A. Purpose

Our ABC Policy is designed to ensure that GESB conducts all its business in an honest and ethical manner. GESB takes a zero-tolerance approach to bribery and corruption, and is committed to acting professionally, fairly, and with integrity in all its business dealings and relationships wherever it operates. GESB is also committed to implementing and enforcing effective systems and procedures to prevent, detect, and remediate bribery. 

All employees, customers, suppliers, and service providers of GESB must comply with this ABC Policy as well as GESB’s Entertainment and Gifts Policy.

Failure to adhere to this ABC Policy by employees and related procedures may result in disciplinary action being taken, up to and including dismissal where appropriate. GESB may also seek to terminate its commercial relationships with third parties who engage in bribery or corruption.

GESB prohibits the offering, giving, requesting, authorisation or acceptance of bribes.  Bribery in any form is prohibited regardless of whether it involves public officials or private persons.  GESB will at all times, comply with this ABC Policy and all relevant anti-bribery and corruption laws including the Singapore Prevention of Corruption Act, the UK Bribery Act, the US Foreign Corrupt Practices Act, the Australian Criminal Code Act (and equivalent state legislation), and other similar anti-bribery laws where it does business.

B. Bribery or Corruption

(i) For the purposes of this ABC Policy, a bribe means offering, giving, promising, or authorizing the payment of anything of value (including cash, gifts, entertainment, goods, services, or any other benefit) to any individual as an inducement or reward for obtaining any commercial, competitive contractual, regulatory or personal advantage or a transaction opportunity.  Anything of value excludes a discount to the counter party or a commission to the middleman of a transaction in the course of transactional activities, provided such activities are truthfully recorded in the payer’s and payee’s account books.

(ii) 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.

(iii) Facilitation payments are also strictly prohibited. These are routine payments made in some countries to government officials to expedite or secure routine governmental action.

C. Compliance

All employees of GESB and its respective board of directors, and all third parties who represent such companies, or who are its suppliers, contractors, service providers, customers or other business partners are required to comply with this ABC Policy and shall not engage in any form of bribery or corruption.

Employees of GESB must:

(a) Not give, offer to give or authorise to give anything of value that could be considered a bribe;

(b) Not request or accept or authorise the request or acceptance of, directly or indirectly, anything of value that could be considered to be a bribe;

(c) Engage in any corruption or fraud;

(d) Attempting to influence government officials or employees;

(e) Know what this ABC Policy means and comply with it;

(f) Report as soon as possible any suspected breaches of this ABC Policy to GESB.

A violation of this ABC Policy by:

(a) employees will lead to disciplinary action for the individuals involved up to and including dismissal, and reporting to the police or relevant regulatory authority;  

(b) any third party with which GESB contracts or otherwise has business dealings with, may lead to termination of any contractual arrangements.  

Additionally, GESB may also be exposed to criminal or civil claims and reputational harm arising from any such violation.

D. Gifts and Hospitality

Entertainment and hospitality are regarded as an acceptable form of business and social behaviour by GESB. Employees are required to comply with GESB’s Entertainment and Gifts Policy.

E. Investigations

GESB will investigate any reports made. The management of GESB will appoint an appropriately senior person or team to investigate the suspected bribery or corruption, who will report to senior local and Group management as appropriate. All reports will be confidential.