CORPORATE POLICIES CORE POLICIES Code of Conduct and Business Ethics Anti-Bribery & Anti-Corruption (ABAC) and The Handling of Gifts, Travel & Entertainment Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Conflict of Interest Whistleblowing Objectives • Establish fundamental principles covering all business practices • Achieve discipline, professionalism, loyalty, integrity and cohesiveness • Comply with ABAC law at each jurisdiction where ESR conducts business • Procedural defence against prosecution (if applicable) • Compliance with AML and CTF regulations in all jurisdictions • Implement Recommendations from the Financial Action Task Force • Set out the principles to manage conflicts of interests in compliance with applicable laws at each jurisdiction and the Hong Kong listing rules • Prevent and deter breach of legal requirements and violations of our Code of Conduct and Ethics and other corporate policies Mechanisms • Annual requirement for all employees to sign the Code of Conduct and Business Ethics Attestation Form • Clear identification of prohibited acts • Specific requirements in applicable jurisdictions • Establishing the true and full identity of each client • Transaction monitoring • Screening of high-risk clients • Annual requirement for Directors and employees to declare 1. Compliance with the Model Code for Directors’ securities transactions & disclosures of interests in share 2. All employees and directors to report any outside affiliations and 3. Connected transactions, if any • Mechanisms for making reports • Protection of whistleblowers • Procedures for investigation and disciplinary action ENVIRONMENTAL, SOCIAL AND GOVERNANCE REPORT 2021 36 PILLAR 3: CORPORATE PERFORMANCE
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