Legal
"We", "us" and "our" refer to Data Direct Pte Ltd. "Staff" and "users" encompasses employees, contractors, agents, and interns operating under company control. "Agents" include third parties conducting business on the company's behalf, such as clients, contractors, suppliers, consultants, and franchisees.
This policy establishes Data Direct's anti-bribery and corruption framework with a zero risk appetite. It applies to the company, its directors, employees, and third parties acting on behalf of the organisation across all geographical locations.
For those parts of the Group that are impacted by foreign or local laws, where this policy and local requirements conflict, staff must comply with the more stringent standard.
Senior executives manage implementation. All employees and third parties must understand anti-bribery obligations. Managers and supervisors are responsible for implementing these arrangements within the scope of their responsibilities.
The company actively opposes and condemns bribery and corruption in all its forms, conducting business in an honest and ethical manner, while acting professionally, fairly and with integrity.
Key commitments include:
Staff must conduct properly documented, reasonable and proportionate AB&C due diligence prior to entering into a relationship with agents, and are advised to seek and fully document independent legal advice when preparing agency agreements.
Before agent payments, staff should:
Staff must monitor agents and alert management to red flags, including:
The company recognises CSR programs may be perceived as bribery attempts and conducts due diligence accordingly. CEO and legal counsel approval is required for CSR programs. We understand it is not sufficient to merely conduct a background check or to rely on the due diligence undertaken by anyone else.
Due diligence assessment examines program solicitation context, beneficiary charity status under local law, beneficiary history and criminal investigation exposure, board member qualifications and conflicts, and budget transparency.
The company fosters a culture of speaking up to encourage reporting of any suspicion of a bribery and/or corruption incident. All allegations are to be reported at the earliest opportunity or upon the concern being discovered. Protection measures include encouragement of anonymous reporting, prohibition on employee self-investigation, non-disclosure of identity without formal requirement and consent, and disciplinary action against those inhibiting whistleblower rights.
Employees must immediately report offered hospitality, gifts, or sponsored travel to reporting managers. External gifts, travel, or entertainment require prior consent. All gifts given and received by employees must be reported to the CEO, or their reporting manager, so these can be documented appropriately.
Employees must disclose potential conflicts to reporting managers, who then notify the CEO. Disclosure occurs at employment commencement and when conflicts arise during tenure, with annual renewal or updates of conflict declarations required.
The company will take all necessary measures to remedy any breach of this policy including the use of our disciplinary or contractual processes where appropriate.
