Anti-Bribery and Anti-Corruption Policy

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY 

1.0       OBJECTIVE

1.1. To provide all employees of Tat Seng Packaging Group Ltd (the “Company”) and its subsidiaries (together referred to as the “Group”) with a framework of principles to comply with in compliance with The Prevention of Corruption Act;

1.2. The Company adopts a “zero tolerance” approach against all forms of bribery and corruption as set out in this Anti-Bribery and Corruption Policy (“Policy”), which applies to the Group.

2.0       SCOPE 

2.1. This Policy applies to all employees and the board of directors;

2.2. This Policy also extends to “third party” of whom include actual or potential customers or clients, suppliers, contractors, government bodies and any individual or organisation.

3.0      DEFINITION

3.1. A bribe or corrupt action includes the receiving, offering, promising, authorising or providing “anything of value” (whether by doing something or not doing something) to any customer, supplier or other third party in order to secure, induce or keep an improper or unfair advantage;

3.2. Anything of value is not only cash, it includes (but not limited to) cash equivalents like gifts, services, employment offers, loans, travel and entertainment, charitable donations, sponsorships, business opportunities, favourable contracts, personal favours, or giving anything even if nominal in value;

3.3. There is a presumption of corrupt intent if anything of value is given to employees of, or persons dealing with the Singapore government, under Singapore laws.

4.0      COMPLIANCE

4.1. Employees and the board of directors must:

  • not give or offer to give or authorise, aid or abet the giving of, direct or indirectly, anything of value that could be considered to be a bribe;
  • not request or accept or authorise, aid or abet the request of acceptance of, directly or indirectly, anything of value that could be considered to be a bribe;
  • ensure contracts with third parties include anti-bribery and corruption clauses and the right to immediately terminate contracts where there are violations of such clauses by any third party.
  • perform proper due diligence on third parties prior to any dealings, engagement or appointment in accordance with the Group’s due diligence procedures to ensure business is done with reputable, honest and qualified third parties;
  • ensure that they read, understand and comply with this Policy as well as any future updates and other materials issued from time to time as part of the Company’s efforts to educate, address and prevent corruption;
  • avoid any activity that might lead to, or suggest, a breach of this Policy;
  • report as soon as possible any suspected breaches of this Policy to their immediate supervisor(s) or otherwise lodge a report (which may be anonymous) to the Chairman of the Audit and Risk Committee in accordance with the Company’s whistleblowing policy, Clause 7. Reporting Mechanism, which is available on the Company’s website (www. tspg.sg).

5.0      CONSEQUENCES OF VIOLATION

5.1. Apart from potential criminal and civil liabilities involving imprisonment and/or a fine, individuals who are found to be in violation of this Policy shall be subject to appropriate disciplinary action, which may extend to immediate termination of employment or appointment. A violation of this Policy will lead to disciplinary action for the individuals involved up to and including dismissal, and reporting to the policy or relevant regulatory agency;

5.2. Disciplinary action will also be taken against individuals who have knowledge of such violations but conceal such information from the Group, or who take detrimental action against others who report such violations.

6.0      MONITOR AND REVIEW

6.1. This Policy will be regularly reviewed and updated as needed to ensure it continues to be adequate and effective.