Compliance Policies
Group Anti-bribery and Corruption Policy
Contents
- Policy Statement
1.1 Scope and Application
1.2 Consequences to Violations
- General Principles
- Facilitation Payments
- Gifts, Entertainment and Travel
- Contributions, Community Investment, and Sponsorship
5.1 Community Investment (CI) and Sponsorship
5.2 Political Contributions
- Counterparties
- Conflict of Interest
- Accounting and Record-keeping
- Training and Certification
- Monitoring
- Reporting of Suspected or Actual Bribery Concerns
- Inquiries
Appendix A
- Policy Statement
The Group Anti-bribery and Corruption Policy (“Policy”) sets out the guiding principles and standards that IPS Group Pte. Ltd. and its subsidiaries (“IPS Group”) are committed to, with regard to conducting business with integrity and the highest ethical standards. We adopt zero-tolerance towards all forms of bribery and corruption and uphold all laws applicable to bribery and corruption. This includes the US Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery Act 2010 (“UKBA”).
- Scope and Application
This Policy applies to all persons, including IPS Group’s Board of Directors and all employees (permanent, temporary, contract) working in IPS Group, including joint ventures and associates where IPS Group has management control.
Employees seconded to companies where IPS Group does not have management control are also expected to abide by this Policy. Joint ventures and associates for which IPS Group does not have management control are strongly encouraged to adopt this Policy or incorporate key elements of best practices in this Policy into their existing policy.
Any deviation from this Policy or subsequent changes must be approved by the Policy Owner.
- Consequences to Violations
A violation of this Policy or the Company’s Code of Conduct could result in disciplinary actions including termination of employment.
- General Principles
The Policy prohibits all forms of bribery including the offering, promising, authorising, providing or receiving anything of a value to or from any customer, business partner, vendor, government official or government entity or other third party in order to induce or reward the improper benefit or performance of an activity connected with a business. Personal funds should not be used to accomplish what is otherwise prohibited by this Policy.
- Facilitation Payments
The Company prohibits facilitation (or expediting) payments made for the purpose of expediting, facilitating or securing the performance or a service of a particular routine governmental action by a government official.
- Gifts, Entertainment and Travel
The Gifts, Entertainment and Travel Policy outlines the principles and guidance that should be followed when giving or accepting gifts, entertainment, travel or accommodation between IPS Group and persons acting on behalf of IPS Group to or from external parties.
Any giving or receiving of gifts, entertainment and travel must be given or accepted for a legitimate business purpose, reasonable, not too frequent, and free of any intent or understanding, express or implied, that any business decision will be influenced thereby, and must not create the appearance of any such intent or understanding.
Gifts or hospitality in the form of cash or cash equivalent are prohibited.
- Contributions, Community Investment, and Sponsorship
5.1 Community Investment (CI) and Sponsorship
All CI and sponsorship initiatives made must adhere to the following principles:
- CI or sponsorships should not be made directly to an individual including a government official or their personal bank account, and there should not be any indication that the CI or sponsorships will be redirected to the individual (including government officials) for personal use.
- CI or sponsorship donations to private charities or organisations should not be made in the name or in honour of an individual or government official or a related party.
- CI or sponsorships donations should not be made in exchange for a purchasing or other decision affecting Company interests.
- CI or sponsorships donations must be reported and documented accurately in the Company’s books and records.
5.2 Political Contributions
IPS Group is politically neutral, and no funds or non-monetary support can be made to any political party, politician, elected official or candidate for public office in any country or jurisdiction. For other bona fide and legitimate purposes, where local law permits, contributions may be made only with prior written approval as set out in our Group Community Investment and Sponsorships Policy.
- Counterparties
IPS Group employees who wish to do business with a counterparty or vice versa are responsible to ensure the identity and background of the counterparty are assessed and satisfactorily verified through our Know-your-counterparty (KYC) screening and due diligence process prior to contracting with the counterparty. This is to mitigate the risks associated with financial crimes which includes money laundering, terrorism financing, bribery and corruption and other illegal corruption schemes.
“Counterparty” refers to a legal entity or a person on the other part of a trade or financial transaction. This can include, but is not limited to joint venture partners, suppliers, customers, third party representatives or intermediaries, beneficiaries, third party payers and collateral providers.
Vendors or suppliers working for IPS Group are expected to adhere and comply with the IPS Group Supplier Code of Conduct and with this Group Anti-bribery and Corruption Policy.
- Conflict of Interest
IPS Group employees and contracted third parties are required to declare to the Company any conflict-of-interest situation and recuse themselves if requested by the Company.
All declarations will be reviewed by the IPS Group’s Group Ethics & Compliance committee to determine if a conflict of interest exists and advise the right course of action.
See Appendix A for Counterparty Conflict of Interest form.
- Accounting and Record-keeping
All financial transactions must be properly authorised and recorded. Benefits received, payments and other compensation made to vendors, customers and third parties should be approved in accordance with the Company’s authorisation matrix and accurately recorded in the Company’s corporate books, records, and accounts in a timely manner and in reasonable detail.
Proper reporting should include clear notation regarding the nature of each expense, identification of all recipients and / or participants, and the necessary approvals received for the expense.
False, misleading, incomplete, inaccurate, or artificial entries in the books, records, or accounts of the Company are a violation of this Policy and anti-bribery laws and are strictly prohibited as these can lead to consequences as stipulated in Section 1.2.
- Training and Certification
All IPS Group’s existing and new employees are mandated to complete the Code of Conduct and anti-bribery and corruption training yearly to ensure they are up to date on the requirements and obligations of the anti-bribery and corruption laws and this Policy. Post training, employees are required to declare that they have understood the content and meaning of the Code and undertake to comply with the Code and all its related policies and procedures. In addition, targeted training sessions are provided to employees who operate in higher risk areas of the businesses as well as those with significant compliance responsibilities.
- Monitoring
The Group Ethics and Compliance committee periodically monitors the effectiveness and implementation of this Policy through the review of the policy, risk, controls, systems, procedures, and the use of data analytics to determine any trends and anomalies that may require further action. The monitoring process and findings are reported periodically to the Board of Directors.
- Reporting of Suspected or Actual Bribery Concerns
All stakeholders including employees who observe or suspect any suspicious internal or third party who may be acting in contravention to this Policy, are encouraged to report it to either the Group Ethics and Compliance Committee at compliance@ips.com.sg or to IPS Group’s whistleblowing website at https://www.ips.com.sg/
All cases reported will be treated as confidential to the extent permitted by law, investigated with appropriate follow-up actions and in accordance with IPS Group’s Whistleblowing Policy. There will be no retaliation taken against anyone who reports a violation or suspected misconduct in good faith.
Any IPS Group employee who fails to report a violation of this Policy may be subject to a disciplinary action up to and including termination of employment.
- Inquiries
For any inquiries relating to IPS Group’s Group Anti-bribery and Corruption Policy, please email to IPS Group’s Group Ethics and Compliance committee at compliance@ips.com.sg
Note: This is an abridged version of the Group Anti-bribery and Corruption Policy. Employees should refer to the full version of this Policy available in the employee intranet.
Appendix A
Counterparty Conflict of Interest Declaration Form
Counterparties conducting business with IPS Group Industries, and its affiliated Companies must complete and submit the Conflict-of-Interest Declaration Form if there is a potential, perceived or actual conflict of interest.
Please submit a signed copy of this form to Group Ethics & Compliance (compliance@ips.com.sg). We will review, assess your declaration submitted and will advise for any mitigation actions to be taken. The relevant IPS Group personnel or department impacted will be contacted and informed. In other situation, IPS Group may contact you for further details were required.
Company Name (Full Legal Name):
Country of Incorporation:
Registered Address:
Contact (Email):
Contact (Phone):
To the best of my knowledge and belief,
- The owner, director, or senior management of my company / business (sole proprietor) or the company I work in, is currently an employee or a director of IPS Group or its subsidiaries?
☐ Yes ☐ No
If yes, please provide details in the table below.
- The owner, director or senior management of my company / business (sole proprietor) or the company I work in, has a ‘Closely Related Persons’ to an employee or a director of IPS Group or its subsidiaries?
☐ Yes ☐ No
If yes, please provide details in the table below.
‘Closely Related Persons’ is defined as the individual’s family members, including but not limited to those living in the same household as the individual. This can include but not be limited to spouse, parents, children and the spouses of the children, stepchildren and the spouses of the stepchildren, adopted children and the spouses of the adopted children, siblings and the spouses of such siblings, parents-in-law, grandparents, grandparents-in-law etc.
Name (Employee of your Company):
Position/Title in your Company:
Name (Employee of IPS Group):
Position/Title in IPS Group:
Relationship:
- Other Conflict of Interest
☐ Yes ☐ No
If yes, please provide details below.
Please describe the situation that has or may give rise to an actual, potential, or perceived conflict of interest.
By signing this document, the undersigned, being duly authorised to complete this declaration form, hereby certify the following:
- consent IPS Group to store, process and transfer the above information in accordance with applicable laws and regulations.
- acknowledge that IPS Group may seek to independently confirm the statements made in this document.
- represent that the facts and information provided in this document is, to the best of his/her knowledge is accurate, current and complete as of the date of disclosure.
- ensure the undersigned or personnel comply with the IPS Group’s Supplier Code of Conduct, when carrying out the obligations under the Contract with IPS Group. In particular, the Counterparty must immediately disclose to IPS Group any conflict or potential conflict of interest that arise and acknowledge the obligation to recuse and /or mitigate any actual, perceived or potential conflict of interest.
Anti Money Laundering Policy
Our Principle
We exercise due diligence in the selection of our business partners. We comply with anti- money laundering regulations.
Policy
IPS Group Pte. Ltd. and its subsidiaries (“IPS Group”) complies with anti-money laundering regulations in all countries where it operates.
Implementation
IPS Group shall implement a ‘know your business partner’ due diligence process to confirm the identity and legitimacy of all business partners. The extent of due diligence procedures may vary according to legal requirements and the risk profile of the transaction. At a minimum the business name, address and tax ID shall be confirmed.
IPS Group shall implement formal procedures to deal with unusual or suspect payment transactions. This includes procedures to block funds or return funds to the sending party. Cases of suspected money-laundering shall be escalated to the Group Ethics and Compliance committee and regulatory authorities will be notified if required.
Warning signs (red flags) for suspect transactions include
- payments to / from countries which are associated with money-laundering,
- payments to / from countries which differ from the registered office of the business partner (e.g., use of off-shore accounts),
- unusually complex transactions with split payments, involving different accounts in different currencies or jurisdictions,
- payments through intermediates, agents, advisors, or ‘nameless accounts’ which have no identifiable link to the customer,
- large payments in cash, cash equivalents, crypto-currencies or by money courier services,
- deficient or apparently false records to conceal the origin or destination of payments,
- over-payments with subsequent request to return or forward the money to a different account or different counter party, and
- financial transactions which are possibly linked to money laundering, criminal activities, drug trafficking or terrorism.
Record-keeping
IPS Group are required to maintain appropriate documents to support all payments.
Code of Conduct
Contents
Message From the Group CEO
Introduction
IPS Group’s Code of Conduct – Key Principles
- We Treat Each Other Fairly and With Respect
- We Protect Personal Information
- We Do Not Bribe
- We Deal With Government Officials Responsibly
- We Work With Trustworthy Business Partners and Representatives
- We Compete Ethically
- We Avoid Conflicts of Interest
- We Treat Gifts, Entertainment and Hospitality Responsibly
- We Safeguard Company Assets and Information
- We Work With Ethical Suppliers
- We Do Not Facilitate Money Laundering or Financial Crimes
- We Maintain Accurate Records, Contracts and Sound Internal Controls
- We Are Good Corporate Citizens
- We Are Politically Neutral
- We Manage Our Health, Safety, Security and Environmental (HSSE) Responsibilities as Our First Priority
Message From the Group CEO
At IPS Group Pte. Ltd. and its subsidiaries (“IPS Group”) we are committed to doing business and conducting our operations with integrity, honesty and in compliance with all applicable laws and regulations.
Acting with integrity means we must do the right thing at all times and when faced with any situation. Our Code of Conduct is designed as our guiding principles when we are faced with issues at work. All of us need to know, understand and apply all these non-negotiable standards in our daily work, regardless of our function or level in the Company.
When you need guidance or are faced with a difficult situation, you should speak up. Approach our colleagues at Group Ethics & Compliance, Group Human Resources or speak to your manager. I assure you that all communications raised in good faith will be treated confidentially and without retaliation.
Each of us has a role to play to bring this Code of Conduct to life. I thank you for your commitment to making IPS Group a responsible and sustainable Company for the future.
Peter Isaac Chan
Group CEO
IPS Group
Introduction
Here at IPS Group Pte. Ltd. and its subsidiaries (“IPS Group”), our directors and employees are committed to doing the right thing and carrying out their duties responsibly and with integrity, guided by the set of principles in this Code of Conduct (“Code”).
This Code sets out the standards and rules of conduct expected of our directors and employees. It also serves as a foundation for all other Company policies, procedures and guidelines.
This Code applies to all persons, including IPS Group’s Board of Directors and all employees (permanent, temporary, contract) working in IPS Group, including joint ventures and associates where IPS Group has management control.
Employees seconded to companies where IPS Group does not have management control are also expected to abide by this Code.
Joint ventures and associates for which IPS Group does not have management control are strongly encouraged to adopt this Code or incorporate key elements of best practices in this Code into their existing policy.
Any deviation from this Code or subsequent changes must be approved by the Policy Owner.
In addition to this Code, directors and employees are expected to comply with all laws, regulations, codes of practice, legal, regulatory and licensing requirements applicable to the different jurisdictions where we operate. Employees who violate the law, this Code or Company policy are subject to disciplinary action in accordance with local laws and Company policies.
If there are violations of this Code, the laws or Company policy, employees should not hesitate to raise concerns or seek guidance directly from a supervisor or from Group Ethics and Compliance.
Alternatively, employees may also reach out directly via IPS Group’s whistle-blowing platform:
Telephone: (65) 68631111
Email: compliance@ips.com.sg
Address: 71 Tech Park Crescent, Singapore 6380720
Whistle-blowing Website at https://www.ips.com.sg/
The Group Ethics and Compliance Committee reports directly to the Board of Directors.
We do not tolerate any form of retaliation against any employee who raises a concern in good faith, about a violation of the law, this Code or Company policy
IPS Group’s Code of Conduct – Key Principles
We Treat Each Other Fairly and With Respect.
IPS Group is committed to maintaining a work environment where all employees are treated with dignity and respect. We do not tolerate any form of discrimination or harassment of our employees. We hire and reward all employees on the basis of merit and believe in providing development opportunities for employees to achieve their full potential.
We Protect Personal Information
We respect the privacy of individuals by complying with the law and our data protection policy when collecting, using, protecting and retaining personal information of our employees, our clients and business partners.
We Do Not Bribe
We adopt a zero-tolerance approach towards all forms of bribery and corruption. We also prohibit any form of facilitation payments that may be characterised as a bribe. We do not authorise any third parties to engage in bribery on our behalf under any circumstances. Further information on our standards can be found in our Group Anti-bribery and Corruption Policy.
We Deal With Government Officials Responsibly
We are committed to meeting all legal, regulatory and contractual requirements that apply when we work or partner with governmental bodies or authorities around the world. These requirements may apply to bidding, accounting, invoicing, subcontracting, employment practices, contract performance, client service, gifts, hospitality, travel and other matters.
We Work With Trustworthy Business Partners and Representatives
We work with business partners and representatives who are committed to doing business ethically. We choose our partners and representatives carefully and conduct due diligence before entering into a business relationship, as their actions can reflect on our Company’s reputation.
We Compete Ethically
We compete for business ethically. We comply with all laws that protect competition and prohibit any forms of anti-competitive behaviour in the locations where we operate.
We Avoid Conflicts of Interest
We avoid any conflict that arises between our own interests and the interest of the Company. If a conflict of interest situation arises, we declare any conflict of interest situation to the Company, which could interfere with our professional duties, and recuse ourselves if requested by the Company.
We Treat Gifts, Entertainment and Hospitality Responsibly
We do not offer and receive gifts or hospitality if it creates the appearance of improper influence in affecting the outcome of a business transaction or dealing, if it is not reasonable and bona fide, or if it violates the laws or standards of our business partners.
Gifts or hospitality in the form of cash or cash equivalent are prohibited.
We Safeguard Company Assets and Information
We safeguard Company assets and use them responsibly. We are also committed to preserving confidentiality and are always mindful of how we collect, process, disclose and otherwise transmit information in our possession or control.
We Work With Ethical Suppliers
Our relationships with our suppliers are important to our success. We choose suppliers that share our commitment to ethical and sustainable business practices, provide superior service on fair and reasonable terms and that comply with the law.
We Do Not Facilitate Money Laundering or Financial Crimes
We are committed to complying with anti-money laundering and sanction laws. Money laundering is a conduct designed to conceal the origin or nature of the proceeds of criminal activity.
We Maintain Accurate Records, Contracts and Sound Internal Controls
We prepare and maintain fair, complete and accurate business records to fulfil our responsibilities to stakeholders in accordance with our system of internal controls. We prohibit any attempts to destroy, alter, misfile, hide, create false or misleading records or side agreements and other “off- the-book” arrangements.
We Are Good Corporate Citizens
We conduct our business responsibly and are committed to respecting human rights, managing the impact of our operations and supporting the communities we operate in to achieve long-term sustainable success. We demonstrate our commitment to corporate social responsibility (CSR), fostering environmental stewardship and improving the quality of life for the communities in which we operate through charitable contributions and community investments.
We Are Politically Neutral
We are politically neutral and we do not contribute funds or non-monetary support, including lobbying, to any political party, politician, elected official, or candidate for public office in any country or jurisdiction.
We Manage Our Health, Safety, Security and Environmental (HSSE) Responsibilities as Our First Priority
We are committed to maintaining a safe and healthy workplace for the benefit of all employees and visitors to our office premises and work sites. We proactively manage the HSSE risks associated with our activities. We operate our facilities and at working sites in a responsible manner, protecting the environment by reducing emissions to air, water and noise, producing less waste as well as promoting environmentally friendly waste management practices.
The Company may amend the Code from time to time.
DATA PROTECTION POLICY FOR EMPLOYEES
This Data Protection Policy (“Policy”) sets out the basis upon which IPS Group Pte Ltd & all affiliated group of companies (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
APPLICATION OF THIS POLICY
- This Policy applies to all persons engaged in a contract of service with us (whether on a part-time, temporary or full-time basis) and interns and trainees working at or attached to us (collectively referred to as “employees”), and all references to “employment” shall apply equally to internships and traineeships (as may be applicable).
PERSONAL DATA
- As used in this Policy, “personal data” means data, whether true or not, about an employee who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Personal data which we may collect in the context of your employment with us includes, without limitation, your:
- Name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
- Mailing address, telephone numbers, email address and other contact details;
- Employment and training history;
- Salary information and bank account details;
- Details of your next-of-kin, spouse and other family members;
- Work-related health issues and disabilities;
- Records on leave of absence from work;
- Photographs and other audio-visual information; and
- Performance assessments and disciplinary records.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally collect personal data that ;
(a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), after :
(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and ;
(ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or;
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
- performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
- all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
- managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
- assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;
- ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
- performing obligations under or in connection with the provision of our goods or services to our clients;
- facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
- facilitating our compliance with any laws, customs and regulations which may be applicable to us.
- The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
- After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
- In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of IPS Group Pte Ltd & all affiliated group of companies or another person. In relying on the legitimate interest’s exception of the PDPA, IPS Group Pte & all affiliated group of companies will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
- In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
- Detection and prevention of misuse of services;
- Network analysis to prevent fraud and financial crime, and perform credit analysis; and
- Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
- Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
- We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
- Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.
PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(OTP)/2 factor authentication (2FA)/multi-factor authentication (MFA) to secure access, and security review and testing performed regularly
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
- We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below (Item 22).
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected and are no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer (DPO) if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, in the following manner:
Name of DPO : Leong F. C.
Contact No. : 6643 0816 (8am-5pm)
Email Address : data.protection@ips.com.sg
Address : 71 tech Park Crescent, Singapore 638072
EFFECT OF POLICY AND CHANGES TO POLICY
- This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
- We may revise this Policy from time to time without any prior policy. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.
Effective date : 01/10/2024
Last updated : 01/10/2024
Fair Competition Policy
Our principle
We support free and fair competition.
Policy
IPS Group Pte. Ltd. & its subsidiaries (“IPS GROUP”) competes openly and fairly in the marketplace and complies fully with all relevant competition laws.
Implementation
IPS GROUP Personnel shall not propose or enter into agreements with competitors which restrict any aspect of their commercial activity. This includes, but is not limited to, any verbal or written agreement or implicit understanding regarding
- prices,
- discounts or rebates,
- costs, profits or profit margins,
- marketing and promotions,
- allocation of sales territories or customers,
- product or service offerings,
- production capacity and production plans,
- the distribution of products in markets,
- dictating resale prices to distributors,
- bidding processes or participation in tenders,
- research and development,
- conditions of sale or purchase, and
- limiting business with suppliers, customers or distributors.
Collection and use of market intelligence
IPS GROUP may obtain information about its markets, including its competitors, in the normal course of business. Market intelligence shall be obtained only from legally permitted sources and by legal means.
All business decisions shall be based on IPS GROUP’s own market evaluations and without coordination or collusion with competitors. This includes decisions on
- target markets and customers,
- products and service offerings,
- means of bringing these products and services to customers,
- pricing and terms and conditions of sale,
- participation in bidding processes, and
- mergers, acquisitions and divestments.
Collaboration with competitors
IPS GROUP may work with competitors on clearly defined projects (e.g., in consortia bidding for customer contracts). IPS GROUP may also collaborate with competitors, for example, in research and development, purchasing and marketing or development of technical norms and standards.
Before entering into such collaborations, legal advice shall be taken. All such collaborations shall be based on written agreements which set out the rights and obligations of each party and provide appropriate safeguards to comply with relevant competition laws
Participation and memberships of industry and business associations
IPS GROUP supports and is active in various industry associations and technical and professional organizations. IPS GROUP Personnel shall exercise due care that any contact with competitors in such organizations complies with competition laws.
International Trade Policy
Our principle
We comply with international trade regulations.
Policy
IPS Group Pte. Ltd. and its subsidiaries (“IPS Group”) complies with international trade regulations. This includes import and export regulations, export controls (sanctions), customs controls and duties, sales tax, transfer pricing and any other trade relevant regulations.
Definitions
Trade regulations apply to all cross-border transactions, as well as transactions between different customs zones within a country. Domestic transactions between a local entity and a foreign national may also fall under international trade regulations or sanctions.
Trade regulations apply broadly to all transfers of goods or services, including tangible and intangible goods, services, technology, know-how (e.g., drawings, designs, advice / consulting), software, digital services, financing, currencies (payments), etc.
Under international trade regulations, many countries also collect statistical information on international trade transactions.
Implementation
IPS GROUP companies shall correctly classify and declare goods and services in customs and shipping documents as well as statistical filings. This includes, but is not limited to, the correct statement of
- seller and buyer,
- product description,
- customs classification,
- origin,
- value,
- destination(s) and transport route, and
- end user / end use.
Export Control
IPS GROUP companies shall implement risk-based processes and controls to comply with export control regulations. Export control screenings include several tests and verification procedures:
- Screening against sanction lists: Sanction lists typically identify countries, organizations or persons subject to trade restrictions.
- Review of ownership: Organizations may be deemed sanctioned if they are directly or indirectly controlled by one or more sanctioned entities.
- Sectoral or industry sanctions: Trade with certain industries or economic sectors may be subject to specific regulations or restrictions.
- Dual use goods: A range of products is subject to special trade controls because they may also be used for military or police applications.
IPS GROUP companies shall implement formal procedures to deal with cases where the screening or evaluation processes identify facts or risks that export control regulations may be violated. This includes procedures to block, suspend and terminate a transaction.
Warning signs (red flags) for suspect trade transactions include
- screening software or ownership analysis identify a counter party as listed or blocked,
- customer is not familiar with the industry or products,
- order of unusual quantities or unusual product mix,
- refusal to provide end use or end user information,
- freight forwarder, shipping company, warehousing company or trading company as final destination,
- unusual packaging or marking requirements,
- unusual shipping routes,
- unclear or changing delivery address or delivery dates,
- unusual payment terms or payment methods,
- insistence on secrecy or unusual security and safety measures, and
- delivery destination in or close to areas of military conflicts.
Customs brokers, freight forwarders and transporters
For all export transactions, IPS GROUP companies shall only use professional / licensed customs brokers, freight forwarders and transporters. Contracts shall include appropriate compliance and due diligence obligations, for example anti-corruption and export control provisions.
Record-keeping
IPS GROUP companies shall maintain all documents pertaining to trade transactions in a systematic manner. Preferably, such documents shall be electronically archived along with the sales or purchase order, or invoice.
Supplier Code of Conduct
Contents
- Policy Statement
- Scope and Application
- Handling of non-compliance
- Reporting Concerns
- Our Expectations of Suppliers
5.1 Compliance with laws
5.2 Business Ethics
5.3 Labour and Human Rights
5.4 Health, Safety and Quality
5.5 Environment
- Acknowledgement
- Policy Statement
IPS Group Pte. Ltd. and its subsidiaries (“IPS Group”), we believe in building sustainable businesses that not only create economic value but do so in a way that benefits our stakeholders. We are committed to working with suppliers who share the same principles of sustainability and ethical behaviour as we do. We aim to collaborate with our suppliers to maintain a resilient and sustainable supply chain. Our Supplier Code of Conduct (“Code”) defines the minimum standards of practice we require from our suppliers, including subcontractors, to adhere to when providing any goods or services to IPS Group. We require all our suppliers to respect and comply with this Code when conducting business.
- Scope and Application
IPS Group will communicate this Code to current and new suppliers. Where further clarification is required, we will provide guidance on the provisions of this Code. Failure to respect and adhere to this Code shall directly impact the ability of suppliers to do business with IPS Group (see section titled “Handling of Non-compliance” for further information). We will monitor the implementation of this Code and the performance of our suppliers against its requirements. For example, suppliers may be required to complete a self assessment questionnaire, provide proof of statements made and demonstrate that this Code is adhered to. We also reserve the right to conduct supplier audits to verify compliance with this Code. In selecting suppliers, IPS Group will, in conjunction with selected evaluation criteria, expect all suppliers to show commitment to the principles contained within this Code. At appropriate intervals, we will review the applicability of this Code and make revisions when deemed necessary. Changes will be communicated to suppliers.
- Handling of Non-compliance
While we will endeavour to work with suppliers through remedial action wherever possible, IPS Group reserves the right to terminate a contract with any supplier who does not comply with the Code. Where we believe our standards are not being effectively applied, we also reserve the right to suspend that supplier’s contracts until satisfactory progress has been made or the issue has been resolved.
- Reporting Concerns
We want to hear from any individual or organisation who wishes to raise a query or concern or report a possible violation or breach to this Code. We expect suppliers to ensure that there will be no retaliation against any employees and subcontractors who make a report in good faith. Reports can be raised via the following channels: • Telephone: (65) 68631111 Email: compliance@lintec-linnhoff.com. Address: 71 Tech Park Crescent, Singapore 638072. IPS Group will conduct each case with impartiality, fairness and confidentiality. Each report will be considered seriously and will undergo an investigation. We expect full supplier cooperation with any such investigation. We will clarify the alleged violations against a supplier within a stipulated period of time and take appropriate remedial action for proven violations.
- Our Expectations of Suppliers
- Compliance with laws
Suppliers must comply with local laws in the countries where they operate. Where the provision of the law and this Code address the same topic, suppliers are encouraged to follow the requirements that promote higher standards. If a supplier has any concerns regarding the application of this Code in light of local laws, we expect them to inform compliance@ipsgroup.com. We are committed to working with all our suppliers to implement the highest standards wherever possible.
- Business Ethics
IPS Group expects its suppliers to abide by the following:
Anti-bribery and corruption
Suppliers must ensure they do not engage in any form of corruption, bribery, facilitation payments or fraud. Suppliers shall not offer any gifts or other benefits to IPS Group employees, and / or anyone acting on IPS Group’s behalf that could improperly influence that employee or person. IPS Group also prohibits anyone from engaging in bribery and corruption on our behalf. We expect our Suppliers to adhere to our Group Anti-bribery and Corruption Policy.
Fair competition
Suppliers must compete fairly and in accordance with all applicable competition laws.
Private and intellectual property
In conducting all activities, suppliers are expected to make appropriate use of personal data and confidential information, and ensure that all intellectual property rights are respected.
Conflict of interest
Suppliers must avoid situations where a conflict of interest may occur. They must immediately disclose to IPS Group any conflict of interest that does arise or in exceptional circumstances, disclose the previously agreed procedure for dealing with any conflict of interest. Such conflicts of interest could include cases where a supplier’s employee or professional under contract may have an interest or business relationship of any kind with IPS Group’s business or where that supplier may be acting on behalf of IPS Group and / or a competitor of IPS Group.
- Labour and Human Rights
IPS Group supports the Universal Declaration of Human Rights and its implementation through the United Nations (UN) Guiding Principles on Business and Human Rights. As such, and in accordance with our Human Rights Policy, we expect suppliers to respect all human rights, including labour rights, throughout their business activities.
Equality and no discrimination
Suppliers are required to promote a fair and equitable work environment that is free from discrimination and harassment for all employees. This shall extend to ensuring terms of employment and its employment practices do not discriminate upon grounds of gender, race, and / or any other characteristic protected by applicable local law.
Modern slavery
Suppliers must prevent all forms of modern slavery from taking place in their operations, including forced and compulsory labour, bonded labour, and human trafficking.
Child labour
Suppliers must ensure their operations are free from the exploitation of child labour. Child labour, as defined by the International Labour Organization (ILO), refers to work that is mentally, physically, socially or morally harmful to children; or work that interferes with their schooling.
Freedom of association and collective bargaining
Suppliers must respect the right of employees to join trade unions, and associations and assemble freely without fear of reprisal, intimidation or harassment.
Rights of local communities
Suppliers must respect the land, resource and cultural rights of local communities and indigenous groups.
- Health, Safety and Quality
Suppliers are required to prevent and manage health and safety risks associated with their activities, products and services, in line with our Health, Safety, Security and Environment Policy.
Workplace health and safety
Suppliers are required to implement effective health and safety prevention and remediation policies and procedures which comply with industry, national and international standards as well as IPS Group’s health and safety requirements. This also includes taking reasonable care to ensure all workers are protected against processes, substances and work methods which are unsafe.
Work environment and housing facilities
Suppliers must provide a safe, clean, comfortable and hygienic working environment and, if applicable, residential or overnight facilities that meet the basic needs of the workers.
Product safety and quality
Suppliers are required to deliver products and services that meet the needs of IPS Group and that are in line with recognised and contractually agreed safety and quality requirements as well as (as a minimum) comply with the local laws in the country in which they are provided to IPS Group (see further the section titled “Compliance with laws” above).
- Environment
We expect all suppliers in all their operations, products and services to minimise their impact on the environment, in line with our Group Environmental Policy and Group Health, Safety, Security and Environment Policy.
Resource consumption, pollution prevention and climate change mitigation
Suppliers must show that they are managing, measuring and minimising the environmental impact of their operations including reductions on emissions (including greenhouse gas emissions), waste, energy and water consumption.
Environmental standards and regulations
Suppliers are required to ensure that they comply with all our corporate and site-specific environmental standards when conducting work on IPS Group sites.
- Acknowledgement
Acknowledgement of the Code is a prerequisite in every IPS Group contract for supply. Through the signature of the contract and acceptance of the purchase order, the supplier confirms that its operations fulfil the requirements contained in this Code and it shall be deemed incorporated and form a part of any contract or relevant order with IPS Group.
Whistleblowing Policy
- Policy Statement
IPS Group Pte. Ltd. and its subsidiaries (“IPS Group”) are committed to maintain a high standard of transparency, accountability and integrity in our business conduct.
This Whistleblowing Policy (“this Policy”) aims to:
- provide a safe and reliable avenue for persons to report any wrongdoings including actual or suspected fraud or violation of IPS Group’s Code of Conduct or any applicable law or company policy (a “reportable concern”) without fear of reprisals when whistleblowing is done in good faith; and,
- ensure that arrangements are in place to facilitate independent, fair and robust investigation of the reported concern and for appropriate follow up actions to be taken.
The Group Ethics & Compliance committee oversees the effective implementation of this Whistleblowing Policy. The committee provides guidance and high-level oversight on high priority investigations and reports its findings directly to the Board of Directors.
- Scope and Application
This Policy applies to all persons, including IPS Group’s Board of Directors and all employees (permanent, temporary, contract) working in IPS Group, including joint ventures and associates where IPS Group has management control. Employees seconded to companies where IPS Group does not have management control are also expected to abide by this Policy.
Joint ventures and associates for which IPS Group does not have management control are strongly encouraged to adopt this Policy or incorporate key elements of best practices in this Policy into their existing policy.
Any deviation from this Policy or subsequent changes must be approved by the Policy Owner.
- Reportable Concern
Employees and external parties are encouraged to come forward to report any actual or suspected fraud or wrongdoings (“reportable concern”) listed below as soon as he/she becomes aware of it.
- Fraud or theft
- Bribery and corruption
- Fraudulent accounting practices
- Conflict of interest violation
- Non-compliances with laws and regulations
- Non-compliances with company policies & procedures, including Code of Conduct
- Unethical or improper conduct, including discrimination / harassment
- Health, safety, security and environmental matters
Other reports that are not within the ambit of this Policy, such as service complaints, operational matters and staff grievances should be made to the relevant Market Departments or Group Human Resource for follow-up actions.
- Whistleblowing Channels
All persons can report or redirect reportable concerns via the following channels:
- Email: compliance@ips.com.sg
- Call: (65) 68631111
- Website: To be advised
- Address: 71 Tech Park Crescent, Singapore 638072
The type of information required when reporting a reportable concern include:
- Your name and contact details
- Your relationship with IPS Group
- Names of the people / organisations involved and their relationship with IPS Group
- The details of the incident (what happened, where, when and how often did it occur)
- Whether management has been notified (if so, whom)
- How you got to know of the incident
- Provide supporting evidence to substantiate the allegations
- Confidentiality and Non-retaliation
IPS Group is committed to use reasonable endeavours, within the limits of applicable laws and regulations, to protect the identity of the Whistleblower, and all persons involved in the investigations of potential fraud or misconduct. The identity of the Whistleblower will be disclosed on a need-to-know basis to Group Ethics & Compliance committee, or as required under any applicable law.
Whistleblowers are encouraged to provide their names and contact details in confidence, rather than anonymously. However, should the Whistleblower choose to remain anonymous, the committee’s investigation process and ability to address the concerns may be hindered if he / she cannot be contacted for clarification.
IPS Group does not tolerate the harassment or victimisation of a Whistleblower who reports a concern in good faith. If it is determined that a Whistleblower was subject to retaliatory actions because of his / her report, appropriate remedial actions will be taken by the Group Ethics & Compliance committee under the Board of Director’s directives.
- Frivolous and Malicious Whistleblowing
IPS Group treats all reported concerns, including anonymous reports, seriously. IPS Group strives to handle each report with impartiality, fairness and confidentiality. As such, IPS Group does not tolerate the misuse of whistleblowing channels for personal gains nor condone frivolous and/or malicious whistleblowing.
If the results of the investigation show that the Whistleblower acted maliciously in reporting his / her concern, appropriate actions will be taken, including disciplinary action up to and including termination of employment.
Examples of frivolous and malicious whistleblowing includes, but is not limited to:
- having no reasonable grounds to believe that the information he / she provided was true and accurate; or
- knowingly spreading false information with the intent to damage another party’s reputation or cause distress to that party.
- Communication of this Policy
This Policy shall be communicated to external parties via the corporate website, and IPS Group’s employees via onboarding and refresher trainings and as and when requested by the Group Ethics & Compliance committee or Board of Directors.