Millenning Pte Ltd (“Millenning”) is committed to conduct our businesses and
operations in an honest, scrupulous and ethical manner.
We adopt a ZERO-TOLERANCE approach to bribery and corruption and are committed
professionally, transparently and fairly with integrity in all our business
relationships as well as implementing and enforcing effective systems to counter
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.
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”).
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.
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”)
"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.
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.
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).
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.
CONSEQUENCES OF VIOLATIONS
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.
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.
UPHOLDING ANTI-BRIBERY AND ANTI-CORRUPTION LAWS
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.
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
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
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.
GIFTS AND ENTERTAINMENT
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.
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
Note: Gifts and/or Entertainment maximum limit (in Singapore Dollars or
equivalent in foreign currency) is $100.
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.
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.
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.
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.
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.
REPORTING ACTUAL OR SUSPECTED WRONGDOINGS
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.
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.
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
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.
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.
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.
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
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