58 / 132
56
EC World Real Estate Investment Trust ANNUAL REPORT 2016
Bribery and Corruption Prevention Policy
The Manager adopts a strong stance against bribery and corruption. In addition to clear guidelines and procedures for
the giving and receipt of corporate gifts and concessionary offers, all employees of the Manager are required to make
a declaration on an annual basis where they pledge to uphold the Manager’s core values and not to engage in any
corrupt or unethical practices. This serves as a reminder to all employees to maintain the highest standards of integrity
in their work and business dealings. The Manager’s zero tolerance policy towards bribery and corruption extends to its
business dealings with third parties. Pursuant to this policy, the Manager requires that certain agreements incorporate
anti-bribery and anti-corruption provisions.
Whistle-Blowing Policy
A whistle-blowing policy and other procedures are put in place to provide employees of the Manager and parties
who have dealings with the Manager with well defined, accessible and trusted channels to report suspected fraud,
corruption, dishonest practices or other improprieties in the workplace, and for the independent investigation of any
reported incidents and appropriate follow up action. The objective of the whistle-blowing policy is to encourage the
reporting of such matters so that employees or external parties making any reports in good faith will be able to do so
with the confidence that they will be treated fairly and, to the fullest extent possible, be protected from reprisal.
Anti-Money Laundering and Countering the Financing of Terrorism Measures
As a holder of a Capital Markets Services licence issued by MAS, the Manager abides by the MAS’ guidelines on the
prevention of money laundering and countering the financing of terrorism. Under these guidelines, the main obligations
of the Manager are:
(a) evaluation of risk;
(b) customer due diligence;
(c) suspicious transaction reporting;
(d) record keeping;
(e) employee screening and representative screening; and
(f) training.
The Manager has developed and implemented a policy on the prevention of money laundering and terrorist financing
and is alert at all times to suspicious transactions. Where there is a suspicion of money laundering or terrorist financing,
the Manager performs due diligence checks on its counterparties in order to ensure that it does not enter into business
transactions with terrorist suspects or other high risk persons or entities. Suspicious transactions are also reported to
the Suspicious Transaction Reporting Office of the Commercial Affairs Department.
Under this policy, the Manager must retain all relevant records or documents relating to business relations with its
customers or transactions entered into for a period of at least five years following the termination of such business
relations or the completion of such transactions.
All prospective employees, officers and representatives of the Manager are also screened against various lists of terrorist
suspects issued by MAS. Periodic training is provided by the Manager to its Directors, employees and representatives
to ensure that they are updated and aware of applicable anti-money laundering and terrorist financing regulations,
the prevailing techniques and trends in money laundering and terrorist financing and the measures adopted by the
Manager to combat money laundering and terrorist financing.
Corporate
Governance