Apart from ESR’s comprehensive corporate governance policies, ESG governance is also our main focus where we have established an ESG Committee chaired by the Group ESG Officer to oversee related matters and implement the overall framework across the Group. In 2021, ESR China and Japan have established a Sustainable Procurement Policy to ensure compliance with international and local regulations relating to procurement and to seek better procurement process design. COMPREHENSIVE, AUTOMATED COMPLIANCE SOLUTIONS • Group Code of Conduct: We deploy a web-based compliance monitoring solution called ComplySci to track employees’ attestations and training activities and in accordance with our Code of Conduct and related corporate policies. • Whistleblowing Policy: For employees, they can refer to the inhouse online system adopted by the Company to file the report by answering questions and uploading proof of documentation. All employees can report if any questions, concerns or observations are noticed in accordance with the Whistleblowing Policy. Any potential violation of ESR`s Group Code of Conduct can be submitted anonymously. For external third parties who have business connections 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 Company corporate webpage to download the “Whistleblowing Report Template” for reporting and submission purpose. All whistleblowing reports will be received and reviewed by the Group Compliance Director and the General Counsel in preparing the investigation report subsequently, if required. No workplace retaliation or ethics violation was filed on record during the reporting period. • Third Party Risk Management: In 2020, we purchased and implemented a new proprietary software and third party due diligence service platform called ComplianceDesktop® licensed by The Red Flag Group, a Refinitiv company. In 2021, we have put it into practice to facilitate an automated review and approval process of third parties prior to their engagement or having a business transaction with the Group, and as of today, 5,235 third parties including vendors, contractors and other suppliers, as well as capital partners and tenants, have been screened by / via / using the platform. Enhanced Focus on Third Party Risk Management During the year, our Group Compliance function worked closely with colleagues in all local offices to ensure smooth implementation of ComplianceDesktop® as part of our enhanced Third Party Due Diligence Workflow. The new automated process improves compliance and risk management across the Group by providing enhanced transparency. Third-party risk includes circumstances that could expose the Group to threats and risks through engagement with third parties. PHASE 1: INITIAL ASSESSMENT (COMPLETED IN 2019) • 3,716 third parties screened • 214 ‘hits’ requiring further review • 67 third parties underwent further assessment by ESR local offices • 100% resolution rate PHASE 2: AUTOMATION (SEPTEMBER – NOVEMBER 2020) • Implementation of automated Third Party Due Diligence Workflow • Training of responsible persons, business unit managers and Legal and Compliance teams • Successful roll-out of ESR ComplianceDesktop® across 8 markets PHASE 3: EXECUTION (JANUARY – DECEMBER 2021) • New Function added to ComplianceDesktop® where requestor can order an Enhanced Due Diligence report • As of the end of this reporting period, 5,235 third parties have been screened through the platform ESG PERFORMANCE R E A C H I N G N E W H E I G H T S 34 ESR STANDALONE FY2021 STRATEGIC REPORT
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