Sustainability Report How does Perennial Holdings manage this? • Employee Code of Conduct • Employee Code of Ethics • Whistleblowing Policy • Policy on Anti-Money Laundering and Countering the Financing of Terrorism • Interested Person Transactions Policy • HSS • Full compliance with relevant laws and regulations in countries of operation Who at Perennial Holdings oversees this? • HR • Legal and Corporate Secretariat • Risk Management Team • Perennial Health and Safety Committee • Finance Team • Designated AML Officer Highlights of FY2023 • Annual Circulation of Company’s Employee Code of Conduct, Employee Code of Ethics and Whistleblowing Policy Relevant UN SDG GOVERNANCE Perennial Holdings integrates strong CG, business ethics and strict regulatory compliance in its everyday operations across all countries where it has a presence. Business Ethics GRI [2-15] [2-16] [2-23] [2-24] [2-25] [2-26] [3-3] [205-2] [205-3] As a large organisation operating in multiple sectors and countries, cases of fraud, corruption or unethical actions could possibly slip by and go unnoticed. Therefore, Perennial Holdings implements measures to ensure that ethical business conduct is ingrained throughout its business operations. The Company is guided by a comprehensive suite of policies and procedures including the Employee Code of Conduct, Whistleblowing Policy and Policy on Anti-Money Laundering and Countering the Financing of Terrorism which serves as a guide for responsible decisionmaking and ethical business conduct. The Code of Conduct aims to ensure that all employees do not engage in any form of activities that may interfere with their judgement and lead to a potential conflict of interest. It sets out principles to guide each employee’s business conduct, both internally and externally. The Code also provides guidance on topics such as conflict of interest, bribery and illegal practices and workplace health and safety. According to the Code of Conduct, employees shall not engage in any unlawful or unethical practices, accept gifts, or engage in insider trading. Employees are also expected to treat all colleagues with respect and any form of discrimination and harassment will not be tolerated. It is the responsibility of all heads of departments to ensure that their team complies with this Code of Conduct. Although the Code of Conduct is not publicly available, it has been endorsed by and remains under the purview of the Chief Executive Officer and Management. The Whistleblowing Policy provides guidance and an avenue for employees to report any grievances or suspected illicit activities within the Company. This ensures that critical concerns are communicated to the Board and appropriate action can be taken in a timely manner. The Whistleblowing Policy, which comes directly under the purview of the Board, is made available to all stakeholders, including employees, service providers and business partners. Under the Whistleblowing Policy, stakeholders are encouraged to report any suspicions of malpractice. The identities of whistleblowers will be protected through the course of subsequent investigations. For more details on this Policy, please refer to https://www.perennialholdings.com Perennial Holdings’ Policy on Anti-Money Laundering and Countering the Financing of Terrorism and procedures include risk assessment and mitigation, customer due diligence, reporting of suspicious transactions and record keeping. In particular, the Policy sets out how due diligence is to be approached, using a risk-based approach and when to perform simplified or enhanced due diligence as well as the forms which need to be completed when conducting due diligence. An escalation chain of command is also set out to address how suspected cases of money laundering and financing of terrorism should be approached. Training is also conducted to ensure employees remain up-to-date on relevant regulation. The policies and procedures mentioned are re-circulated to Management and all employees on an annual basis. This acts as a yearly refresher on the expected business conduct and emphasises the severity of violating these policies. Updates may be made to the policies and procedures where relevant and applicable and will be communicated accordingly to all employees. In FY2023, Perennial Holdings is pleased to report that there were no reported cases of fraud, corruption or unethical behaviour. Corporate Governance GRI [3-3] The establishment of a robust CG culture and strong internal controls are crucial for economic growth as it boosts investor confidence and the Company’s reputation. Since its inception, Perennial Holdings has emphasised the importance of good CG through its annual CG report and internal policies and guidelines review. A comprehensive risk management system is incorporated into the CG framework to ensure that actual and potential risks arising from Perennial Holdings’ business activities are actively monitored and managed. Sustainability risks are also considered within this framework, thereby enhancing Perennial 124 PERENNIAL HOLDINGS PRIVATE LIMITED
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