Anti-Bribery and Anti-Corruption Compliance

Asian Detours is committed to operating with the highest levels of integrity, and in compliance with all applicable laws. Bribery and corruption are never acceptable business practices and are not tolerated by Asian Detours. In addition to our Code of Business Conduct and Ethics, Asian Detours encourages a culture of integrity and transparency in all of the company’s activities.

All forms of bribery are prohibited at Asian Detours, whether conducted directly or indirectly through a third party, and whether involving Government Officials, private sector individuals, or private or state-owned companies. Asian Detours also prohibits facilitation payments.


The Asian Detours Anti-Bribery and Anti-Corruption Policy, applicable to all Asian Detours' entities, provides the overall framework for the company’s Anti-Bribery and Anti-Corruption Compliance Program as well as guidelines for the prevention, management, and remediation of bribery and corruption related risks. The Anti-Bribery and Anti-Corruption Policy and Procedure requires adherence to all relevant anti-bribery and anti-corruption laws, including the Singapore's Prevention of Corruption Act, and the laws of other countries where Asian Detours conducts business. Additionally, Asian Detours' Anti-Bribery and Anti-Corruption Guiding Principles provide key anti-corruption principles that apply to all interactions with the company’s customers, business partners, and other third parties in both the public and private sector.

Asian Detours' Anti-Bribery and Anti-Corruption Guiding Principles

Asian Detours (and our group of companies) is committed to operating with the highest level of integrity.

All Asian Detours colleagues must adhere to the following Anti-Bribery and Anti-Corruption Guiding Principles:

  1. Business activities must be conducted with integrity and in accordance with Asian Detours' Values.

  2. Bribery or corruption will not be tolerated, whether in the public or private sector.

  3. Facilitation payments are prohibited.

  4. Anti-corruption laws prohibit improper payments and require maintenance of accurate books and records for all transactions.

  5. If there are any inconsistencies between Asian Detours' policies and anti-corruption laws or regulations, the more restrictive standards apply.

  6. Certain interactions with Government Officials must be pre-approved.

  7. Compliance due diligence must be conducted on certain third parties prior to entering into engagements with them.

  8. Anti-corruption laws provide severe criminal and civil penalties for violations committed by both companies and individual employees.

  9. Concerns about potentially improper activity, doubts or questions must be raised to managers or directly to the management.

Asian Detours promotes a culture of open and honest communication. The company’s Open Door Policy encourages everyone to ask questions and raise concerns. Questions and concerns can be reported through various channels, including anonymously through email at integrity@asiandetours.com

Should you have any questions on our terms and conditions as listed above, please email us at info@asiandetours.com.

 
 

Asian Detours Anti-Bribery and Anti-Corruption Policy

SECTION A: ANTI BRIBERY AND ANTI CORRUPTION POLICY

Definition

For the purposes of this Anti Bribery and Anticorruption Policy, bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, or to induce or reward improper conduct.

Bribery and corruption, whether involving government officials, or commercial entities, including joint ventures, can be direct or indirect through third parties such as agents, brokers and joint venture partners including facilitation of payments.

Our commitment

Asian Detours as a Group of Companies is committed to put in place procedures to prevent bribery by any individual or organisation that performs services for or on behalf of the Group. Consequently, this Anti Bribery Policy applies to every employee, director and officer in every wholly-owned Group company and in every joint venture company which is subject to the control of the Group.

Contractors, consultants or suppliers who are our agents or who are working on our behalf or in our name, through outsourcing of services, processes or any business activity, will be required to act consistently with this policy when acting on our behalf. Independent contractors, consultants or suppliers will be made aware of this policy as it applies to our people in their dealings with them. Joint venture companies not under the Group control and joint venture partners are encouraged by the Group to adopt a similar policy, and adequate procedures, to prevent bribery.

Policy and Procedures

The Group does not tolerate any form of bribery or corruption.

You must not offer, pay, make, seek or accept a personal payment, gift or favour in return for favourable treatment or to gain any business advantage. You must follow the anti-bribery and corruption laws to which you and the Group are subject, remembering that Singapore anti-bribery and corruption laws apply wherever you are operating.

You are liable to disciplinary action, dismissal, legal proceedings and possibly imprisonment if you are involved in bribery and corruption.

You must ensure people who work for and with you understand bribery and corruption is unacceptable.

You must comply with the Operating Guidelines sets out below for the prevention of bribery and corruption.

Operating Guidelines

(a) Through Intermediaries and Third Parties

The Group prohibits the giving, offering, promising to give or offer, soliciting, accepting or receiving of any bribes through any intermediary agents, representatives, contractors and other associated persons of the Company acting on behalf of the Group.

For purpose of this Anti Bribery and Anti-Corruption Policy, “third parties” shall include actual or potential customers, suppliers, service providers, business contacts, agents, brokers, representatives, government and public bodies and any individual or organisation which the employee may come into contact with in the course of their employment.

(b) Gifts and Hospitality

The acceptance of gifts from customers, existing and/or potential, business partners, suppliers, contractors, competitors or members of the public is prohibited as it may create a situation of conflict or potential conflict of interest.

Pursuant to the Group’s Code of Conduct, Gifts not exceeding SGD$100 can be retained by the employee. All gifts exceeding SGD$100 must be recorded in a registry maintained by the relevant business head detailing the description of the gift, the name of the person providing the gift and the manner in which such gift was disposed of. Gifts exceeding SGD$100 can be retained by the employee if it has been declared to and approved by the relevant business head. It should be noted that retention of gifts is allowed only if they are received under non-obligatory circumstances.

As business lunches/dinners are an accepted mode of hospitality, these need not be declared but care must be exercised while accepting such meals. These should be infrequent. The sole purpose must be for enhancement of a business relationship and not for reciprocity.

It is important that gifts or hospitality never influence business decision-making process, cause others to perceive an influence or fall afoul of any applicable anti-corruption or anti-bribery laws.

(c) Facilitation Payments

The Group also prohibits the making of any ‘facilitation payments’, which are unofficial payments (sometimes known as ‘grease’ payments) made to public or government officials or authorities. No employee or any third parties should make any facilitation payments for and/or on behalf of the Group.

If in doubt as to whether a payment is a facilitation payment, the employee should seek the approval of senior management before proceeding further.

(d) Books and Records

The employees of the Group (the “Employees”) shall keep and maintain books, records and accounts in reasonable detail that accurately and fairly reflect transactions in or related to the Group’s business, including, but not limited to, accurately and fairly recording the purpose of any payment received or made.

(e) Political Contributions

Employees do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

(f) Charitable Contributions and Donations

Charitable contributions and donations are acceptable (certainly are encouraged), whether or in-kind services, knowledge, time or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. The Group only make charitable donations that are legal and ethical under local laws and practices.

No donation on behalf of the Company must be offered or made without the prior approval of Senior Management.

(g) Reciprocal Agreements

Reciprocal agreements or any other form of “quid pro quo” is not acceptable unless they are legitimate business arrangements, which are properly documented and approved by Management. Improper payments to obtain new business / contract retain existing business or secure any improper advantage should never be accepted or made.

Employees

Corruption and corrupt activities may take many forms and employees need to remain alert and discerning at all times. In conducting the business of the Group and in the course of your work, you must be aware of potential ‘red flag’ situations where there is generally a higher risk of corruption or which may raise concerns under the anti-corruption and anti-bribery laws.

Examples of ‘red flag’ situations may include but not limited to:

  • where a third party has close family, personal or business ties with government officials or authorities or their employees and officers;

  • where a third party requests for payment in cash or for no records to be made of payments and/or refuses to sign a formal contract or to provide an invoice or receipt for the payments made;

  • where a third party requests for payments of unexpected additional fee or commission or reimbursements of extraordinary or vague expenses, whether or not to ‘facilitate’ a service;

  • where a third party requests for payments to ‘overlook’ potential legal or regulatory violations;

  • where you receive invoices which appear to be non-standard, or the payment request exceeds what is stated in the invoice, or the invoice indicates payment for a fee or commission which appear large given the services stated to have been provided;

  • where a third party demands lavish entertainment, hospitality or gifts before commencing or continuing contractual negotiations or provision of services; and

  • where you are offered an unusually generous gift or lavish hospitality by a third party.

The onus is on the employee to prevent, detect and report any forms of corruption and bribery.

Employees are to adhere strictly to the Anti Bribery and Anti-Corruption Policy and any violation to the policy will be properly investigated.

Implementation
  1. Every employee shall have an unfettered right to file a genuine and bona fide complaint and shall not be restricted in the exercise of such right.

  2. Any complaint alleging obstruction or reprisals shall be received, reviewed and investigated in the same manner as any complaint alleging improprieties.

  3. The procedures for the receipt, retention and treatment of a complaint are set out in Appendix A and shall be fully complied with.

  4. Every complaint may be sent to or lodged in the manner to Designated Person, Head of Audit and Risk Management Committee.

  5. The identity of concerned employees who have lodged complaints shall be kept confidential anonymity.

  6. A Complaints Register shall be maintained or caused to be maintained for the purposes of recording details of all complaints received, including the date of such complaint and the nature of such complaint. The Complaints Register shall be made available for inspection upon any request of the Audit and Risk Management Committee.

Investigation
  1. Designated Person will conduct an initial review of the report received and recommend the remedial, disciplinary or other action to be taken action taken by the Company. All investigations shall be reported to the Audit Committee for their attention and further action as necessary.

  2. Upon receipt of any Complaint, the Audit and Risk Management Committee may determine to commence or conduct further investigations or review and to take such remedial, disciplinary or other action as it deems appropriately. The Company reserves the right to take such action as the Audit and Risk Management Committee deems appropriate against any such Employees.

Penalties

No employee has authority to violate this policy or any applicable anti-corruption or anti-bribery laws or to authorize anyone else to do so.

In the event that if an employee is inconsistent or in conflict with the procedures will be charged with disciplinary action, up to and including dismissal or termination of contract in compliance with local and national laws, regulations, rules, directives or guidelines the extent of such inconsistence.

In support of these procedures, the Group has determined that on the acceptance of gifts and hospitality in business relations, gifts not exceeding SGD$100 can be retained by the employee if it has been declared to and approved by the relevant business head.

In addition, the Group will review strictly in dealing with contractual relations to ensure no bribe, kickback, payoff or other improper payment or benefit will be proposed or entered into.

This policy will be disseminated and published to all employees, contractors, suppliers and business partners.

SECTION B: PROCEDURES FOR REPORTING ANTI BRIBERY AND ANTI CORRUPTION

1. Applicable Law

The Group will uphold all laws relevant to counter bribery and corruption in all the jurisdictions in which the Group operates. For the Group’s businesses and operations in Singapore, Company is bound to observe all relevant and applicable laws which include but are not limited to the Prevention of Corruption Act of Singapore, Chapter 241, and any other anticorruption laws in countries, in which the Group operates or does business.

2. Definitions

The following concepts are essential to understanding the scope of the prohibition on bribery and corrupt conduct. These concepts should be interpreted broadly.

“Bribery” refers to:

  • offering, promising or giving financial or other advantage to induce a person to perform an activity improperly, or to reward them personally for doing so; or
  • requesting, agreeing to receive, or accepting a financial or other advantage personally to perform an activity improperly, or being rewarded personally for doing so.

“Corruption” refers to the abuse of entrusted power for personal gain, including bribery, fraud, deception, collusion, embezzlement, insider trading, money-laundering and other similar activities.

A bribe, ‘kickback’, gratification or other corrupt payment may include but is not limited to the following:

  • money, gift, loan, fee, reward, commission, valuable security or other property or interest in property of any description, whether movable or immovable;
  • any contract, office or employment;
  • any payment, release, waiver, discharge or liquidation of any loan, debt, obligation or other liability, whether in whole or in part; and
  • any other service, favour or advantage of any description.

A ‘kickback’ is the unethical or illegal return of part of payment already made or to be made in a legitimate business transaction.

The giving or receiving of bribes in any form and for any corrupt purpose is an offence under the Prevention of Corruption Act, Chapter 241 (Singapore), whether or not the benefit or effect of the bribe is enjoyed by the person giving or receiving the bribe or by some other person. The bribery offence may be established notwithstanding that the person was not able to complete the corrupt act requested or to put the corrupt intention into action. The consequences for an individual or company being involved in bribery, whether directly or indirectly are extremely serious. Under the laws of Singapore, persons convicted of acts of corruption and bribery may be liable to a fine of up to $100,000 and/or to imprisonment for a term not exceeding 5 years.

“Complaint” means any complaints alleging Improprieties, Obstruction or Reprisals;

“Complaint Register” means a register to record detail of all Complaints lodged;

“Group” means the Company and its subsidiaries;

“Improprieties” means any activity, conduct or omission by an employee, officer or agent of the Group or external advisers, consultants or professional firm (including auditing firms providing external or internal auditing services) engaged by the Group which relate to accounting, financial reporting, internal controls, internal accounting controls, financial, operational and compliance controls or risk management practices that are questionable or may not be in accordance with generally accepted accounting principles, standards or practices or which relate to issues of honestly or integrity or the commission or any act or activity which may be contrary to any law or regulation;

“Obstruction” means the use or attempted use of force, authority, intimidation, threats, harassment, coercion, undue pressure or any other action or behaviour which is intended or leads itself to or in fact does impede, obstruct, influence or otherwise interferes with an employee’s or officer’s exercise of his right to report any improprieties or Reprisals or which may discourage other from so doing in the future; and

“Reprisals” means the use or the attempted use of force, authority, intimidation, threats, harassment, coercion, undue pressure or any act or omission or any negative or other inappropriate behaviour by any employee or officer of the Group, against any person who has failed or intends to file a Complaint.

3. REPORTING POLICY AND PROCEDURES

a. Reporting of Improprieties

The Company believes that it is in the best interests of the Group to promote an environment conducive for Employees to, in confidence, raise or report concerns about Improprieties, without fear of Reprisals, and to put in place arrangements for the investigation of such concerns for appropriate follow-up action.

b. Publication of these Procedures

The Company shall disseminate and publish these Procedures to all Employees together with all updates and clarifications.

c. Authority to receive Complaints

All Complaints, other than reports involving any Director, member of senior management (having designation of “Head/Chief/Managing Director of a Division” and above) shall be addressed to Mr Denis Koh who shall be authorised to receive and act on all Complaints received by or on behalf of the Group.

Name.                            Email.

Mr Denis Koh                denis.koh@asiandetours.com

All Complaints involving any Director, member of senior management (having designation of “Head/Chief/Managing Director of a Division” and above) shall be addressed to the Non-Executive Director(s) who may be reached at:-

Name.                            Email.

Mr Daniel Koh               complaints@asiandetours.com


d. Right to file Complaint

Every Employee shall have an unfettered right to file a genuine and bona fide Complaint and shall not be restricted in the exercise of such right.

e. Prohibition of Obstruction

The Company objects to and does not tolerate nor condone any Obstruction cause against any Employee who wishes or intends to file, or who is in the process of filling, a Complaint, and may institute such disciplinary action as it deems appropriate against any employee, officer or agent of the Group found to have caused or attempted to cause any such Obstruction.

f. Prohibition of Reprisals

The Company objects to and does not tolerate nor condone any Reprisals made against any Employee who has filed or attempted or intends to file a Complaint and may institute such disciplinary action as it deems appropriate against any Employee found to have made or attempted to make any such Reprisals.

Any Complaint alleging Obstruction or Reprisals shall be received, reviewed and investigated in the same manner as any Complaint alleging Improprieties.

4. COMPLAINT PROCEDURES

a. Procedures for handling Complaints

The procedures for the receipt, retention and treatment of a Compliant are set out below and shall be fully complied with.

b. Submission of Complaint

Every Complaint may be sent to or lodged in the manner described in paragraph 1.3 above.

c. Confidentiality of Identity

Employees are strongly encouraged to disclose their identity when lodging Complaints.

The identity of all Employees who have lodged Complaints shall be kept confidential save where:-

    1. the identity of the Employee, in the opinion of the Audit and Risk Management Committee, is material to any investigation;

    2. it is required by law, or by the order or direction of a court of law, regulatory body or by the Singapore Exchange or such other body that has the jurisdiction and authority to require such identity to be revealed;

    3. the Audit and Risk Management Committee is if the opinion that it would be in the best interests of the Group to disclose the identity;

    4. it is determined that the Complaint was frivolous, in bad faith, or in abuse of these policies and procedures or lodged with malicious or mischievous intent; or

    5. the identity of such Employee is already public knowledge by reason other than disclosure under this paragraph 2.3.

d. Registration of Complaints

A Complaints Register shall be maintained or caused to be maintained for the purposes of recording details of all Complaints received, including the date of such Complaint and the nature of such Complaint.

The Complaints Register shall be made available for inspection upon any request of the Audit and Risk Management Committee.

5. INVESTIGATION OF COMPLAINTS

a. Review and Investigation

All whistle-blowing reports, other than reports involving any Director, member of senior management (having designation of “Head/Chief/Managing Director of a Division” and above) shall be received by the Risk Management and Assurance Director who will log all reports into a register. The Risk Management and Assurance Director shall conduct an initial review of the report received and recommend the remedial, disciplinary or other action to be taken action taken by the Company.

In the event that the whistle-blowing reports involve any Director, member of the senior management or the Risk Management and Assurance Director, the reports shall be escalated to the Chairman of the Audit and Risk Management Committee, for his attention and further action as necessary.

b. Determination by Audit and Risk Management Committee

Upon receipt of any Complaint, the Audit and Risk Management Committee may;-

    1. conduct its own investigation or review;

    2. instruct the internal auditors or external auditors other professionals to conduct further investigations or review;

    3. instruct management to take such remedial, disciplinary or other action as it deems appropriate;

    4. engage such third parties as the Audit and Risk Management Committee may determine, to commence or conduct further investigations or review;

    5. engage such third parties as the Audit and Risk Management Committee may determine to take such remedial, disciplinary or other action as it deems appropriate; and/or

    6. take any other action as Audit and Risk Management Committee may determine in the best interests of the Group.

The Company reserves the right to take such action as the Audit and Risk Management Committee deems appropriate against any such Employee.

c. Abuse of Policies and Procedures

The Group may, upon determination by the Audit and Risk Management Committee, take or cause to be taken such action as is appropriate against any Employee who has made a Complaint frivolously, in bad faith, in abuse of the policies and procedure herein or lodged with malicious or mischievous intent.

 

Asian Detours Code of Business Conduct & Ethics

Introduction

Asian Detours and its subsidiaries (“the Group”) have adopted a Code of Conduct (“the Code”) that applies to all employees. The Code sets out the principles to guide employees in carrying out their duties and responsibilities to the highest standards of personal and corporate integrity when dealing with Asian Detours, its competitors, customers, suppliers, other employees and the community.

The Code sets the minimum standard that the Group expects of all employees, regardless of the jurisdiction or legal entity through which the Group operates. Where appropriate, the Code can be supplemented by additional specific requirements related to a country, entity or business unit.

It is the responsibility of every employee to comply with the spirit and principles of the Code, as amended from time to time.Compliance with the LawIn addition to the Code, Asian Detours expects employees to comply with all laws, regulations and legal requirements applicable to the different jurisdictions where it operates.


Workplace Health and Safety

The Group is committed to provide a healthy and safe work environment for employees, customers, business partners and visitors. Every employee has a personal responsibility to support this commitment.

Employees are obliged to carry out their work in a safe manner, without causing harm to themselves or others, and to report any potentially unsafe or unhealthy situations immediately.

They must observe and follow all safety and environmental regulations laid down in the operation instructions, including putting on the necessary safety equipment, where applicable.


Company Property and Assets

Employees are responsible for company property entrusted to them. This property includes, but is not limited to physical property (such as phones, company vehicles or computers), records (such as data on customers and company records), and intangible property (such as computer software and computer records). It is important that, whichever category the property falls into, employees must treat the Group’s property as they would their own and must not damage it, deface it or remove it for personal use, unless authorised to do so.

Similarly, they are responsible for the proper expenditure of the company’s funds including expenses. While spending or committing company funds, employees must be sure that the transaction is proper and documented, and that the company receives appropriate value in return.

Computers

Employees must use office computers, or terminals, only in the way in which they have been instructed. They should protect their own password and not use anyone else's ID or password to access records.

Unless authorised, employees must not alter records or software instructions. They must always ensure that any software they use has been obtained from authorised suppliers and should only install software if they are permitted to do so.

Just as they must not misuse company property, they must not dispose of any company property in an unauthorised manner, such as by selling, loaning or giving it away without proper permission.
Job PerformanceThe Group is committed to providing quality and efficient service to all customers, and every employee has an important role to play.

They are required to perform tasks assigned in a responsible and reliable manner and to manage time at work efficiently, without wasting company time and resources by taking part in unauthorised activities including, but not limited, to trading, gambling or political activities on the premises.


Dealings with other Employees

At all times, every employee has a responsibility to treat colleagues with respect and consideration. Improper behaviour includes, but is not limited to, discrimination or harassment in any form such as bullying, intimidation, threats, ridicule, sexual, racial or verbal abuse, insults, gestures, wilful or serious insubordination, physical violence etc. Asian Detours will not tolerate these behaviours and will take disciplinary action including termination or dismissal.

While on duty, employees must not conduct themselves in such a manner that will interfere with or prevent other employees from carrying out their duties properly.


Customers and Business Partners

Honesty in all dealings with the Government, businesses and other organisations is essential. Making of payments or payments in kind such as gifts or favours to influence individuals to award business opportunities to the Group or to make a business decision in the Group’s favour is prohibited.

Employees must always seek any third party's confidential information through the proper authorities. If given such confidential information, employees must ensure that they are entitled to have it, and obey the rules of having such information, if any.

They must always maintain good relationships with customers which is vital to the success of the business. Customers must feel that they are getting the highest standard of service from a company which listens to them and is responsive to their needs.

Information about customers and business partners must remain confidential and should only be imparted with full authority to do so.


Alcohol & Drugs

Drugs and/or alcohol can impair an individual's capacity to perform his/her job safely, efficiently and with respect for colleagues and customers. The use of such substances may result in injury or a threat to the well-being of an individual, colleagues, customers or members of the public.

An employee must attend work in a fit state and is not to be under the influence of alcohol or drugs during working hours.

Involvement with the manufacture, possession, use, distribution, sale, purchase, or transfer of illegal drugs is strictly prohibited.


Official Records

Information is a valuable asset of the Group and its integrity depends on the honesty, completeness and accuracy of its records. This means that anyone preparing the company's records and reports must be diligent in assuring the accuracy and completeness of all data, records, reports and expenditure connected with the company.

Employees must keep copies of company records such as installation data, customer records and test data at a safe location. For financial record keeping purposes, employees must not engage in any practice or procedure which might conceal, facilitate or constitute bribery, kickbacks, improper gratuities or other illegal or improper payments or receipts, or which might appear as such.


Proprietary Information & Intellectual Property

Many employees have access to information, which includes the trade secrets, know-how used by the Group to distinguish its businesses and services from those of competitors, as well as sensitive private business information of a commercial, technical or financial nature such as prospects, agreements with customers, business partners, competitors, account plans, business proposals, negotiations and contracts.

It is important that all company proprietary information is kept confidential. Employees have a duty to safeguard company information, bearing in mind ethical, legal ramifications and government regulations. Information of commercial value or of a sensitive nature must be tightly controlled. For example, when releasing information to a third party for a bid proposal, a Non-Disclosure Agreement (format provided by legal department) should be signed by the third parties, and information released is on a need-to-know basis.

Any trademark, copyrights, patents, designs, registered designs, proprietary information and all other intellectual property rights developed and commissioned by the company belong to the Group. Employees are reminded not to infringe any third parties' rights including, but not limited to, any third party intellectual property rights, copyrights, patents and trademarks.

The Group will hold exclusive property of any invention, discovery, design or improvements made. This could also include inventions employees may create which relate to the company’s business, regardless of whether the invention or designs are patentable or are capable of being registered or copyrighted.

Employees must report these inventions to the company and shall, at the company's request and expense, disclose information relating to the invention and do what is required to obtain patents or industrial rights relating to the invention. The patents will be in the name of the company or its nominee and the employee will not be entitled to any payment for the invention. The company's ownership of any intellectual property created by employees while with the company continues after they have left service.

When employees leave the company for any reason, including retirement, they must return all the company’s property, including all documents and records in their possession, and they must not disclose or misuse company confidential information. Employees are also responsible for protecting information provided in confidence by any third party, such as a customer, supplier or a partner, after they leave the company.


Disclosure of Official Documents, Information and Trade Secrets

All documents, papers and information acquired in an employee’s official capacity or otherwise should be treated as confidential and trade secrets of the Group. Employees must not copy, reproduce, extract, translate or in any way deal with them in a manner that is not authorised or allow others to do so, or disclose, publish or communicate them to the Press or to individuals whether directly or indirectly unless it is in the course of their official duties or if it is lawfully required or authorised by any Court of law or with authorisation from the Management. This clause shall continue to apply even after they are no longer employed by the Group.


Conflict of Interest

A ‘conflict of interest’ arises when employees have a competing professional or personal interest that would either make it difficult to fulfil their duties properly, or would create an appearance of impropriety that could undermine customer or public confidence.

Employees must do nothing that conflicts with the interests of the Group, or anything that could be construed as being in conflict, for example, participating in the evaluation/approval of award to a vendor in which an employee has a vested interest (either personally, or through close relatives). Employees should declare/disqualify themselves from handling transactions which put them, whether perceived or real, in a position of conflict.

Employees must avoid all situations which could result in conflicts of interest. They should comply with reporting and disclosure requirements of potential or actual conflicts of interest, and disclose any matters which could reasonably be expected to interfere with their professional duties.


Business Dealings

Employees should not engage in any outside business dealings that involve or could appear to involve, a conflict between their personal interests and the interests of the Group (i.e. conflict of interests).

Employees must not have any direct or indirect financial or business interest in or dealings with competitors, suppliers, customers or anyone else with whom they are engaged in a business relationship on behalf of the Group, which might or might appear to, create a conflict of interest, or impair the judgments they make on behalf of the Group.

They should also not engage in any personal business dealings which detract from or conflict with their employment in Asian Detours.

Employees must avoid situations where their loyalties may be divided between the Group's interest and those of a customer, supplier or competitor.

Employees must not take advantage of any opportunity for personal gain that rightfully belongs to Asian Detours. They should avoid putting themselves in any situation which might, or might appear to put them at a personal advantage, and they must report any potentially compromising situation to their supervisors promptly.


Employment Outside the Group

Employees should not engage in any outside employment or hold any position without the prior written consent of a Director unless such employment has been arranged or is undertaken in connection with the performance of their responsibilities and duties as part of the enlarged Group.

If employees are considering accepting an external appointment, they must consider if accepting this position may give rise to the possibility of conflict. If they have been given permission to take on such employment or to have other business relationships, they must ensure that these activities do not negatively affect their ability to fully and effectively perform their role for Asian Detours or Asian Detours' reputation and/or its services to customers or Asian Detours' current or future business plans.


Gifts and Hospitality

The acceptance of gifts from customers, existing and/or potential, business partners, suppliers, contractors, competitors or members of the public is prohibited as it may create a situation of conflict or potential conflict of interest.

Retention of Gift

Gifts not exceeding SGD$100 can be retained by the employee. All gifts exceeding SGD$100 must be recorded in a registry maintained by the relevant business head detailing the description of the gift, the name of the person providing the gift and the manner in which such gift was disposed of. Gifts exceeding SGD$100 can be retained by the employee if it has been declared to and approved by the relevant business head. It should be noted that retention of gifts is allowed only if they are received under non-obligatory circumstances.

As business lunches/dinners are an accepted mode of hospitality, these need not be declared but care must be exercised while accepting such meals. These should be infrequent. The sole purpose must be for enhancement of a business relationship and not for reciprocity.


Dealing with the Media

It is important that news about all company activities – from new partnerships to new services – be properly co-ordinated.


Statements made in any online forum (e.g. web logs or blogs) or social networking sites (e.g. Facebook) are considered to be public statements. No comments regarding the Group, its business, products, services, strategy or practices should be made without prior approval from Management. Where employees do participate in blogs or any other online space, even personal sites maintained outside of work hours, they should take care to ensure not to act in conflict with the best interests of the Group.


Fraud

Where an employee has concerns, or receives information about any fraud in connection with the affairs of the Group, it is the employee's responsibility to report those concerns or information.

Asian Detours adopts a "zero tolerance" approach to fraud and has implemented a formal policy, the Whistleblower Protection Policy which sets out the procedures for reporting and investigating fraud in connection with the business and affairs of the Group.


Penalties

Breaches of this Code will result in disciplinary action including termination or dismissal, as well as compensation for damage caused.

 

Asian Detours Conflict of Interest Policy

Objective

Asian Detours and its subsidiaries (“the Group”) have implemented its policy on ‘Conflict of Interest’ in support of a Corporate Governance framework, to assure the highest level of ethical conduct of persons employed by or involved in the governance of the Group in all that pertains to the Group, and to avoid public perceptions and financial consequences detrimental to the Group that could arise from the misuse, or perception of misuse, of an individual's position or influence.

The Group’s conflict of interest policy is not designed to eliminate or exclude relationships and activities that might create a duality of interest, but rather to encourage transparency and careful deliberation in those cases where conflicts or perceived conflicts may arise.

Conflicts of interest

A conflict of interest may be defined as an interest that might affect, or might reasonably appear likely to affect, the judgment or conduct of an individual associated with the Group.

A conflict of interest may exist when the interests or concerns or potential interests or concerns of any director, officer, fellow, or staff member, or any individual, group or organisation to which one of these people has allegiance, may be seen as competing with the interests or concerns of the Group, or may impair these people's independence or loyalty to the Group.

For example, a conflict of interest may exist if a director, officer, fellow, or staff member:

  1. has a business or financial interest in any third party dealing with the Group;

  2. holds office, serves on a Board, participates in management, or is employed by any third party dealing with the Group;

  3. derives remuneration or other financial gain from a transaction involving the Group (other than salary or salary and benefits expressly authorised by the Group);

  4. receives gifts from any third party on the basis of his or her position with the Group (other than occasional gifts valued at no more than $50, or if valued at more than $50, the gift is made available in a team space or common area for others to share - e.g., fruit baskets, boxes of candy). All other gifts should be returned to the donor with the explanation that the Group policy does not permit the acceptance of gifts. No personal gift of money should ever be accepted; and

  5. engages in any outside employment or other activity that will materially encroach on such person's obligations to the Group; compete with the Group's activities; involve any use of the Group's equipment, supplies, or facilities; or imply the Group's sponsorship or support of the outside employment or activity.

Disclosure

Whenever any director has a conflict of interest or a possible perceived conflict of interest with the Group, he or she shall notify the Chairman of the Board of Directors of such conflict. Whenever any staff member or fellow has a conflict of interest or a possible perceived conflict of interest with the Group, he or she shall consult with their supervisor or another member of the Senior Management Team and, if warranted, notify the CEO of such conflict.

When any conflict of interest is relevant to a matter under consideration or requiring action by the Board of Directors, or committee thereof, the interested person shall call it to the attention of the Chairman of the Board of Directors and shall not be present during Board or committee discussion or decision on the matter. However, that person shall provide the Board or applicable committee with any and all relevant information on the particular matter.

The minutes of the meeting of the Board of Directors or committee thereof shall reflect that the conflict of interest was disclosed, that the interested person was not present during discussion or decision on the matter, and did not vote.

Review and application of policy

The policy and its application shall be reviewed annually for the information and guidance of directors, officers, and staff members, each of whom has a continuing responsibility to scrutinise their transactions and outside business interests and relationships for potential conflicts and make such disclosures as described herein.

Each director will be asked to complete a Conflict of Interest Policy Disclosure Statement upon his or her election or re-election to the Board and annually thereafter. Each officer and senior staff member will be asked to complete such a Statement upon his or her employment and on an annual basis thereafter.

This policy will be disseminated and published to all directors, officers, fellow, employees, contractors, suppliers and business partners who is presently serving the Group, or who may hereafter become associate with it, together with all updates and clarifications.

 

Environment, Health & Safety

Objective

Asian Detours and its subsidiaries (“the Group”) have implemented its policy on ‘Environment, Health and Safety’ (“EH&S”) in support of a Corporate Governance framework, to:

  1. foster greater awareness of sustainable approaches across the Group;

  2. enhance its capabilities to identify and manage adverse impacts from all business activities; and

  3. instill a culture of ‘no harm, less pollution and wider conservation approaches to protect the environment’ in all business operations.

Our commitment

The Group is required to safeguard the environment by:

  • incorporating environmental and social considerations into business strategy, and allocate adequate resources to manage EH&S risks associated with projects;

  • promoting a safe, clean and healthy environment and better work culture to minimise any adverse environment, health, safety and social impacts arising out of operations;

  • establishing EH&S system and processes to adhere to and comply with applicable legislation, regulations and other requirements pertaining to environment, health, safety, labour and community at large;

  • optimising energy and resources by way of minimising wastes and increasing use of environmentally sustainable products, materials and services;

  • monitoring, reporting and improving of applicable procedures and performances (where required) regularly; and

  • communicating this EH&S Policy to all employees, contractors, suppliers and business partners.

This EH&S Policy will be disseminated to all employees, contractors, suppliers and business partners.

 

Human Rights Policy

Objective

Asian Detours and its subsidiaries (“the Group”) have implemented its policy on ‘Human Rights’ in support of a Corporate Governance framework, to:

  1. foster greater awareness of human rights throughout the Group including (but not limited to) equal opportunity, antidiscrimination, right to life, liberty, and security of person;

  2. enhance its capabilities to identify and manage adverse impacts from all business activities; and

  3. instill the culture of ‘respecting individuals’ right to freedom of thought, conscience, and religion including freedom of opinion and expression without interference’ in all business operations.

Our commitment

In line with applicable international and national practices, including the Universal Declaration of Human Rights, the International Labor Organization’s (ILO) Declaration and the tenth principle of United Nations Global Compact (UNGC), the Group is required to safeguard the human rights by:

  1. being involved in multilateral efforts to support human rights, as well as taking part in activities designed to promote human rights;

  2. making specific references to this Human Rights Policy in the Group’s standards, policies, procedures and ethical values;

  3. treating all employees with respect and dignity, promoting diversity in the workplace in consistent with the Group’s policies and procedures, and adhering to all applicable national laws and core labor principles;

  4. interacting with all employees in a manner that respects human rights and consistent with the spirit and intent of this Human Rights Policy;

  5. reinforcing awareness of potential human rights issues;

  6. monitoring, reporting and improving applicable procedures (where required) regularly; and

  7. communicating this Human Rights Policy to all employees, contractors, suppliers and business partners.

This Human Rights Policy will be disseminated to all employees, contractors, suppliers and business partners.

This EH&S Policy will be disseminated to all employees, contractors, suppliers and business partners.

 

Contact Us

ADDRESS

2 Netheravon Road, 

Civil Service Club

@ Changi 1 S01-01 Singapore 508503

PHONE

+65 - 6733 2282

EMAIL

ASIAN DETOURS GROUP OF COMPANIES

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