73 ANNUAL REPORT 2022 STRATEGY & OUTLOOK • Broadcasted ABAC Memorandum from Group CEO. • Conducted Group-wide ABAC awareness webinars. • Reviewed and revamped ABAC online training. • Conducted three ABMS internal audits. • ABAC due diligence completed for all business partners and international commercial representatives. • Enhanced functionality for online declaration of Gifts, Hospitality & Entertainment (“GHE”) on YNet. ABAC INITIATIVES IN FYE 2022 Code of Conduct & Business Ethics In line with our aim of fostering a culture of integrity across Yinson and our supply chain, we continue to implement Yinson’s COBE diligently. The COBE defines the foundation of our ethical standards and expectations for personal conduct. The COBE brings together Yinson’s main governance policies, including references to our other Group-wide policies. The COBE training is conducted annually for all new employees. Good corporate governance, pg 145 Compliance of our supply chain & third parties We spend considerable effort to engage with our supply chain and third parties to encourage a high standard of compliance. Yinson’s ISO 9001-qualified Vendor Registration Platform (“VRP”) was fully released in 2020, enhancing our capabilities relating to pre-qualification assurance and vendor performance. Vendors who are interested in working with us must provide their company information through the platform, which screens them by risk classification into ‘registered’ or ‘pre-qualified’ categories. The ‘registered’ vendors, who are categorised as lower risk, undergo a basic compliance checklist including acknowledgment of their adherence to Yinson’s COBE and ABAC policies. To be approved as a pre-qualified vendor with us, vendors go through a more comprehensive screening that considers information such as the vendor’s Health, Safety, Environment and Quality (“HSEQ”) management and performance, adverse media, watchlists, government records, sanctions, finance management, sustainability compliance, ABAC compliance, insurances and ISO certifications. Non-conformities found are documented in the VRP and followed up for resolution. A supplier’s risk assessment and categorisation is reviewed yearly in the VRP. 193 vendors were pre-qualified with Yinson in FYE 2022, with none flagged for social and environmental non-performance. In FYE 2022 and to date, we enhanced the VRP process as follows: • Released ESG module which consists of dedicated question sets, as well as benchmarking and reporting that aligns with global standards and methodologies, including GRI, ISO, CDP, TCFD, SDG, WEF and SASB standards. • Released country-specific forms to enhance regulatory data collection. • Released annual updates for suppliers. • Added questions on remote support. • Added clarifications within the Safety & Compliance and Finance question sets. • Adjusted trigger rules for insurance, ABAC and sustainability. • Added Yinson categories of supply. Yinson is in the progress of developing the ESG Supply Chain Policy that is expected to launch in 2022. The purpose is to outline our requirement to suppliers and contractors to integrate environmental considerations, social performance and governance into business towards creating a more sustainable supply chain. As part of the policy, suppliers and contractors are required to adopt Yinson’s health and safety guidelines to minimise incidents and injuries in workplace. The scope of social requirements such as diversity, equality, child and forced labour are also covered in the policy. Sustainable supply chain management, pg 157 Personal Data Protection Personal Data Protection has always been an important topic for Yinson as part of its overall corporate governance. With our growing presence in Brazil, as well as conversion works for our offshore production assets taking place in China, adapting our personal data compliance practises to manage the recent enactment of China’s PIPL and Brazil’s LGPD has been a primary focus for our privacy team in FYE 2022. In addition to maintaining our high standards of privacy compliance in our other operating countries, such as Malaysia, Singapore and Europe, the team is in the process of extensively reviewing issues in accordance to the PIPL and LGPD to ensure conformity. Yinson has empowered our Data Protection Officers (“DPOs”) and Deputy DPOs in our regional offices to communicate on Data Privacy awareness to the local employees. In addition, the DPOs have undertaken certified trainings to further enhance their knowledge on local Personal Data Privacy laws. The DPOs have conducted gap analysis with the support of local external legal counsel to identify areas of improvements on Personal Data Protection and Data Privacy. The DPOs are in the midst of implementing the proposed measures to close the gaps identified. CORPORATE COMPLIANCE REVIEW
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