78 Environmental, Social and Governance Report 2023 PILLAR 3: CORPORATE PERFORMANCE AUTOMATED COUNTERPARTY DUE DILIGENCE WORKFLOW Pre-due diligence screening • Data collection and automated screening of responses from counterparties • Responsibility of screening falls on the Business Unit Managers Due Diligence Investigation • Due Diligence reports are generated from LSEG • Initiated and overseen by Legal and Compliance teams Post-due diligence monitoring • Monitoring via Worldcheck, the Screening & Due Diligence database by LSEG • Approval of counterparties subject to renewal every 24 months 2 This represents the total number of screened counterparties in 2023 to-date, which includes 1,944 suppliers. Risk Management CASE STUDY REVISIONS MADE TO COMPLIANCE POLICIES In 2023, Group Compliance presented and obtained the Board’s approval for the revised 6 core compliance policies. With the successful acquisition of ARA, the focus was to harmonise the practices with ARA. Other key updates also include (i) providing specific guidelines on sanctions compliance in the AML/CTF & sanctions policy, (ii) clear guidance on the process of accepting and offering benefits in the anti-bribery, anti-corruption and handling of gifts, travel & entertainment policy, (iii) updated the list of ESR listed securities (“ESR Shares”) that is part of the Group and providing guidance on dealing with ESR Shares, (iv) emphasise that political donations is strictly prohibited in the Code of Conduct and Business Ethics, (v) clear guidelines in managing conflicts of interest (“COI”) and measures on preventing COI and (vi) guidelines on reporting possible violations through the whistleblowing channels and the availability of the whistleblowing policy in other local languages including Japanese and Korean. External legal expert was also engaged to ensure that the policies are in line with the latest regulatory updates and market practices. Group compliance also developed a set of training videos and slides which covers the key updates and requirements of each policy. These training materials were rolled out to all employees as part of the group-wide mandatory compliance training. In addition, these compliance policies were summarised and presented to the Board for approval, and formed part of their training on key areas of the policies, such as anti-corruption and anti money-laundering matters. KEY PERFORMANCE INDICATORS ‡ Politically Exposed Persons, Relative or Close Associates, State Owned Entities and State Invested Entities 3 Risk Buckets containing 67 Specific Risk Areas assessed • Official lists covering sanctions, watchlists, regulatory and enforcement lists • Political exposure covering PEPs, RCAs, SOEs and SIEs‡ • Structured adverse media which covers an extensive list of risk areas including fraud, insider trading, cybercrime, bribery and corruption • Environmental and social risks 7,1512 Counterparties by geographic location Australia China China, Hong Kong India 3,189 1,937 303 374 Japan South Korea Singapore Vietnam, Indonesia & Thailand 837 294 187 30
RkJQdWJsaXNoZXIy MTIwODcxMw==