We are automating key components of our compliance programme to ensure strict adherence with high standards of ethical conduct throughout our business. • ESR Group Code of Conduct — We deploy a web-based compliance monitoring solution called ComplySci® to track our employees’ attestations and training activities in accordance with our Code of Conduct and other corporate policies such as ABAC and CTF. • Whistleblowing Policy — For employees, they can refer to the in-house online system adopted by the Company to file the report by answering questions and uploading documents proof. All employees can report if any questions, concerns or observations are noticed. Any potential violation of ESR’s Group Code of Conduct can be submitted anonymously. For external third parties who have business connection with the Group, they can submit the report to the designated email address at whistleblowing@esr.com and all information received will be treated with strict confidence. They can refer the Group’s corporate webpage to download the “Whistleblowing Report Template” for reporting and submission purpose. All whistleblowing reports will be received and reviewed by the Group’s Head of Compliance and the General Counsel in preparing the investigation report subsequently. No workplace retaliation or ethics violation was filed or recorded during the reporting period. • Anti-Corruption Policy — ESR is committed to having a rigorous Anti-Bribery and Anti-Corruption (“ABAC”) policy. The policy serves ESR and employees to comply with relevant laws and regulations, and also provides a procedural defence in different jurisdictions where ESR conducts business. The policy is applicable to multiple countries such as Australia, China, India, Japan, South Korea, Hong Kong, Singapore, U.K. and U.S.. It covers employees and third-party vendors, suppliers, contractors, agents, intermediaries, joint venture partners, representatives or consultants and any persons with whom the Group does or may do business with. To promote business integrity in the Group’s business dealings, the following “4R Rules” shall be observed at all times: a) comply with Regulations, b) be Reasonable, c) be Responsible and d) Keep Books and Records accurately. • Tax Compliance – ESR complies with the tax laws of each of the jurisdictions it operates in. In addition, we receive updates on the tax laws on a regular basis from our tax consultants and conduct further reviews and assessments accordingly. OTHER POLICIES Information Security Communications Guideline Privacy (ESR Australia) Modern Slavery (ESR Australia) Sustainable Procurement Policy (ESR China, India & Japan) Asset Development & Management Guidelines (ESR China, India & Japan) Objectives • Preserve the confidentiality, integrity and availability of information • Comply with disclosure requirements in accordance with prevailing best practices • Comply with the Privacy Act (including the Australian Privacy Principles) • Comply with applicable legislation, including the Modern Slavery Act 2018 (Commonwealth Act) • Comply with the leading international and local regulations and best practices relating to procurement • Provide ESG Framework throughout the business cycle of Asset Development for entities and corresponding funds Mechanisms • Information Security Management Committee led by the IT director • Information security framework and management system • Procedures for critical communications, media enquiries, internal communications and use of social media • Measures to protect information from misuse, interference, loss and unauthorised access, modification and disclosure • ASO ISO 31000:2018 risk management system • Annual public disclosure • Ensure consistency with our fiduciary responsibilities to its investor clients • Continuously seeking to design and implement sustainable procurement process that are in compliance with or exceeding these standards • Best practices for ESG in asset development which are internally followed • Definition of ESR business cycle including “What we do”, “Key processes” and “How we do it” CORPORATE POLICIES ENVIRONMENTAL, SOCIAL AND GOVERNANCE REPORT 2021 37 PILLAR 3: CORPORATE PERFORMANCE
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