Confidential
CODE OF ETHICS FOR EMPLOYEES OF ONE MARINA PROPERTY SERVICES PTE LTD (ONE MARINA, HEREINBELOW ALSO REFERS TO “Company”)
1.INTRODUCTION
1.1The Code of Ethics defines broadly the standards of integrity that all employees have to abide by when conducting business or interacting with external parties and performing work responsibilities, regardless of their positions in One Marina. Essentially, the desired behaviour is one that is ethical, legal, socially responsible and in accordance with the established policies of One Marina. The Code applies to all employees of One Marina, including all part-time employees and contract employees.
1.2The general principles underlying the Code are:
i) Conduct business with honesty and integrity;
ii) Comply strictly with the laws; and
iii) Exercise good judgment by doing things right and acting ethically when the law is not specific.
1.3The One Marina’Management will regularly review the Code to ensure its continued relevance to the Company.
1.4For purposes of reporting any known or suspected wrongdoing, an employee can refer to the whistleblowing policy and report to one or more of the following parties in One Marina or the person, listed as follows:
i) Head of Department, Human Resource; or
ii)Internal Auditor; or
iii)Chairman of the Audit Committee / Chairman of the Board c/owhistleblowing hotline
2.COMPLIANCE WITH RELEVANT LAWS AND REGULATIONS
2.1The Company and its employees must, at all times, comply with all laws and regulations applicable to the Company’s business activities. The Company will not condone the activities of any employee who achieves results through violation of the law or unethical business dealings. These include any payments for illegal acts, indirect contributions, kickbacks, and bribery. The Company does not permit any activity that fails to stand public scrutiny.
2.2Employees uncertain about the application or interpretation of any legal requirement should refer the matter to the Head of Department, who, if necessary, should seek legal advice.
3.GENERAL EMPLOYEE CONDUCT
3.1All employees are expected to perform their duties conscientiously, honestly, and in accordance with the best interests of the Company.
3.2Employees are to conduct themselves in a professional manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job.
3.3All employees have a duty to uphold the reputation and standing of the Company. They should not be involved in any act which disparages any part of the Company.
- WORKPLACE HEALTH AND SAFETY
4.1Employees 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.
5. CONFLICT OF INTERESTS
5.1Employees must not use their position or the knowledge gained as a result of their position for private or personal advantage. If any employee senses that a course of action he or she has pursued, is presently pursuing, or is contemplating pursuing may involve him or her in a conflict of interest with his or her employer, he or she should immediately communicate all the facts to the One MarinaHRHead.
5.2 A conflict of interest arises when an employee’s personal interest or official capacity in other Company interferes with his or her ability to exercise independent and objective judgment or to carry out his or her duties at work in the best interests of the Company.
5.3 Some examples of potential conflict of interest include, but are not limited to, the following:
i)Contracting with a vendor managed by a relative or friend without going through the normal procedures of obtaining quotations;
ii)Working independently as a consultant to a vendor or customer without declaring his or her interest and obtaining permission to do so;
iii) Engaging in any trade or business privately if the work performed therein is similar to that performed at the Company or which the Company may be interested in performing.
5.4Every employee is required to declare his or her interest or relationship which may conflict with the interests of the Company as soon as possible. The employee shall abstain from decision-making in situations where there is possible conflict of interest.
6.OUTSIDE ACTIVITIES, EMPLOYMENT, AND DIRECTORSHIPS
6.1Unless specifically approved by One Marina CEO, employees must not acquire any business interest or participate in any other activity outside the Company that would, or would appear to:
(a)Create an excessive demand upon their time and attention, thus depriving the Company of their best effort on the job.
(b)Create a conflict of interest – an obligation, interest or distraction – that may interfere with the independent exercise of judgment in the Company’s best interest.
7. RELATIONSHIPS WITH CLIENTS AND SUPPLIERS
7.1 Without permission from the One Marina HR Head, employees should avoid investing in or acquiring a financial interest for their own accounts in any business Company that has a contractual relationship with the Company, or that provides goods or services, or both to the Company, if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of the Company.
8. GIFTS, ENTERTAINMENT AND FAVOURS
8.1 All employees should not accept entertainment, gifts, or personal favours that could, in any way, influence, or appear to influence, business decisions in favour of any person or Company with whom or with which the Company has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their position with the Company might be inclined to, or be perceived to, place them under obligation. However, employees may accept a gift of nominal value or advertising novelty, when it is customarily offered to others having a similar relationship with the person/ Company. If employees have any doubts about a particular situation, he/ she should consult his/ her Head of Department.
8.2 All gifts of more than nominal value or which is not customarily offered to others, if accepted out of goodwill and business relationship reasons, or if delivered to the employee’s home/ office, must be declared immediately to the Head of HR Department. Appropriate arrangements will be made to return or dispose of what has been received, and the person/ Company gifting will be reminded of the Company’s policy with respect to gifts.
9KICKBACKS AND SECRET COMMISSIONS
9.1 Regarding the Company’s business activities, employees must not receive payment or compensation of any kind, except as authorized under the Company’s remuneration policies. In particular, the Company strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law.
10. COMPANY’S FUNDS AND OTHER ASSETS
10.1 All employees who have access to Company’s funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in the Company’s instructional manuals or other explanatory material, or both. The Company imposes strict standards to prevent fraud and dishonesty. If any employee becomes aware of any evidence of fraud and dishonesty, he or she should immediately advise one or more of the parties listed in Para 1.4 above so that the Company can promptly investigate further.
10.2 When an employee’s position requires spending Company’s funds or incurring any reimbursable personal expenses, that individual must use good judgment on the Company’s behalf to ensure that good value is received for every expenditure.
10.3 The Company’s funds and all its other assets are for the Company’s purposes only and not for personal benefit.
11. COMPANY’S RECORDS AND COMMUNICATIONS
11.1 Accurate and reliable records of many kinds are necessary to meet the Company’s legal and financial obligations and to manage the affairs of the Company. The Company’s books and records must reflect all business transactions in an accurate and timely manner. All employees responsible for accounting and record keeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements. All employees are expected to cooperate fully with the Company’s internal and external auditors during their work.
11.2 All employees must not make or engage false record or communication of any kind, whether internal or external, including but not limited to:
(a) False expense, attendance, production, financial, or similar reports and statements;
(b) False advertising, deceptive marketing practices, or other misleading representations.
12. PRIVACY AND CONFIDENTIALITY
12.1 When handling financial and personal information about customers or others with whom the Company has dealings, all employees must observe the following principles:
(a) Collect, use, and retain only the personal information necessary for the Company’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
(b) Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
(c) Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.
13.INTELLECTUAL PROPERTY RIGHTS
13.1Employees shall make full and complete disclosure in respect of all works (including but not limited to hardware, software, processes, inventions, systems, apparatus, products, artworks and designs) to the Company and shall, if and when required by the Company, join with the Company in making any applications required to protect such works. Employees are obliged to keep such information confidential and shall not disclose the information unless and until the Company releases him/ her from these obligations in writing.
14.INFORMATION TECHNOLOGY
14.1All employees are to take proper care of their computer and data residing in it. They should only use them for appropriate purposes. Employees should not install illegal or unauthorized software in their computers, and should not use the Company’s connections to the Internet to access inappropriate sites, e.g. pornographic websites.
14.2Employees should only use the Company’s e-mail system and internet services for official purposes only.
15.LEGAL PROCEEDINGS
15.1An employee shall immediately inform his or her Head of Department, giving details, of any pending civil or criminal action, law suit, court proceedings, police investigation or any other equitable charges that may be brought against him/ her that would seriously impair the Company’s reputation or his/ her employment with the Company. The Head of Department shall promptly notify the One MarinaHR Headof such action or proceeding and wherever necessary, implement any measures, interim or otherwise, to address the effect that such action or proceeding may have on the employee and the Company.
16DISCRIMINATION AND HARRASSMENT
16.1Any discrimination based on gender, age, race, religion, marital or family status, political beliefs, sexual orientation, disability or nationality is not acceptable.
16.2Any conduct of a sexual nature which would create an intimidating, hostile, or offensive working environment would be deemed to be sexual harassment. Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such
16.3Any intimidation, coercion and threats, bullying or actions leading to bodily and/or mental harm are unacceptable at all times.
17DEALING WITH MEDIA
17.1All staff shall observe proper decorum in their communication to the external public at large and to all forms of media. At no time shall the staff cause disrepute or damage to the Company’s interest,image and credibility.
17.2All media requests for information and interviews should be referred to the Head of Business Cluster.
17.3Statements made in any online forum (eg web blogs) or social networking sites (egFacebook) are considered to be public statements. No comments regarding the Company should be made without prior approval from Head of Business Cluster.
18Any doubt or question under this Code should be raised with the One Marina HR Head. Failure to comply with the Code may result in disciplinary action up to and including termination.
Acknowledgement
I, ______, NRIC/Passport No. ______,
have read and understood the content of this Code of Ethics and agree to abide by it.
______
SignatureName/Date
Initial :PM-HRM-03/F07/R02
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