A. Purpose

GESB is committed to conducting business ethically and lawfully. All service providers, customers and suppliers must comply with the terms of this policy in relation to their respective activities and dealings with GESB.

B. Scope

Customers, suppliers and service providers shall take all measures to prevent corrupt practices in its dealings with GESB.

C. General principles

(i) No customer, supplier or service provider should accept or offer entertainment or gifts that could or appear capable of, influencing business decisions, inducing any director, employee or representative to perform their functions improperly, or influencing public officials with respect to a matter granting business or an advantage in the conduct of GESB’s business.

(ii) All entertainment and gifts must be reasonable and proportionate at levels in terms of both frequency and value.

(iii) GESB acknowledges that entertainment and gifts are customary in its sectors and these are permissible if they are:

(a) Business-related: entertainment may be offered or received only when the event has a primarily business purpose, when the parties engage in business discussions, and when the giver is present at the event.

(b) Reasonable, proportionate and appropriate: entertainment and gifts are gestures of courtesy and should not be of disproportionate value in the circumstances, or inappropriate in nature.

(c) Occasional: business entertainment should not be received from, or offered to, the same organisation on a regular basis which could give rise to an actual or perceived cumulative effect of inducing the recipient to act improperly, or of influencing a public official recipient with respect to a matter granting business or an advantage in the conduct of the company’s business.

(d) In kind only: cash should not be offered or received at any time.

(e) Approved and registered: a Line Manager must provide a written approval for the receipt or offer of entertainment and gifts and evidence of this should be retained and readily available.

(iv) Customers, suppliers and service providers shall not:

(a) offer or provide, directly or through any intermediaries, any bribe, gift, reward, consideration, favour or any other advantage, whether material or immaterial (Advantages) to any representative of GESB for the purpose of:

(1) influencing them to act contrary to the interest of GESB; or

(2) obtaining or rewarding favourable treatment by GESB with respect to the terms, conditions, price or performance of a contract;

(b) offer or provide Advantages which might be considered a bribe under international legislation, to a government official, either in Singapore or any other country;

(c) collude with other parties to preclude or compromise dealings with GESB. The customers, service providers and suppliers also undertake to report to GESB, through its official reporting channels stipulated below, any such attempts made by others to involve the customers,  service providers and suppliers  in acts of collusion against GESB; or

(d) instigate third parties to perform actions pertaining to the above.

(v) Customers, vendors and service providers must ensure that all their employees, sub-contractors or agents are aware of and comply with the provisions in this policy.

(vi) Customers and suppliers shall ensure that they adhere to the following:

D. Gifts

(i) Any gift must be unsolicited and not affect, or be perceived as affecting, business judgment. Gifts should only be offered to and received in connection with a customary business or cultural occasion. Cash, loans, kickbacks or the equivalent advantages are absolutely prohibited.

(ii) Gifts must not exceed SGD150 and in any event, must not occur more than 3 times a year with the same person.

(iii) No gift must be given to government officials on behalf of GESB or any of its members.

E. Hospitality (meals and entertainment)

(i) Hospitality must be unsolicited and not affect, or be perceived as affecting, business judgment. Meals and entertainment should only be offered to and received from the representative from GESB dealing with the customer, supplier or service provider in their role in such company, is for purposes supported by GESB and may only be offered in conjunction with legitimate business meetings, conferences or events hosted, supported or sponsored by GESB. They may never be provided on a stand-alone basis.

(ii) Hospitality must not exceed SGD150 (for managers, executives and below) and SGD250 (for senior managers and above) and in any event, must not occur more than 3 times a year with the same person. Spouses or other guests of the invitee must not be included.

F. Additional requirements

(i) Tender periods

To avoid any form of conflict of interest, no customer, supplier or service provider shall offer entertainment or gifts to, or accept them from any director, employee or representative in periods when they are involved in tenders or contract negotiations.

(ii) Discounted products and services

Receiving or offering a product or service at a discounted rate for an individual’s personal use is not permitted unless that discount is widely available to others.

(iii) Spouses, Partners and Guests

GESB acknowledges that some entertainment may include an invitation to bring a spouse, partner or guest to an event or activity, such as attending a business function or community event. In such situations, a Line Manager should provide his/her written approval in advance. Evidence of this approval should be retained and readily available.

(iv) Events

Tickets to events (sports, music, theatre etc) can be given or received on an occasional basis subject to any company director, employee or representative; having obtained the relevant the Line Manager’s approval. The giver (or the giver’s organisation) must be present at the event. Any related entertainment or hospitality must be proportionate and not at a level that is intended to (or could be perceived as being intended to) induce the recipient to act improperly in connection with a business decision, or to influence a public official recipient with respect to granting business or an advantage in the conduct of GESB’s business.

Approval of Entertainment and Gifts Received or Offered

The written approval of the Line Manager is required for the giving or or receipt of, entertainment and gifts.

Consequences of Not Complying with this Policy

Failure to adhere to this policy, or any guidelines which apply to GESB may result in disciplinary action; up to and including dismissal. GESB may also seek to terminate its commercial relationships with third parties who engage in bribery or corruption, in particular, if any such conduct occurs with respect to such third parties’ dealings with the GESB.