CLAS made no payment and donation to political campaigns, political organisations, lobbyists or lobbying organisations, trade associations and other tax-exempt groups, as it expects to be judged on its own merits. CapitaLand Hope Foundation’s constitution also states that no grant or assistance shall be given in aid of any political organisation or purpose. For more information on CLAS’ FBC Risk Management framework, Anti-Money Laundering and Countering the Financing of Terrorism measures, please refer to the Corporate Governance section on pages 131 to 133 of CLAS’ Annual Report 2023. GOVERNANCE laundering and terrorism financing information sources and lists of designated entities and individuals provided by MAS. Substantiated cases of FBC are reported quarterly to the ARC. Actions taken can include the termination of staff’s contract, and/or reporting to the appropriate external authorities. In FY 2023, three cases were substantiated2. Employees involved in all of these cases had their employment terminated. There were no cases involving anti-competition or money laundering behaviour. Processes were reviewed and actions were taken to prevent recurrence in the future. 2 These cases were disclosed regardless of the financial loss to CLAS. There was no financial loss to CLAS arising from these cases. Staff Supply Chain/Partners Communication/Signing of Code of Conduct › FBC Risk Management Policy › Annual declaration through the ‘CapitaLand Pledge’ to uphold CapitaLand’s core values, and not to engage in any corrupt practices › Relevant training › FBC Risk Management Policy › CapitaLand’s Supply Chain Code of Conduct and anti-corruption clause in key contracts Feedback Channels › Whistle-blowing reporting › Whistle-blowing reporting WHISTLE-BLOWING AND GRIEVANCE HANDLING A whistleblowing (WB) policy and other procedures, including grievance handling, are in place to provide employees and external parties who have dealings with the Managers 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 WB policy is to encourage the reporting of such matters – that staff 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. The identity of the whistle-blower is kept confidential. The ARC maintains oversight and monitoring of WB reports at its scheduled meetings. All employees of the Managers are informed of the WB policy which is available on CLI’s website and on the Intranet. For more information on CLAS’ WB policy, please refer to the Corporate Governance section on pages 123 and 132 of CLAS’ Annual Report 2023. CONFLICT OF INTEREST Employees complete an annual declaration which provides important information that allows actions to be taken to minimise any potential conflicts of interest. All employees are required to provide declarations on areas including indebtedness, directorships or employment outside the organisation, relatives working in the Group, securities trading and compliance with financial crime and sanction compliance policies. In FY 2023, there were no material conflicts of interest noted. ETHICAL MARKETING CLAS supports the ethical marketing of its products and services and practices fair competition, including room sales. It adheres to the Singapore Code of Advertising Practice (SCAP) and any other rules and regulations that apply. The SCAP was formulated against the background of national law, international law and practice, including the International Code of Advertising Practice published by the International Chamber of Commerce. 69 CAPITALAND ASCOTT TRUST
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