75 Environmental, Social and Governance Report 2023 PILLAR 3: CORPORATE PERFORMANCE COMPLIANCE At ESR, we are committed to strict compliance with laws and regulations in all the jurisdictions where we operate. In accordance with our Code of Conduct and Business Ethics and Group Human Resources Policy, our employees have freedom of political association. However, it is essential that these activities do not create the impression that employees are speaking or acting on behalf of the Company, unless explicitly authorised to do so. ESR strictly prohibits any form of political involvement on behalf of the Company for political purposes, including any illegal political donations or lobbying expenditures to political organisations or individuals. We emphasise that no contributions or spending were made to any political party or politician for any campaign or related purposes during FY2023. By leveraging on our technology and robust regulatory compliance framework, we have implemented a comprehensive compliance programme. This programme ensures that we adhere to the highest standards of compliance and ethical conduct. • ComplySci® and Thomson Reuters e-learning: We utilise two key tools to support our compliance efforts. ComplySci® is a web-based compliance solution that helps us manage compliance risks and track employees’ acknowledgements of ESR’s Code of Conduct and Business Ethics as well as other relevant policies such as Conflicts of Interest Policy, Anti-Bribery, Anti-Corruption and Handling of Gifts, Travel & Entertainment Policy, Anti-Money Laundering, Counter-Terrorist Financing & Sanctions Policy, Employee Dealing and The Handling of Inside Information and Whistleblowing Policy. Through ComplySci®, employees attest that they have read, understood and will adhere to these principles. Additionally, we utilise Thomson Reuters e-learning platform, to assign compliance-related training courses, covering various topics including anti-bribery and anti-corruption, business gifts and entertainment, insider dealing and anti-competitive conduct and health, safety and environment. Each training includes a self-assessment component where employees can evaluate their understanding of the training material. All employees must complete the mandatory training modules assigned annually and certification to the Code of Conduct and Business Ethics. To ensure the effectiveness of our ethical standards and compliance-related policies, Group Internal Audit will conduct an annual review of the compliance with the above policies, including ethical standards. This process helps us assess the internal controls associated with these standards and policies. We are pleased to report that no breaches of our Code of Conduct and Business Ethics were reported during FY2023. As a Group, we are committed to minimising conflicts of interest by implementing clear prohibitions and proper segregation of duties in situations where a responsible party may have a personal interest during a business transaction and must be excluded from the business discussion or receiving any related information. • Whistleblowing: Guided by our Code of Conduct and Business Ethics, Whistleblowing, Group Human Resources and Human Rights policies, we establish grievance mechanisms to address concerns and reports regarding compliance and workplace conduct. These mechanisms are available to both internal and external stakeholders, including employees, who wish to raise issues related to infringements or violations in confidence. For external third parties, including supply chain workers, who have commercial relationships with ESR and our employees, the designated email address whistleblowing@esr.com is available for reporting whistleblowing complaints. All complaints received through this channel are treated with the utmost confidentiality. External whistleblowers can also visit our corporate website (https://www.esr.com/whistleblowing-policy/) to download and fill out the ‘Whistleblowing Report Form’ to report their findings. Where permissible by law, reporting is anonymous; providing contact information on a voluntary basis is encouraged and helpful for investigating reports, in case there are follow-up questions. The Group’s Head of Compliance and the General Counsel review and analyse all submissions, preparing regular investigative reports for internal communications and fact-checking purposes. The Audit Committee would be notified of all whistleblowing cases and will determine the course of actions to take. The Group is committed to an open, fair and transparent environment to allow employees and external third parties in making genuine reports of any misconduct or violations. Retaliation is prohibited against anyone who assists in an investigation into such matters, even if the report is subsequently not or cannot be substantiated. It is worth noting that no complaints regarding workplace discrimination or ethics violations were reported during FY2023. Risk Management
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