ST Telemedia’s Anti-corruption Policies
ST Telemedia is committed to conducting our business and affairs lawfully, ethically and with integrity. This commitment extends throughout our portfolio of companies, regardless of where our business and operations are conducted. As part of this commitment, our directors, officers, employees and consultants and those of our portfolio companies are expected to hold themselves to a high level of ethical standards and act in accordance with applicable laws and regulations.
We adopt a zero-tolerance policy towards any form of corruption and bribery. We will not tolerate bribery, kickbacks or corruption of any kind, directly or through third parties, whether or not explicitly prohibited by this policy statement and its related guidelines and policies or by law.
Our personnel and other persons acting on our behalf (including agents and intermediaries) must conduct their activities in full compliance with this policy statement and its related guidelines and policies, as well as all applicable anti-corruption laws and regulations in the countries where we have business activities (including the Singapore Prevention of Corruption Act, the U.K. Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act), and shall not, directly or indirectly, engage in any corrupt or improper practices.
We also expect those who act on behalf of, or otherwise deal with, us and/or any of our portfolio companies to be aware that this policy statement and its related guidelines and policies underpin the conduct of our business and affairs and in order to work with us and/or our portfolio companies, they need to act in a manner consistent with this policy statement and its related guidelines and policies.
We will strive to ensure that our business partners share our zero tolerance policy against corruption and bribery. We will avoid engaging in business dealings with those known or reasonably suspected to be engaging in corruption or bribery.
All our portfolio companies are expected to have in place and maintain a policy or a code of conduct that is aligned with the key principles set out in this policy statement and its related guidelines and policies including (where necessary) additional rules and procedures applicable to that portfolio company’s operations.
