SUSTAINABILITY REPORT Cont’d Sponsorship, Donations and Political Contributions Press Metal is an apolitical public listed company and does not favour or promote the agenda of any political party, nor is the Group affiliated with any political organisation. Our approach to sponsorship, donations and contributions is clear and strict, with a zero-tolerance policy. All proposals for donations or sponsorships for such causes (e.g. corporate social responsibility, community building) must comply with the Group’s established criteria and must not be made with the intention of influencing business decisions or as compensation for improper payments or bribery. All sponsorships and donations must undergo approval by two (2) Executive Directors regardless of the amount. These contributions must be accurately recorded in the Group’s financial records, in compliance with applicable law, and be capable of being publicly disclosed. ZERO TOLERANCE POLICY Cascading the Anti-Corruption Agenda to the Supply Chain Press Metal continues to strengthen internal controls and procedures through continuous identification and monitoring of corruption risks exposure within our supply chain. Our ABAC Policy is extended to our third-party providers and expects strict internal controls and procedures in place, as outlined in the SCoC. We have implemented a multi-level approval process as check and balance system for internal control. For instance, financial transactions require three (3) levels of approval, including the job performer, checker, and approver. This approach provides assurance that all commercial decisions are made with utmost integrity and transparency, and potential corruption risks will be detected and addressed. Additionally, the Group has implemented additional measures such as providing relevant training to our employees to identify corruption practices and performing ABAC audits. Ethical Partnerships Press Metal has implemented the Mergers and Acquisitions Plan (“M&A Plan”) that sets out clear protocols and guidelines when engaging potential investee companies. Requirements such as adherence to relevant laws and regulations, and assessment of financial and non-financial risks including bribery, corruption, and other financial offences, affirm that our partnerships are built on shared values and objectives. As depicted in the M&A Plan, potential investee companies must undergo due diligence, including an ESG selfassessment questionnaire. The questionnaire, which was developed with reference to FTSE4Good criteria and GRI Standards, encompassed ESG indicators that assess non-financial performance in addition to background checks, a document verification process, and bribery risk assessment. Where necessary, we include contractual clauses that permit us to terminate any contract with business partners where bribery or corruption has been identified and not mitigated. Site Decommissioning Press Metal has established the Closure, Decommissioning and Divestment (“CDD”) Plan that depicts how unwanted facilities and infrastructure are decommissioned. As part of our commitment to responsible and sustainable business practices, we have developed this plan to inform interested parties such as government agencies and local communities. The CDD plan outlined the procedure that requires communication to the local government and surrounding communities when there is an intention for closure or decomissioning. Besides, this plan also sets out clear guidelines on how Press Metal will restore the area used for operations, roads, and infrastructure to usable land. The closure and decommissioning policies and procedures outlined in this plan apply to operations where Press Metal holds a controlling position. The divestment policies and procedures are not applicable to investments that we do not have management control nor the authority to make decisions. ANNUAL REPORT 2022 104
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