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60ADVANCING AHEADstaff with less than twelve months contract. Ethics training include completing mandatory courses on topics such as awareness on anti-money laundering, anti-bribery and anti-corruption via third party training platforms whereby employees are required to pass an assessment in order to complete the course. The training will help new joiners and existing staff understand the compliance policies and procedures that guide employee behavior to meet required standards. It will also reinforce employees%u2019 compliance knowledge and related protocols as part of their ongoing business activities to minimise compliance risks.Through the Company%u2019s Code of Conduct and Business Ethics and Whistleblowing policy, employees are encouraged to report control deficiencies, ethical issues or suspicions of impropriety to their direct supervisor, local Compliance Officer, Group Compliance Officer or Group General Counsel, where applicable, through various whistleblowing channels. ESR is dedicated to treating whistleblowers with fairness and ensuring their protection from reprisals, victimisation, or any form of detrimental or unfair treatment when they report in good faith. The confidentiality of all information received will be maintained, and the identities of all whistleblowers will be safeguarded. All reported cases will be reviewed to understand the circumstances surrounding the allegations, based on the information provided by the whistleblowers. The management treats all misconduct and dishonesty seriously, conducting independent investigations and taking appropriate disciplinary action on concerns raised, including termination of employment, if required. All independent investigations will be reported to the Audit Committee. Separately, a grievance, which vary in complexity and severity, can be brought up by an employee to his/her manager, Head of Department or directly to the Human Resources Department. In situations where disciplinary action is required against an employee, the Human Resources Department will take the necessary measures leading to the required action in accordance with the Disciplinary Action provision, with the management%u2019s approval. The management will review all grievance cases and aims to resolve complaints objectively, fairly, promptly, and confidentially.ESR Group regularly monitors the evolving climate regulations in the markets that it operates, ensuring that its climate risk strategy is fully aligned with both local and global disclosure requirements, as well as increased expectations from various key stakeholders such as investors, clients, and ESG rating agencies. As APAC%u2019s leading real asset manager powered by the New Economy, ESR Group is focused on raising the bar in its sustainability efforts and leveraging on this as a competitive advantage against its peers.Compliance RiskThe Group is committed to comply with the applicable laws and jurisdictions in its day-to-day business processes and does not tolerate any breaches in regulatory compliance. Non-compliance may result in litigation, penalties, fines or revocation of business licenses which have potential reputational and financial impact. The Group has established a compliance framework that covers training, monitoring, reporting for any non-compliance including screening, investigations, enforcement and disciplinary actions. New and impending changes to regulations are closely monitored to ensure that the Group adheres to regulatory requirements with material non-compliance or regulatory breaches escalated to the Board and management for follow-up.A comprehensive corporate governance framework has been established to maintain responsible and transparent business practices and to adopt a zero-tolerance approach to fraud, bribery and corruption in any form in the conduct of business. All employees are committed to acting professionally, transparently, and fairly with integrity in all business dealings and relationships with the Group%u2019s stakeholders at all times. The framework includes policies on code of conduct and business ethics, conflict of interest, whistleblowing, anti-money laundering and counter terrorist financing and sanctions, prohibition of bribery, acceptance or offer of gifts and entertainment and employee trading and handling of insider information to ensure that all business activities are conducted with honesty, fairness and high ethical standards. Compliance with policies and procedures is required at all times. Group Internal Audit will conduct an annual review of compliance with these policies, including ethical standards. In addition, there are mandatory annual ethics and compliance training, employee trading and code of conduct attestation by employees, including contract staff with at least twelve months of employment. Under the New Employee Orientation Welcome Session, Group Compliance will provide an introduction of the Compliance frameworks, including policies and systems mentioned above, to new joiners which also includes any contract staff or part-time