Anti-Bribery Policy

Please read our anti-bribery policy to understand our brand's commitment to standing up against bribery and corrupt practices and how we actively prevent it in our company.

Introduction

This policy sets out the general rules and principles to which we adhere in the conduct of business. It will be communicated to all businesses and employees, as well as to relevant business partners and other individuals and entities as needed. Those who work in areas within our business identified as being exposed to particularly high risks will receive additional training and support in identifying and preventing corrupt activities.

This policy explains the procedures by which Growe Supply ("the company") can maintain high ethical standards and protect its reputation against any allegations of bribery and corruption. Its successful implementation requires pro-active adoption at the following levels:

  • You: as an employee, temporary worker, or contractor of the company, are required to read and understand all aspects of this policy and to abide by it.
  • Department Manager: Each department's overall compliance with the requirements of this policy is the responsibility of the head of the department.
  • Divisional Management: The Managing Directors of business divisions have overall responsibility for ensuring that all business units within their division comply with this Policy
  • The Company's Board of Directors ("the Board"): The Board will assist with continuous refreshing and reinforcing of this policy via application guidance and monitoring.

1. Policy Statement

It is the company's policy to conduct business honestly and without the use of corrupt practices or acts of bribery to obtain or receive an unfair advantage.

Growe Supply is committed to ensuring adherence to the highest legal and ethical standards of business conduct. This must be reflected in every aspect of the way in which we operate. We must conduct all our dealings with integrity. Bribery and corruption harm the societies in which these acts are committed and prevent economic growth and development.

This is not just a cultural commitment on the part of the organization; it is a moral issue and a legal requirement. Bribery is a criminal offence in most countries in which the company operates, and corrupt acts expose the company and its employees to the risk of prosecution, fines, and imprisonment, as well as endangering the company's reputation.

This policy has been adopted by the Board and is to be communicated to everyone involved in our business to ensure their commitment to it. The Board attaches the utmost importance to this policy and will apply a "zero tolerance" approach to acts of bribery and corruption by any of our employees or by business partners working on our behalf.

This policy is for guidance only and does not form part of the contract of employment. The company may amend it at any time in consultation with the relevant authorities and organizations.

Any breach of this policy will be regarded as a serious matter and will be dealt with under our disciplinary procedure. In serious cases, it may be treated as gross misconduct leading to summary dismissal.

2. What is Bribery & Corruption?

Bribery and corruption have a range of definitions in law, but the fundamental principles apply universally.

Bribery is the offer, promise, giving, demanding, or acceptance of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust.
Corruption is the misuse of an office or power (whether in government or in business) for private gain.

Acts of bribery or corruption are intended to influence recipients in the performance of their duty and incline them to act dishonestly. For the purposes of this policy, whether the recipient of the act of bribery or corruption works in the public or private sector is irrelevant.

The person being bribed is generally someone who will be able to obtain, retain, or direct business. This may involve sales initiatives, such as tendering and contracting, or it may simply involve the handling of administrative tasks such as licenses, customs, taxes, or import/export matters. It does not matter whether the act of bribery is committed before or after the tendering of a contract or the completion of administrative tasks.

3. What is a Bribe?

Bribes can take on many different shapes and forms, but typically they involve corrupt intent. There will usually be a 'quid pro quo' - both parties will benefit.

A bribe could be any of the following:
  • Direct or indirect promise, offering, or authorization of anything of value;
  • Offer or receipt of any kickback, loan, fee, reward or other advantage;
  • Giving of aid, donations, or voting designed to exert improper influence.

4. Who Can Engage in Bribery & Corruption?

In the eyes of the law, bribery and corrupt behavior can be committed by:

  • An employee, officer or director of a company;
  • Any person acting on behalf of the company (e.g. business partners who are agents);
  • Individuals and organizations where they authorize someone else to carry out these acts.

Acts of bribery and corruption will commonly (but not always) involve public or government officials (or their close families and business associates). For the purposes of this policy, a government official could be:

  • A public official, whether foreign or domestic;
  • A political candidate or party official:
  • A representative of a government regulator (e.g., Ministers, Head of Statutory Boards) or of a government-controlled organization (e.g., Ministry of Transport).

5. What Does the Law Say About Bribery & Corruption?

In Singapore, bribery and corruption are governed primarily by the Prevention of Corruption Act (PCA) of 1960, which is the principal legal framework addressing such offenses. The PCA prohibits both the giving and receiving of bribes, and it applies to both public officials and private sector entities. Specifically, sections 5 and 6 of the PCA cover active and passive bribery, while sections 11 and 12 outline the specifics concerning bribery of members of parliament and public officers, respectively.

Under the PCA, a broad definition of ‘gratification’ includes not only money but also gifts, loans, fees, rewards, and other forms of value, demonstrating the law's extensive reach in prohibiting corrupt activities. The Act also provides for a statutory presumption that any gratification received by a public official is deemed corrupt unless the contrary is proven by the accused.

The enforcement of these laws is primarily the responsibility of the Corrupt Practices Investigation Bureau (CPIB), an independent agency that reports directly to the Prime Minister. The CPIB possesses extensive investigative powers to pursue cases of corruption. 

Additionally, the Penal Code includes provisions related to bribery, focusing on offenses involving public servants and the associated penalties for various forms of corrupt conduct, which can include significant fines and imprisonment.

Moreover, Singapore has seen a trend of strict enforcement of anti-corruption laws. Recent cases have highlighted the ongoing investigations and prosecutions of both individuals and corporations involved in bribery, reflecting the government's commitment to combat corruption. In particular, the PCA has no exemptions for facilitation payments or customary practices, indicating a zero-tolerance approach to bribery in all its forms.

Overall, the framework of Singapore's bribery and corruption laws aims to foster integrity in public service and private enterprise, ensuring that corruption is met with harsh penal consequences. This legal environment continues to evolve, responding to new challenges in the fight against corruption.

6. What Steps Can We Take to Prevent Bribery & Corruption?

We recognize that bribery and corruption undermine trust and can adversely affect our reputation and operations. To uphold our commitment to ethical conduct, we have established the following measures to prevent bribery and corruption within our organization:

6.1. Implement Comprehensive Policies and Procedures

  • We have developed robust anti-bribery and corruption policies that clearly outline unacceptable behaviors and establish strict guidelines for our employees.
  • These documents are regularly reviewed and updated to reflect the latest legislation and best practices

6.2. Training and Awareness Programs

  • All employees, from new hires to senior management, receive training on our anti-bribery policies and relevant laws, including the Prevention of Corruption Act.
  • Regular workshops and seminars ensure that our staff understands the implications of bribery and corruption and knows how to act responsibly.

6.3. Risk Assessment

  • We conduct regular risk assessments to identify potential areas of vulnerability to corruption within our operations.
  • This proactive approach allows us to implement targeted measures that mitigate these risks effectively.

6.4. Due Dilligence on Third Parties

  • As part of our commitment to preventing corruption, we perform thorough due diligence on all third-party partners, including vendors, contractors, and agents.
  • This ensures that our business relationships align with our ethical standards.

6.5. Whistleblower Protection

  • We have established a confidential reporting mechanism that enables employees and stakeholders to report suspected bribery and corruption without fear of retaliation.
  • This encourages a culture of openness and vigilance within our organization.

6.6. Strong Leadership Committment

  • Our leadership team sets a clear tone from the top, emphasizing our commitment to ethical business practices.
  • We actively promote a culture of integrity and accountability throughout our organization.

6.7. Effective Monitoring & Auditing

  • Regular internal audits and monitoring processes are in place to ensure compliance with our anti-bribery policies.
  • Any irregularities identified are addressed promptly and thoroughly.

6.8. Enforcement and Consequences

  • We take violations of our anti-bribery policies very seriously.
  • Any employee found to be engaging in corrupt practices will face disciplinary action, which may include termination of employment and legal consequences.

6.9. Enforcement and Consequences

  • We actively engage with our stakeholders, including clients, suppliers, and the community, to promote the values of transparency and ethical conduct.
  • Together, we can work to combat bribery and corruption throughout our industry.

6.10. Enforcement and Consequences

  • The landscape of anti-corruption regulation is constantly evolving. We are committed to keeping abreast of any changes in relevant laws and best practices, enabling us to adapt our policies and practices as necessary.

At Growe Supply, we believe that integrity is a cornerstone of our business and its a fundamental principle ensure we continue to thrive in the long-term. We invite all stakeholders to join us in upholding these principles and ensuring that our corporate environment remains free from bribery and corruption.

7. Where do Bribery & Corruption Risks Typically Arise?

7.1. Use of Business Partners

The definition of a business partner is broad, and could include agents, distributors, joint venture partners or partners in The Company's supply chain who act on behalf of the company.

Whilst the use of business partners can help us reach our business goals, we need to be aware that these arrangements can potentially present The Company with significant risks.
Risk can be identified where a business partner conducts activities on The Company's behalf, so that the result of their actions can be seen as benefiting The Company. Such business partners are more commonly known as agents.

Business partners who act on The Company's behalf must always be advised of the existence of, and operate at all times in accordance with, this policy.
Executive Management is responsible for the evaluation of each relationship and determining whether or not it falls into this category. Where risk regarding a business partner arrangement has been identified, Divisional Management must:
  • Evaluate the background, experience, and reputation of the business partner;
  • Understand the services to be provided, and methods of compensation and payment;
  • Evaluate the business rationale for engaging the business partner;
  • Take reasonable steps to monitor the transactions of business partners appropriately;
  • Ensure there is a written record in place which acknowledges the business partner's understanding and compliance with this policy.
Growe Supply is ultimately responsible for ensuring that business partners who act on its behalf are compliant with this policy as well as with any local laws. Ignorance or "turning a blind eye" is not an excuse. Executive Management should consult in the first instance with the CFO. Executive Management and the CFO should consult with the company leader in charge of the Legal Department where necessary.

7.2. Gifts, Entertainment & Hospitality

Gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to our business. These activities are acceptable provided they fall within reasonable bounds of value and frequency.

How to evaluate what is 'acceptable'?
First, take a step back and ask yourself the following:
  • What is the intent - is it to build a relationship or is it something else?
  • How would this look if these details were on the front of a newspaper?
  • What if the situation were to be reversed - would there be a double standard?

If you find it difficult to answer one of the above questions, there may be a risk which could potentially damage Growe Supply's reputation and business. This action could well be unlawful. It is best to say no in such situations. 

Although no two situations are the same, the following guidance should be considered globally:

Never Acceptable
Circumstances which are never permissible include examples that involve:
  • A 'quid pro quo' (offered for something in return)
  • Gifts in the form of cash/or cash equivalent vouchers
  • Entertainment of a sexual or similarly inappropriate nature
  • Lavish corporate hospitality

As a general rule, The Company's employees, engaged contractors and business partners should not provide gifts to, or receive them from, those meeting the definition of a government official in section 4 (or their close families and business associates).

However, it is understood that in certain countries gift giving and receiving with such individuals is a cultural norm. If you are faced with such a situation, please consult with the company leader in charge of the Legal Department before proceeding.

Usually Acceptable

Possible circumstances that are usually acceptable include:

  • Modest/occasional meals with someone with whom we do business;
  • Occasional attendance at ordinary sports, theatre and other cultural events;
  • Gifts of nominal value, such as pens, or small promotional items.
A variety of cultural factors such as customs, currency and expectations may influence the level of acceptability. If you feel uncertain at any time regarding cultural acceptability of gifts, entertainment or hospitality, please consult the company leader in charge of the Legal Department. In addition, if an example does not fall under the above categories, please in the first instance seek guidance from a company leader in charge. Generally, such examples would not be permissible without prior approval.

Transparency is Key
Executive Management will be required to maintain and monitor its gifts, entertainment and hospitality register. 
  • Any form of gift, entertainment or hospitality given, received or offered which meets or exceeds the equivalent of SGD 100 per person or per gift in value must be appropriately recorded in the register.
  • In the event that an impermissible form of gift, entertainment or hospitality has been accepted, you must appropriately record the transaction within the register and contact the company leader in charge of the Legal Department.

7.3. Facilitation Payments

In many countries, it is customary business practice to make payments or gifts of small value to junior government officials in order to speed up or facilitate a routine action or process. It may be that we need to obtain licenses or permits faster than the normal course, or we may need lawfully to import or export equipment.

Despite this, facilitation payments as defined here are against this Growe Supply policy and are illegal within Singapore as well as within most countries in which we operate:

In Singapore, facilitation payments are generally regarded as a type of bribery under the Prevention of Corruption Act (PCA). The law does not recognize a special exemption for facilitation payments; instead, they fall under the broad definition of “gratification” in the PCA, which encompasses any advantage given with the intention of influencing a public official.

The PCA makes no distinction between facilitation payments and bribes regardless of size or local cultural expectations, even if that is "how business is done here".

However, if a facilitation payment is requested, or if you are forced to pay under duress or faced with potential safety issues or harm, such a payment may be made, provided that certain steps are followed. If you are ever placed in such a situation, you must contact the company leader in charge of the Legal Department as soon as possible and you must record the payment appropriately within The Company's books and records to reflect the substance of the underlying transaction.

If you are unsure whether certain payments which resemble the definition of facilitation payments are permissible, please contact the company leader in charge of the Legal Department.

8. Departmental Adoption

In order for this policy to be effective, it must be applied across all departments. Department Managers are responsible for taking relevant steps within their department to ensure and continuously monitor compliance with this policy.

9. How to Raise a Concern

We all have a responsibility to help detect, prevent and report instances not only of bribery, but also of any other suspicious activity or wrongdoing. 
  • Growe Supply is absolutely committed to ensuring that all of us have a safe, reliable, and confidential way of reporting any suspicious activity.
  • We want each and every one to know how they can "speak up".
If you have a concern regarding a suspected instance of bribery or corruption, please speak up - your information and assistance can only help. The sooner you act, the better for you and for the company.

If you are concerned that a corrupt act of some kind is being considered or carried out - either within Growe Supply, by any of our business partners or by any of our competitors: 
  • Please report the issue/concern to your leader.
  • If for some reason it is not possible to speak to your leader, please then report it to another company leader.
In the event that an incident of bribery, corruption, or wrongdoing is reported, we will act as soon as possible to evaluate the situation. Growe Supply has clearly defined procedures for investigating fraud, misconduct and non-compliance issues and these will be followed in any investigation of this kind.

For further details see also Growe Supply's policy on Whistleblowing. If you have any questions about these procedures, please contact the company leader in charge of the Legal Department.

10. Conclusion

It is the ultimate responsibility of the Board to refresh and reinforce this policy and its underlying principles and guidelines. Executive Management, under the overview of the CFO and Head of Legal, are responsible for the establishment and ongoing monitoring of compliance with sections 6, 7 and 8 of this policy.

Last Updated: 30 Dec 2024