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Anti Bribery And Anti Corruption Policy

General

  1. INTRODUCTION
    1. Millenning Pte Ltd (“Millenning”) is committed to conduct our businesses and operations in an honest, scrupulous and ethical manner.
    2. We adopt a ZERO-TOLERANCE approach to bribery and corruption and are committed to acting professionally, transparently and fairly with integrity in all our business dealings and relationships as well as implementing and enforcing effective systems to counter bribery and corruption.
    3. This anti bribery and anti corruption policy (the "Policy") sets out Millenning’s policies and guiding principles to conduct our businesses with honesty, fairness and high ethical standards. This Policy sets out the minimum standard that must be followed by ALL staff. Where international, regional or local laws, regulations or rules impose a higher standard, that higher standard must be followed.
    4. This Policy applies to all employees (full and part-time), sales affiliates, interns, contract workers, consultants, officers and directors of Millenning (collectively called “Millenning staff”).
    5. As part of Millenning’s commitment to conduct our businesses with honesty, fairness and high ethical standards, we will also need to request and ensure that people acting on behalf, as well as our local and overseas working partners do so in compliance with this Policy.
  2. GENERAL PRINCIPLES
    1. Millening staff at all times shall not, directly or indirectly, (i) offer, (ii) promise, (iii) agree to pay, (iv) authorise payment of, (v) pay, (vi) give, (vii) accept, or (viii) solicit “Anything of Value” to or from any third party in order to secure or reward an improper benefit or improper performance of a function, activity or to procure an unfair business advantage (collectively called “Prohibited Conduct”)
    2. "Anything of Value" means bribes, kickbacks, a financial advantage, services, favours or any other direct or indirect benefit or gratification, whether in cash or in kind, tangible or intangible. The term "Anything of Value" has a wide application. Examples of these include but are not limited to gifts, meals, entertainment, discounts that are out of the ordinary or routine businesses, offers of employment or charitable contributions, including any gratification, services or favours which may not have a tangible or direct financial value attached, such as sexual favours.
    3. Prohibited Conduct can also include what is known as "facilitation payments" which are routine payments typically made to low-level “Government Officials” to expedite or secure a service or routine action. Offers of employment or any other benefits, tangible or intangible, made or given to family members of Government Officials or of other counterparties (including parties who are not Government Officials) would also be prohibited.
    4. A "Government Official" includes but not limited to any elected or appointed official of a national or local governmental entity of any country; representatives or employees of a government agency at any level, including customs, immigration and transportation workers, military personnel, representatives of political parties, candidates for political office, representatives of public international organizations, employees of state-owned or controlled entities in any part of the world and any entity hired by a government agency or instrumentality for any purpose (e.g., consultants, marketing or advertising agencies).
    5. Note : Type of conduct/act which is prohibited under Section 2.1 does not actually have to take place. We must avoid any conduct that creates even the appearance of improper activity or conduct.
  3. CONSEQUENCES OF VIOLATIONS
    1. Violations can have severe consequences for Millenning and the individual involved, and can attract both criminal and civil penalties. As an example, under the Prevention of Corruption Act of Singapore ("PCA"), a conviction for a corruption offence is punishable by fines of up to S$100,000 or an imprisonment term of up to seven (7) years or both.
    2. In addition, if Millenning is found to have taken part in corrupt activities, our MAS License may be immediately revoked which will have severe repercussions and damage to both our reputation and financial performance.
  4. UPHOLDING ANTI-BRIBERY AND ANTI-CORRUPTION LAWS
    1. Millenning will uphold all applicable laws relevant to counter bribery and corruption in all the jurisdictions in which we operate. For our businesses and operations in Singapore, we are bound to observe all relevant and applicable laws which include but are not limited to the PCA, the Penal Code and The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act which may be relevant to the corrupt receipt of gifts and hospitality.
    2. We will also abide by the UK Bribery Act 2010 and US Foreign Corrupt Practices Act as these laws can apply to conduct outside each of these countries. The application of all these laws means that any Millenning staff may be subject to criminal liability if he/she directly or indirectly, offers or pays, or authorises the payment of or accepts Anything of Value in exchange for some improper advantage for himself and/or Millenning even if done outside of Singapore.
    3. It is also common in many jurisdictions that the improper acts of consultants, representatives, agents, and intermediaries ("Third Parties") can create criminal liability for the entities for which those Third Parties work. As such, it is necessary for Millenning to ensure that Third Parties that are engaged by us uphold the principles that are stated in this Policy
    4. Millenning may terminate its relationship with any Third Parties that deviate from Millenning's anti-corruption standards and expectations. We must take reasonable precautions and conduct due diligence to ensure that the Third Parties conduct business ethically, are aware of our zero-tolerance approach to bribery and corruption and comply with anti-corruption laws. Arrangements with Third Parties should be subject to clear contractual terms with appropriate representations by the Third Party to comply with applicable laws relating to anti-bribery and anti-corruption.
  5. GIFTS AND ENTERTAINMENT
    1. Business courtesies - Millenning recognises that the exchange of business courtesies, such as modest gifts, and entertainment (including meals, invitations to attend promotional events or parties) particularly during festive periods is customary and legitimate to create goodwill, and/or strengthen business and commercial relationships. Such courtesies are allowed if they are not lavish in the light of accepted business practices and are not intended to improperly influence the decisions of the persons involved.
    2. Basic rules on gifts and entertainment - Basic rules that should be observed when offering or receiving a gift or entertainment: (i) Do not give or accept cash (including ang pows) or any other cash equivalent (including gift vouchers); (ii) lavish or unreasonable gifts or hospitality, whether these be given or received are unacceptable as they may be construed as a bribe. Millenning staff must however avoid placing themselves in situations which could create personal obligations that other persons could exploit to obtain a preferential treatment.
    3. Note: Gifts and/or Entertainment maximum limit (in Singapore Dollars or equivalent in foreign currency) is $100.
    4. If you have any queries on whether a gift or entertainment is appropriate in any circumstance, please seek guidance from the Chief Compliance Officer or the Chief Executive Officer before you accept the gift and/or entertainment.
  6. TRAINING
    1. All Millenning staff must receive read, review and sign a copy of this Policy. The signed copy is to be return to the Admin Staff.
    2. All Millenning staff will be provided with regular anti-corruption compliance training programmes to educate them about the requirements and obligations of anti corruption laws and this Policy. Records on attendance records will be maintained to verify that all Millenning staff receives the necessary training to perform their responsibilities accurately and consistently.
  7. RECORD KEEPING
    1. It is the responsibility of every Millenning staff to ensure that all benefits which are received or provided under Section 5 are fully and accurately kept and handed to the Company's Admin Staff.
    2. The following information must be documented to substantiate each benefit received/provided under Section 5. (i) Business purpose; (ii) Benefit received/provided under, and its value; (iii) Date, location and establishment (where a meal is hosted/received ); (iv) Name, title and employer of the giver/receiver; and (v) Names and affiliations of other participating persons, if any. At a minimum, all such records must be kept for seven (7) years. The Chief Compliance Officer shall have the right to inspect such records as and when he deems appropriate to ensure compliance with this Policy.
  8. REPORTING ACTUAL OR SUSPECTED WRONGDOINGS
    1. Any Millenning staff who observes or suspects that another Millenning staff or anyone else may be acting in contravention of this Policy has an obligation to report it. All such concerns may be reported to the Chief Compliance Officer or Chief Executive Officer or Director. Appropriate follow-up action will be taken by either or all of them.
    2. Any Millenning staff who fails to report known or suspected violations may be subject to disciplinary action including termination of employment. In Singapore, a failure to report known or suspected violations by way of a Suspicious Transaction Report to the Commercial Affairs Department may also result in an offence under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act.
    3. Reporting should be made without delay as prompt reporting and resolution of corruption or bribery issues in many cases are required by applicable law or regulatory requirements.
    4. Note : Any report made in accordance with Section 8.1 will be treated with utmost confidentiality. No Millenning staff acting in good faith will suffer adverse consequences to his employment or retaliation for reporting or for refusing to engage in Prohibited Conduct, even if such refusal results in loss of business opportunities to Millenning.
    5. Every Millenning staff should be assured that there will be no retaliation taken against anyone who has, in good faith (i) sought advice regarding any conduct that may be implicated by this Policy, (ii) has reported a good faith suspicion of a violation of this Policy, or (iii) refused to participate in any conduct that may violate this Policy.
  9. QUESTIONS
    1. If you have any questions relating to this Policy, in particular on the propriety of the conduct or the manner of handling any transaction, you should consult the Chief Compliance Officer, Chief Executive Officer or Director.
  10. NO EXCEPTIONS
    1. No exception to the guidelines set out in this Policy may be made except with the prior written consent of the Chief Compliance Officer, Chief Executive Officer and Director
    2. Any Millenning staff found to have engaged in Prohibited Conduct or ignored suspicious activity may face disciplinary action, including termination of employment or contract and/or referral to appropriate law enforcement/regulatory authorities.