STRENGTH IN UNITY 62 Compliance Risk The Group is committed to complying with the applicable laws and jurisdictions in its day-to-day business processes and does not tolerate any breaches in regulatory compliance. Non-compliance may result in litigation, penalties, fines or revocation of business licenses, which have potential reputational and financial impact. The Group has established a compliance framework that covers training, monitoring, reporting for any non-compliance including screening, investigations, enforcement and disciplinary actions. New and impending changes to regulations are closely monitored to ensure that the Group is adhering to regulatory requirements with material noncompliance or regulatory breaches escalated to the Board and management for follow-up. A comprehensive corporate governance framework has been established to maintain responsible and transparent business practices and adopt a zero-tolerance approach to fraud, bribery and corruption of any form in the conduct of business. All employees are committed to acting professionally, transparently, and fairly with integrity in all business dealings and relationships with the Group's stakeholders at all times. The framework includes policies on code of conduct and business ethics, conflict of interest, whistle blowing, anti-money laundering and counter terrorist financing, prohibition of bribery, acceptance or offer of gifts and entertainment and employee trading and handling of insider information to ensure that all business activities are conducted with honesty, fairness and high ethical standards. Compliance with policies and procedures is required at all times. Group Internal Audit will conduct a review of compliance with such policies, including ethical standards, annually. In addition, there are mandatory annual ethics and compliance training, employee trading and code of conduct attestation by employees. This includes contract staff who have at least a 12-month employment contract. Ethics training include completing mandatory courses on topics such as awareness on anti-money laundering, anti-bribery and anti-corruption via third party training platform whereby employees are required to pass an assessment in order to complete the course. The training will help new joiners and existing staff to understand the compliance policies and procedures which guide employees’ behaviour to meet the required standards and requirement, and also reinforce the employees' compliance knowledge and related protocols, as part of their ongoing business activities to minimise the compliance risks. Through the Group's Code of Conduct and Business Ethics and Whistleblowing policy, employees are encouraged to report control deficiencies, ethical issues or suspicions of impropriety to the local Compliance Officer, Group Compliance Officer or Group General Counsel, when applicable, through various whistleblowing channels. ESR Group is dedicated to treating whistleblower with fairness and ensuring their protection from reprisals, victimisation, or any form of detrimental or unfair treatment when they report in good faith. The confidentiality of all information received will be maintained, and the identities of all whistleblower will be safeguarded. All reported cases will be preliminary reviewed to understand the circumstances surrounding the allegation based on the information provided by the whistleblower. Management treats all misconduct and dishonesty seriously and seeks to conduct independent investigation and take appropriate disciplinary action on concerns raised, including termination of employment, if required. All independent investigations will be reported to the Audit Committee accordingly. Separately, a grievance, which may vary in complexity and severity, can be brought up by an employee to his/her manager, head of department or directly to the human resources department. In situations where the matter involves disciplinary action being taken against an employee, the human resources department will proceed with the necessary measures leading to the required action in accordance with the Disciplinary Action provision with the management’s approval. The management of the Group will review all grievance cases and aims to resolve complaints objectively, fairly, promptly, and confidentially.
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