Code of Business Conduct
1.0 Purpose and Scope
This Code of Business Conduct and Ethics (“Code”) applies to all Directors, Management, Employees, and Business Representatives of LHS and its subsidiaries (collectively, “Relevant Individuals”).
LHS is committed to conducting business with the highest standards of ethics, transparency, and accountability. We adopt a zero-tolerance approach to bribery, corruption, and other forms of misconduct, and are dedicated to complying with all applicable laws, including the Singapore Prevention of Corruption Act (PCA) 1960.
This Code sets the minimum expectations of behaviour for all Relevant Individuals. If local laws or regulations impose stricter standards, the higher standard will apply. The Code should be read together with other LHS policies and is subject to periodic updates.
2.0 Glossary of Key Terms
- Anything of Value: Includes gifts, bribes, kickbacks, cash, discounts, services, employment offers, donations, favors, and other benefits, whether tangible or intangible.
- Government Official: Any officer or employee of a government agency, political party, public international organization, or state-owned enterprise.
- Third Party: Any agent, consultant, contractor, vendor, or intermediary acting on behalf of LHS.
- Conflict of Interest: A situation where personal interest interferes, or appears to interfere, with professional duties or the interests of LHS.
3.0 Responsibilities and Compliance
All Relevant Individuals must:
- Understand and comply with this Code.
- Report actual or suspected violations promptly.
- Support a culture of ethics and accountability.
Reports can be made confidentially to the Managing Director or via email at whistleblower@lhse.com
Violations may result in disciplinary action, including termination and legal proceedings.
4.0 Ethical Principles
4.1 Anti-Bribery and Corruption
• LHS prohibits offering, soliciting, or accepting bribes or facilitation payments.
• No gifts or benefits may be given or received to improperly influence decisions.
• This applies to both public and private sector interactions.
4.2 Gifts and Entertainment
• Modest, customary gifts may be permitted only if:
o They are not intended to gain improper advantage.
o They comply with LHS policy and are declared.
• Gifts exceeding S$100 must be reported to Management
4.3 Third-Party Dealings
• Conduct due diligence before engaging third parties.
• Include contractual clauses on ethical conduct.
• Terminate relationships with third parties who violate ethical standards.
4.4 Sponsorships and Contributions
• Charitable, political, or religious contributions must:
o Be approved by senior management.
o Not be used as a disguise for improper benefits.
4.5 Employment Practices
• Employment must never be used as a tool for business advantage.
• Hiring of individuals recommended by external parties must be based on merit.
4.6 Conflicts of Interest
• Disclose any actual or potential conflicts to your supervisor or the Managing Director.
• Avoid using your position at LHS for personal gain.
4.7 Record Keeping
• Maintain accurate records for all transactions.
• Record any gifts, entertainment, donations, and sponsorships transparently
5.0 Workplace Conduct and Culture
5.1 Equal Opportunity
• LHS provides a fair, respectful workplace and prohibits discrimination of any
kind.
5.2 Harassment and Safety
• Harassment, violence, and substance abuse are strictly prohibited.
• Employees must comply with all workplace safety protocols.
5.3 Environmental Responsibility
• LHS is committed to sustainability and minimizing environmental impact.
6.0 Whistleblowing and Protection
• Reports made in good faith will be protected.
• Retaliation against whistleblowers is strictly prohibited.
• False reports made maliciously may result in disciplinary action.
7.0 Training and Certification
• All employees will undergo anti-corruption and ethics training.
• New hires must sign a declaration acknowledging understanding and commitment to this Code.
8.0 Monitoring and Review
• Updates will be communicated to all employees.
• Employees are encouraged to suggest improvements via compliance@lhse.com