53 Environmental, Social and Governance Report 2022 PILLAR 3: CORPORATE PERFORMANCE COMPLIANCE ESR adheres strictly to the laws and regulations in the jurisdictions where we operate. In line with our Code of Conduct & Business Ethics and Group Human Resources Policy, while employees are free to take part in political activities, these activities must not create an impression that they are speaking or acting on the Company’s behalf, unless authorised by the Company to do so. ESR also prohibits any direct or indirect illegal political donations to political organisations or individuals in any form. No contributions and spending to any political party/politician for any campaign and/or related purposes were made during the reporting period. Leveraging on our technology and robust regulatory compliance framework, we have a compliance programme to ensure strict adherence to the highest standards of compliance and ethical conduct. • ComplySci® and Thomson Reuters e-learning — We deploy a web-based compliance solution called ComplySci® to oversee compliance risk management and track employees’ attestations to declare that they read, understand, and abide by the principles of ESR’s Code of Ethics and other compliance related policies, such as Conflicts of Interest Policy, Anti-Bribery & Anti-Corruption and Handling of Gifts, Travel and Entertainment Policy, Anti-Money Laundering & Counter-Terrorist Financing & Sanctions Policy, and Employee Trading and the Handling of Inside Information. We deploy an e-learning platform called Thomson Reuters e-learning to assign compliance related trainings to employees, which include mandatory courses on topics relating to all compliance related policies. The training includes a self-assessment for employees to complete the course. In addition, our Group Internal Audit team examines the ethical standards and compliance related policies at least once every three years to ensure that the related internal controls are effective. There were no breaches reported regarding our Code of Conduct and Business Ethics during the reporting period. The Group is committed to minimising conflicts of interest by implementing proper segregation of duties and clear prohibitive treatment towards situations where responsible party may gain personal interest during a business transaction. Risk Management & Compliance • Whistleblowing — Guided by our Code of Conduct & Business Ethics, Group Human Resources policy and Human Rights policy, we have in place grievance mechanisms for internal and external stakeholders to raise concerns on any issues such as infringements or violations related to compliance and workplace conduct. In line with our Whistleblowing policy, employees can refer to the in-house online system, ComplySci®, to file any reports. Employees can use this internal online system to submit anonymous reports by filling out situation-specific questions and attaching supporting documentation. All queries, concerns or observations reported by employees will be reviewed and investigated. In addition, we use whistleblowing@esr.com as the designated email address for third parties to report any incidents. The filed complaints received will be treated with the utmost confidentiality. External whistleblowers can also download and fill out the “Whistleblowing Report Form” to report their findings via our corporate website. The Group General Counsel and Group Compliance Director will consolidate and examine the submissions for internal communications and fact-checking. There were no complaints of workplace discrimination or ethics violations made during the reporting period. • Anti-Corruption Policy — ESR has a strong commitment to maintaining a rigorous Anti-Bribery and Anti-Corruption (ABAC) policy. This policy helps ensure compliance with relevant laws and regulations, and serves as a procedural defence in various jurisdictions where ESR operates. The policy applies to multiple countries, including Australia, China, India, Indonesia, Japan, South Korea, Singapore, Thailand, Vietnam, and the United Kingdom. It covers employees, as well as third-party vendors, suppliers, contractors, agents, intermediaries, joint venture partners, representatives, or consultants, and anyone else who conducts or may conduct business with the Group. 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 applicable tax regulations in jurisdictions we conduct business in. We routinely get updates on tax rules from our tax consultants and undertake additional evaluations and assessments.
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