Appoints the Compliance Officer and sets mandatory training, risk assessment and internal audit of the compliance programme.
Scope
This policy applies to all directors, officers, employees, contractors, agents and intermediaries of the company, and governs how the other compliance policies are run, monitored and tested.
Compliance Officer
Adrian Jones, Managing Director, is appointed as the company's Compliance Officer. The Compliance Officer is responsible for the day-to-day operation of the compliance policies, for answering compliance questions, for keeping the compliance records, and for reporting to the board. The Compliance Officer may be contacted at compliance@inbox.case.sg. Where a matter concerns the Compliance Officer personally, it is handled by another director.
Mandatory training
Anti-corruption and anti-money laundering training is mandatory. Every director, employee and contractor completes it within 30 days of joining and at least once in every twelve months after that. The training covers the Anti-Bribery and Anti-Corruption Policy, the Anti-Money Laundering and Counterparty Screening Policy, the Sanctions Policy, the Gifts and Hospitality Policy and the Whistleblowing and Speak-Up Policy. Completion is recorded in a training register kept by the Compliance Officer. A person who has not completed the training may not approve payments or engage counterparties on the company's behalf.
Compliance risk assessment
The Compliance Officer carries out a compliance risk assessment at least once a year, and whenever the company enters a new country, a new line of business or a materially larger transaction. The assessment covers bribery and corruption, sanctions, money laundering, and supply-chain risk, and sets the controls that apply. Individual counterparties are also risk-assessed under the Anti-Money Laundering and Counterparty Screening Policy.
Internal compliance audit
The compliance programme is audited internally at least once a year. The audit tests a sample of counterparty screening records, payments, gifts and hospitality entries, declared interests, training records and whistleblowing reports against the policies. The Compliance Officer reports the findings and any corrective actions to the board, and the board records its review in its minutes. The board may appoint an external reviewer at any time.
Reporting to the board
The Compliance Officer reports to the board at least annually on training completion, the risk assessment, the internal audit, any reports received under the Whistleblowing and Speak-Up Policy, and any breaches and the action taken.