| Singtel aspires to the highest standards of corporate governance and
business ethics through the implementation of appropriate policy, structure
and enforcement of our Code of Ethics and core value of integrity. |
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| Major control initiatives across the businesses have been implemented,
focusing on establishing and maintaining accountability for prevention,
detection and reporting of fraud, and applying the Group’s zero tolerance
policy at the highest levels of management. |
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| The adoption of the Fraud Investigation and Whistleblower Protection Policy
in Singtel, along with our whistleblower programme, provides robust
internal controls in the management of fraud risk. This includes prompt
identification of suspected fraud and encouraging employees to raise any
concerns about fraud or other irregularities without fear of reprisal. The
Policy and related processes, including the adoption of a zero tolerance
approach to fraud, are formally communicated to our people each year.
The Policy requires independent and prompt investigation of all fraud
matters by Internal Audit and timely and regular reporting of all significant
fraud cases and whistleblower complaints to the Audit Committee, Senior
Management and external auditors, as appropriate. |
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| During the year, Singtel reported one case of alleged corruption to the law
enforcement authority. We also conducted a thorough internal investigation
and in accordance with our zero tolerance approach, the services of the
people involved were subsequently terminated. |
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| To encourage further transparency and reporting of potential or actual
instances of fraud, the independent whistleblower hotline was published
on our corporate website. In January 2013, a separate internal Fraud Risk
Management Committee was formed comprising senior management
members to review all fraud related cases within Singtel and ensure
neccessary follow-up actions. |
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| Fraud and control awareness training programmes were conducted
throughout the year to broaden the education and awareness of our
people on fraud risk and accompanying mitigating measures. A total of
94 participants attended these sessions in FY2013. Internal Audit worked
with Management to conduct regular training in Singapore and overseas
subsidiaries and offices. The training sessions included discussion of
past fraud cases and the lessons learnt on internal control procedures.
Continuous education on the Code of Business Conduct via eLearning has
been rolled out and 870 employees have completed this programme since
December 2011. |
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| Singtel launched a Code of Ethics with Vendors in December 2011. This code requires all employees to comply with the guidelines
covering gifts and hospitality in order to avoid a situation of conflict or
potential/perceived conflicts of interest. Employees have to make the
required declarations to Human Resources and their line supervisor. They
also have to report any breach or case involving potential or alleged fraud to
Human Resources and Internal Audit. |
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| We require our people to be honest in all business dealings at all times.
Any payment or in-kind transaction, such as gifts or favours, to influence
business opportunities or decisions in Singtel’s favour is prohibited.
Singtel has a strict Code of Conduct that governs employee dealings with customers, suppliers, competitors and the community. On an annual basis,
all Singtel employees are required to make a mandatory declaration on the
absence of any instances of conflict of interest. |
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| In accordance with the requirement under SGX Listing Rule 1207 (10), the
Board is required to issue an opinion to the shareholders on the adequacy
of Singtel Group’s internal controls, addressing financial, operational and
compliance risks in the Corporate Governance section of the Annual Report. |
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| The framework and process to support the Board’s opinion on the adequacy
of Singtel Group’s internal controls include reviews and statutory audit of
financial statements by external auditors, results of work performed by
Singtel Internal Audit, annual certification by Management on adequacy
and effectiveness of risk management and internal controls, and reporting
protocol for escalating major incidents and violations. |
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| An escalation process had been established so that the Board of Directors,
Senior Management and both internal and external stakeholders are kept
informed of corporate crises in a timely manner, based on level of severity.
Such crises may include violations of code of conduct and/or applicable
laws and regulations, as well as loss events and fraud, which have or
are expected to have a significant impact on the Group’s business and
operations. |
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| Risk management |
| Risk takes on many forms and can have material impact for a company of
Singtel’s size and breadth of operations. It can have an adverse impact on
Singtel’s reputation, operations and financial performance. It is imperative
that the identification and management of risk reduces the uncertainty
associated with the execution of our business strategies and allows Singtel
to maximise opportunities that may arise. |
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| In May 2012, a separate Board Risk Committee was established by the
Board of Directors to assist in its responsibilities relating to the governance
of risk. This has provided an increased focus and a more integrated Group-wide perspective in relation to the oversight of material risks. The
committee’s responsibilities include ensuring that Management maintains
a sound system of risk management and internal controls to safeguard
shareholders’ interests and the Group’s assets. It is also tasked with
determining the nature and extent of the material risks which the Board is
willing to take in achieving the Group’s strategic objectives. |
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| Day-to-day Singtel’s risk management operates within a robust
framework. The ongoing process for executive officers involves risk
identification, monitoring, management and reporting of risks throughout
the organisation. This in turn provides assurances to the Board, its Risk
Committee and other interested stakeholders. More information on the risk
management process is found in our annual report http://info.singtel.com/annualreport/2013/corporate-governance/risk-management-philosophy-and-approach.html. |
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