Anti-Bribery & Corruption

  1. INTRODUCTION

    1. Boustead Projects Limited and its subsidiaries and associated companies (“BP Group”) observes and encourages its employees to meet the highest standards of ethical conduct. Each employee is required to act fairly, honestly and in accordance with all laws, contractual obligations and BP Group policies, at all times.

    2. The BP Group has a zero tolerance policy against fraud, corruption or unlawful behaviour. To assist in the early detection of misconduct that may have a harmful effect to the reputation and business of the BP Group, the Anti-Bribery and Corruption Policy and Whistleblowing Policy have been established[1] with the approval of the Audit & Risk Committee to outline the options for whistle-blowing, the procedure for investigation of whistle-blower complaints, and protection of whistle-blowers from reprisal.

      1. Anti-Bribery and Corruption Policy

        The BP Group has implemented an Anti-Bribery and Corruption Policy which is approved by the board of Boustead Projects Limited, and reviewed on a regular basis. The latest version of the BP Group’s Anti-Bribery and Corruption Policy may be accessed here.


      2. Whistleblowing Policy

        The BP Group has also implemented a Whistleblowing Policy which is established to give BP Group employees the assurance that they will be protected from reprisal or victimization for whistleblowing in good faith, and to provide proper avenues for employees to raise concerns about actual or suspected improprieties, so as to deter wrongdoing and promote good corporate practices. The avenues of reporting are identified on the BP Group’s website and are available to both BP Group employees and third parties outside the BP Group, such as suppliers, sub-contractors, clients and members of the public.


    3. Some examples of reportable incidents are:

      1. Concerns about the BP Group’s accounting, internal controls or auditing matters;

      2. Breach of or failure to implement or comply with significant obligations in the BP Group’s policies or code of conduct;

      3. Impropriety, corruption, acts of fraud, theft and/or misuse of the BP Group’s property, assets or resources;
      4. Commission of a criminal offence or breach of law;

      5. Abuse of power or authority;

      6. Serious conflict of interest without disclosure;

      7. Intentional provision of incorrect information to public bodies;

      8. Fraud against investors, or the making of fraudulent statements to the Singapore Exchange Securities Trading Limited, members of the investing public and regulatory authorities;

      9. Acts to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of the BP Group;

      10. Concealing information about any malpractice or misconduct;

      11. Any other serious improper matters which may cause financial or non-financial loss to the BP Group, or damage to the BP Group’s reputation.

  2. HOW TO REPORT

    The Whistleblowing Committee of the BP Group reviews all whistleblowing reports and updates the Audit & Risk Committee of all whistleblowing reports received.

    Any concern regarding improper, unethical or unlawful conduct may be reported to the Whistleblowing Committee via the following channels:


    E-mail whistleblowing@boustead.sg
    Mail The report should be addressed to the Chairman, Audit & Risk Committee at the address below:

    Boustead Projects Limited
    82 Ubi Avenue 4
    #07-01 Edward Boustead Centre
    Singapore 408832
    The report should be submitted with the following particulars:
    Incident Reporting
    1. Name of Whistleblower (unless anonymous)
    2. Date and Time of Incident
    3. Place of Incident
    4. Parties Involved in Incident
    5. Nature of Report
    6. Possible Evidence
    Raising of Suspicion
    1. Name of Whistleblower (unless anonymous)
    2. Nature of Suspicion
    3. Basis of Suspicion
    4. Possible Evidence
  3. HANDLING OF REPORTS

    Reports will be forwarded to the members of the Whistleblowing Committee, which consist of (1) a member of the Audit & Risk Committee, (2) Deputy Director, Human Resources and (3) Senior Vice President, Internal Audit.

    All reports (including the whistleblower’s identity) will be kept confidential. The BP Group will not disclose information provided by the whistleblower unless the BP Group is compelled to disclose the information due to a legal obligation or to seek legal or audit advice, for example, if the information is requested for a criminal investigation. Where possible, the BP Group will first contact the whistleblower before disclosing the whistleblower’s identity.


  4. WHISTLEBLOWER PROTECTION

    The BP Group does not condone any retributive action taken against employees who raise concerns through any of the avenues of reporting. Employees who make use of the avenues of reporting to raise concerns in good faith, will have their identities kept confidential, and will not be subject to dismissal even if they were mistaken. They will also be protected against reprisal in other forms, such as harassment.

    However, these protections will not be given to anyone misusing the avenues of reporting to make a frivolous, mischievous or malicious allegation.



1The BP Group has established internal policies and procedures available to BP Group employees, which, where internally distributed, contains detailed procedures for matters including the receipt, reporting and investigation of whistle-blowing complaints, such as access to reports, retention of records, management of the alleged subject of whistle-blowing and disclosure of investigation records.