Code of Business Conduct and Ethics
TechSearch Pte Ltd (the “Company") has adopted the following Code of Business Conduct and Ethics (the “Code”) for itself and the officers and employees of the Company and its subsidiaries (the Group”). The Code is intended to help us recognize and deal with ethical issues, deter wrongdoing, provide mechanisms to report and prevent dishonest or unethical conduct and foster a culture of honesty and accountability.
Each of us has a personal responsibility to conduct ourselves, and ensure that our suppliers, agents and representatives are aware of their obligation to conduct themselves, in a legal, ethical way and to comply with both the letter and the spirit of this Code.
No code or policy can anticipate every situation that may arise. This Code is intended to serve as a guide. Employees are encouraged to ask their managers questions about particular circumstances that may involve the provisions of this Code.
Conflict of Interest
A "conflict of interest" occurs when our individual private interests interfere, or appear to interfere, in any way with the interests of the Company. Each of us must avoid conflicts of interest with the Company.
This Code does not attempt to describe all possible conflicts of interest which could develop. Some of the more common conflicts from which we should refrain, are:
· an employee or a family member receiving an improper personal benefit as a result of the employee’s position with the Company. A “family member” means a spouse, parents, children and siblings, whether by blood, marriage or adoption;
· knowingly engaging in any conduct or activity that is inconsistent with the Company's best interests or that disrupts or impairs the Company's relationship with any person or entity with which the Company has or proposes to enter into a business or contractual relationship;
· accepting compensation, in any form, from any source other than the Company, which affects job performance in any way;
· offering, giving or receiving gifts to or from anyone who deals with the Company in cases where the gift is being made to influence our actions in our position with the Company, or where acceptance of the gifts could create the appearance of an impropriety.
Each of us has an obligation to comply country specific anti-bribery and anti-corruption laws. You may not give, promise or offer anything of value, no matter how small, to any customer, government employee or other person for the purpose of improperly influencing a decision, securing an advantage, avoiding a disadvantage or obtaining or retaining business. If you engage in such behavior, you expose yourself and the company to civil and/or criminal liability, significant reputational harm and undermine the trust that our customers, shareholders and communities have placed in us.
Each of us has a responsibility to the Company to advance its legitimate interests.
We must not:
· personally take for ourselves or divert to others opportunities that are discovered through the
use of Company property, information or our respective position;
· use Company employees, property, information or our respective positions for personal gain; or
· compete with the Company, directly or indirectly, for business opportunities.
Confidentiality and Privacy
Each of us must maintain the confidentiality and privacy of information and personal data entrusted to us by the Company, employees and our customers and comply with TechSearch’s Privacy Statement which is found at http://www.techsearch.com.sg
Protection and Proper Use of Company Assets
We must each protect the Company's assets and ensure their efficient use. No one is to use
Company assets for personal benefit.
We have a responsibility to deal fairly with each other and our customers, candidates and suppliers. No one must take unfair advantage of anyone else through manipulation, concealment, abuse of confidential information, misrepresentation of material facts or any other unfair dealing practices.
Compliance with Laws, Rules and Regulations
Each of us shall, and shall ensure that our suppliers, agents and representatives are aware of their obligation to, comply with all laws, rules, regulations applicable to the Company including the any applicable anti-corruption and anti-bribery laws, labor and employment laws, and applicable health, safety and environmental laws, applicable data privacy and protection laws and all policies established by the Company.
Reporting Dishonest or Unethical Behavior
When in doubt about the best course of action in a particular situation, employees should talk to their managers or other appropriate personnel. Subject to applicable laws, anonymous reporting may be permitted. Retaliation of any kind against any Director, officer or employee for reports made in good faith is expressly prohibited and will result in corrective action, including termination of employment. If an employee does not feel that the reported violation has been addressed, they should follow up directly with the Company Secretary.
Failure to Comply; Compliance Procedures
The failure by any Director, officer or employee to comply with the laws, rules or regulations
governing the Company's business, this Code or any Company policy will constitute grounds for
corrective action, up to and including termination of employment or engagement. Reports of
known or suspected violations will be promptly investigated by the appropriate function, which
may include Audit, Human Resources or Law.
Adopted by Board of Directors
February 9, 2004, as amended on August 10, 2010