctions laws and regulations. ANNUAL REPORT 2023 133
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