Singapore Technologies Engineering Ltd

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including honesty and integrity. However, it does not cover the range of values sought by the question, or go into sufficient depth by explaining what they mean by such values and why they matter to the organisation. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, the company has appointed the Audit Committee and the Risk Review Committee with overall corporate responsibility for its ethics and anti-corruption agenda. However, it is unclear how this responsibility is shared between the two committees. The company therefore scores 1.

Based on public information, it is unclear whether the company has appointed a senior person responsible for implementing the company’s ethics and anti-corruption agenda. TI notes the existence of the IA but it is unclear whether this fulfils the role.

Based on public information, the Board reviews the group’s top ten risks, of which adherence to anti-corruption legislation is a factor. However, TI does not assess this to be sufficient evidence of a review of the company’s ethics and anti-corruption agenda. In addition, it is unclear how often this exercise is undertaken.

Based on public information, there is no readily available evidence to suggest the company has a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based.

Based on public information, there is no readily available evidence that the company has a formal process to review and update its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence of a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company has a risk profile which seems to include adherence to anti-corruption laws, but it is unclear whether this is implemented enterprise-wide.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is evidence that the company has contractual rights for the behaviour of agents with respect to countering corruption. However, it is not clear that the company has formal monitoring and audit procedures in place and that contracts are terminated if corrupt activities are found. The company therefore scores 1.

Based on public information, there is evidence that the company makes clear to contractors through policy and contractual terms, its stance on bribery and corruption. However, it is not clear that the consequences of non-compliance are made clear. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is evidence that the company has an anti-corruption policy which seems to include terms on gifts and hospitality, conflicts of interest, bribery and political contributions. However, the full code of conduct is not publicly available and as such cannot be assessed. The company therefore scores 1.

Based on public information, there is evidence that the company has a zero tolerance anti-corruption policy.

Based on public information, there is no readily available evidence that the company’s Anti-Corruption policy is easily accessible to Board members, employees and third parties, as it is not publicly available.

Based on public information, there is no readily available evidence that the company’s Anti-Corruption policy is easily understandable and clear to Board members, employees and third parties.

Based on public information, the Code of Conduct and Ethics applies to all employees. However, there is no explicit mention of whether it applies to members of the Board. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest. The company makes several references to conflicts of interest. However, these are assessed to be limited statements, it is not clear what applies to employees and directors, and the statements made do not define what would constitute a conflict of interest.

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company’s Code of Business Conduct and Ethics makes reference to gifts and hospitality, but this document is not public and therefore could not be assessed.

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company’s Code of Business Conduct and Ethics makes reference to gifts and hospitality, but this document is not public and therefore could not be assessed.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. The company’s Code of Business Conduct and Ethics makes reference to political contributions and donations, but as the document is not publicly available, it was not possible to assess the policy.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is no readily available evidence that the company provides training in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is evidence that employees who are found to be in violation of the Code of Business Conduct & Ethics may face disciplinary action. However, it is not clear whether this extends to members of the Board. Furthermore, the statement suggests that there may be exceptions. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. TI notes that the company has a Whistleblowing Framework but limited information is provided.

Based on public information, there is no readily available evidence that the company provides whistleblowing channels to all employees in all geographies.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to ensure that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

Based on public information, there is no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence that the company has a non-retaliation policy and that disciplinary measures are applied to employees who breach it.