ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

  1. Objective

    Vintedge Pte Ltd (“Vintedge” or the “Company”) is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. It is Vintedge’s policy to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice of not engaging in bribery or corruption.

  2. Scope and applicability

    This Anti-bribery and Anti-corruption Policy (this “Policy”) applies to all individuals working for all affiliates and subsidiaries of Vintedge at all levels and grades.

    In this Policy, “Third Party(ies)” means any individual or organization, who / which come into contact with Vintedge or transact with Vintedge.

  3. Policy details

    A bribe is an inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. It is illegal to directly or indirectly offer a bribe or receive a bribe.

    A bribe may be anything of value and not just money -- gifts, inside information, sexual or other favors, corporate hospitality or entertainment, offering employment to a relative, payment or reimbursement of travel expenses, charitable donation or social contribution, abuse of function --and can pass directly or through a third party. Corruption includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery.

  4. Gifts and hospitality

    Employees or members of their immediate families (spouse, mother, father, son, daughter, brother, sister or any of these step- or in-law relationships, whether established by blood or marriage including common law marriage) should not provide, solicit or accept cash or its equivalent, entertainment, favors, gifts or anything of substance to or from competitors, vendors, suppliers, customers or others that do business or are trying to do business with Vintedge.

    Loans from any persons or companies having or seeking business with Vintedge, except recognized financial institutions, should not be accepted. All relationships with those who Vintedge deals with should be cordial, but must be on an arm’s length basis. Nothing should be accepted, nor should the employee have any outside involvement, that could impair, or give the appearance of impairing, an employee's ability to perform his/her duties or to exercise business judgment in a fair and unbiased manner.

    This Policy does not prohibit normal and appropriate gifts, hospitality, entertainment and promotional or other similar business expenditure to or from Third Parties. However, the key determining factor for appropriateness of the gift or hospitality and/or its value would be based on facts and circumstances under which such gift or hospitality is provided.

    The practice of giving gifts and hospitality is recognized as an established and important part of doing business. However, it is prohibited when they are used as bribes. Giving gifts and hospitality varies between countries and sectors and what may be normal and acceptable in one country may not be so in another. To avoid committing a bribery offence, the gift or hospitality must be:

    1. Reasonable and justifiable in all the circumstances
    2. Intended to improve the image of Vintedge , better present its products and services or establish cordial relations

    The giving or receiving gifts or hospitality is acceptable under this Policy if all the following requirements are met:

    1. It is not made with the intention of influencing a Third Party to obtain/ retain business or a business advantage or to reward the provision or retention of business or a business advantage or in explicit or implicit exchange for favors/ benefits or for any other corrupt purpose
    2. It complies with local laws and customs
    3. It is appropriate in the circumstances. For example, in Singapore it is customary for hampers to be given during Christmas or Chinese New Year
    4. Taking into account the reason for the gift or hospitality, it is of an appropriate type and value and given at an appropriate time
    5. It is given openly, not secretly and in a manner that avoids the appearance of impropriety

    If you have any question or doubt about whether a gift, meal or entertainment or is appropriate, seek guidance from your supervisor.

  5. What is not acceptable?

    It is not acceptable for any employee of Vintedge (or someone on his / her behalf) to:

    1. Accept an offer of a gift of any size from any Third Party which is in negotiation with, or is submitting a proposal with Vintedge
    2. Give, promise to give or offer, any payment, gift, hospitality or advantage with the expectation or hope that a business advantage will be given or received or to reward a business advantage already given
    3. Accept or solicit any payment, advantage, gift or hospitality from a Third Party that you know or suspect is being offered with the expectation that it will obtain a business advantage for them
    4. Threaten or retaliate against, another employee who has refused to commit a bribery offence or who has raised concerns under this Policy
    5. Engage in any activity that might lead to a breach of this Policy

  6. Willful blindness

    If an employee wilfully ignores or turns a blind eye to any evidence of corruption or bribery within his / her department and/or around him / her, it will also be taken against the employee. Although such conduct may be “passive”, i.e. the employee may not have directly participated in or may not have directly benefited from the corruption or bribery concerned, the wilful blindness to the same can, depending upon the circumstances, carry the same disciplinary action as an intentional act.

  7. Bribes and kickbacks

    Neither an employee of Vintedge nor any person acting on behalf of Vintedge shall make and shall not accept bribes or kickbacks of any kind. You must avoid any activity that might lead to or suggest that a bribe or kickback will be made or accepted by Vintedge.

  8. Competition

    Vintedge Technologies' success depends on building productive relationships with our partners and clients based on integrity, ethical behavior and mutual trust.

    We are committed to succeed in business by virtue of excellence service quality and value, and not by creating unfair disadvantage for its competitors.

    We believe in competing fairly and strictly on the merits of services quality and make no attempts to restrain or limit trade.

  9. Charitable donations

    As part of its corporate citizenship activities, Vintedge may support local charities or provide sponsorship, for example, to sporting or cultural events.

  10. Political activities

    We are apolitical, advocate government policies on sustainability and do not contribute financial or in kind to political parties, politicians and related institutions in any of the countries. We do not make contributions to political parties, political party officials or candidates for political office. You should not make any political contribution on behalf of Vintedge, use any Vintedge resources to assist a candidate or elected official in any campaign or coerce or direct another employee to vote a certain way. You should never attempt to offer any incentives to public officials in the hopes of influencing the decision of that individual.

  11. What are the governing legislations?

    All national laws relating to bribery and corruption, especially such laws that are in place in jurisdictions where Vintedge has an office or carries out its work, are of importance to the Company. The laws that may apply to the Company include:

    1. Singapore: The Prevention of Corruption Act
  12. Waiver and amendment of the policy

    We are committed to continuously reviewing and updating our policies and procedures. The Policy will be reviewed and audited from time to time which requires cooperation from all concerned.

  13. Reporting Process

    Staff who are aware of any cases of corruption or bribery should report the case to management.

    The management shall strive to provide a workplace free of bribery and corruption by complying with all applicable laws relating to bribery, money laundering and/or corruption as well as prohibiting the exchange of money or anything else of value to or from anyone, including government officials, to influence actions or obtain an improper advantage.

    Staff in supervisory role is responsible to uphold the same standard concerning bribery, corruption and unethical business practices, and are authorized to take corrective action to stop such activities

    Reporting of Corruption/Bribery cases can be made by email to Sophia@vintedge.com