Ascendas REIT - Annual Report 2021

Corporate Governance Directors and employees of the Manager are also required to refrain from dealing in Ascendas Reit’s securities if they are in possession of unpublished price-sensitive information of Ascendas Reit arising from their appointment as Directors and/or in the course of performing their duties. As and when appropriate, they would be issued an advisory to refrain from dealing in Ascendas Reit’s securities. Under this policy, Directors and employees of the Manager are also discouraged from trading on short-term or speculative considerations. They are also prohibited from using any information with respect to other companies or entities obtained in the course of their employment in connection with securities transactions of such companies or entities. A Director is required to notify the Manager of his or her interest in Ascendas Reit’s securities within two business days after(a) the date on which he or she becomes a Director or (b) the date on which he or she acquires an interest in Ascendas Reit’s securities. A Director is also required to notify the Manager of any change in his or her interests in Ascendas Reit’s securities within two business days after he or she becomes aware of such change. Dealings by the Directors are disclosed in accordance with the requirements in the SFA and the Listing Manual. In FY2021, based on the information available to the Manager, save as disclosed in accordance with such requirements and other than the awards of Units in part payment of Directors’ fees, there were no dealings by the Directors in Ascendas Reit’s securities. Code of Business Conduct TheManager adheres to an ethics and code of business conduct policy which deals with issues such as confidentiality, conduct and work discipline, corporate gifts and concessionary offers. Clear policies and guidelines on how to handle workplace harassment and grievances are also in place. The policies and guidelines are published on CLI Group’s intranet, which is accessible by all employees of the Manager. The policies that the Manager has implemented aim to help to detect and prevent occupational fraud in mainly three ways, as set out below. First, the Manager offers fair compensation packages, based on practices of pay-for-performance and promotion based on merit to its employees. The Manager also provides various healthcare subsidies and financial assistance schemes to alleviate the common financial pressures its employees may face. Second, clearly documented policies and work procedures incorporate internal controls which ensure that adequate checks and balances are in place. Periodic audits are also conducted to evaluate the efficacy of these internal controls. Finally, the Manager seeks to build and maintain the right organisational culture through its core values, educating its employees on good business conduct and ethical values. Fraud, Bribery and Corruption Risk Management Policy In line with its core values, the Manager is committed to doing business with integrity. This is reflected in its longstanding zero tolerance stance against fraud, bribery and corruption. Consistent with this commitment, various policies and guidelines are in place to guide all employees of the Manager to maintain the highest standards of integrity in their work and business dealings. This includes clear guidelines and procedures for the giving and receipt of corporate gifts and concessionary offers, and an annual pledge by all employees of the Manager to uphold the Manager’s core values and to not engage in any corrupt or unethical practices. The Manager’s zero tolerance policy on bribery and corruption extends to its business dealings with third parties. Pursuant to this policy, the Manager requires that certain agreements incorporate anti-bribery and anti-corruption provisions. Annual Report 2021 141