57 / 132
55
EC World Real Estate Investment Trust ANNUAL REPORT 2016
The Manager has devised and adopted a securities dealing policy for the Manager’s officers and employees which
applies the best practice recommendations in the Listing Manual. To this end, the Manager has issued guidelines to its
Directors and employees which set out prohibitions against dealings in ECW Group’s securities:
(i)
while in possession of material unpublished price sensitive information;
(ii)
during two weeks immediately preceding, and up to the time of the announcement of, ECW’s financial statements
for each of the first three quarters of ECW’s financial year; and
(iii) during one month immediately preceding, and up to the time of the announcement of, ECW’s financial statements
for the full financial year.
Prior to the commencement of each relevant period, an email would be sent out to all Directors and employees of the
Manager to inform them of the duration of the period. The Manager will also not deal in ECW Group’s securities during
the same period.
Under the policy, Directors and employees of the Manager are discouraged to trade on short-term or speculative
considerations. They are also prohibited from using any information with respect to other companies or entities
obtained in the course of their employment in connection with securities transactions of such companies or entities.
The Manager has complied with its securities dealing policy in accordance with Listing Rule 1207(19).
(F) CODE OF BUSINESS CONDUCT
The Manager adheres to an ethics and code of business conduct policy which deals with issues such as confidentiality,
conduct and work discipline, corporate gifts and concessionary offers. Clear policies and guidelines on how to handle
workplace harassment and grievances are also in place. The policies and guidelines are published on Sponsor’s Intranet
which is accessible to all employees of the Manager. The policies that the Manager has implemented aim to help to
detect and prevent occupational fraud in mainly three ways.
First, the Manager offers fair compensation packages, based on practices of pay-for-performance and promotion
based on merit to its employees. The Manager also provides various healthcare subsidies and financial assistance
schemes to alleviate the common financial pressures its employees face.
Second, clearly documented policies and work procedures incorporate internal controls which ensure that adequate
checks and balances are in place. Periodic audits are also conducted to evaluate the efficacy of these internal controls.
Finally, the Manager seeks to build and maintain the right organisational culture through its core values, educating its
employees on good business conduct and ethical values.