confidentiality, insubordination, inefficiency, publications, conflict of interest, harassment and disciplinary action, amongst others. The Code also details the circumstances under which employees would be deemed to have breached standards and the actions that can be taken against them in such an event. Supplementing the Code, we mandate the carrying out of due diligence exercises covering practices related to employee recruitment and dealings with external parties such as vendors, agents, customers, business partners and public officials. With these guidelines in place, we are positioned to maintain our standards and performance even as our geographical and sectoral presence expands. For more detailed information on the internal controls we have implemented to strengthen our stance on business ethics, please refer to Statement on Risk Management and Internal Control on page 167. Encouraging Reporting of Unethical Behaviour Our Whistleblowing Framework and Policy is a structured mechanism that all employees and external parties may use to report suspected or known instances of misconduct – including corruption, bribery, fraud and misuse of company resources. The mechanism guarantees that all reports received will be dealt with confidentially and that the whistleblower will be protected from any reprisals, creating an open environment where employees and stakeholders feel supported in raising concerns relating to business ethics and conduct. Incidents of Corruption and Actions Taken During the year under review, no operations were assessed for corruption-related risks and there were no confirmed incidents of corruption and action taken. Anti-Corruption Training In the year under review, our employees received training on our anti-corruption and anti-bribery standards. This training was provided to 100% of our Top and Senior Management, 45% of our Middle Management, 43% of Professional (Executive) staff and 11% of Non-Executive/Support staff. Anti-Competitive Behaviour In the year under review, we received zero legal notices and were involved in zero legal actions relating to anti-competitive behaviour or violations of anti-trust or monopoly laws. DATA PRIVACY & SECURITY Why It Matters We operate in an increasingly complex threat landscape, with sophisticated cybercriminals continuously devising new ways to penetrate corporate IT systems and databases. As such, any breach of our cyber defences could lead to significant operational disruptions, financial losses and impacts to our reputation amongst key stakeholder groups, in addition to legal and regulatory action. This is particularly the case for our IT division, which handles large volumes of trade data on a daily basis. Our Approach Our products, services and processes are increasingly digitallybased, meaning that we store large amounts of customer data including personally identifiable information (“PII”). To safeguard the trust of our customers, our Data Privacy Policy details clear practices that we adhere to in protecting all personal data under our possession. The policy is in line with the Personal Data Protection Act (“PDPA”) 2010 and mandates that we respect our customers’ preferences regarding the use of their data and seek permission before carrying out any actions involving their data. Data privacy is also of concern in our business relationships. As such, we sign non-disclosure agreements whenever undertaking business transactions involving the exchange of sensitive business data, providing assurance to our business partners that their proprietary data and intellectual property will be safeguarded. Complaints Concerning Data Privacy and Losses of Customer Data In FY2023, there were zero incidents – and zero complaints – concerning breaches of customer privacy or data misuse, including breaches relating to PDPA 2010. 137 Integrated Report 2023
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