Code of Business Conduct & Ethics
LHS Group is committed to conducting business with the highest standards of ethics, transparency, and accountability.
Purpose & Scope
Purpose & Scope
This Code of Business Conduct and Ethics applies to all Directors, Management, Employees, and Business Representatives of LHS Group and its subsidiaries (collectively, "Relevant Individuals").
LHS Group 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.
Where local laws or regulations impose stricter standards, the higher standard applies.
Glossary of Key Terms
Anything of Value
Gifts, bribes, kickbacks, cash, discounts, services, employment offers, donations, favours, and other benefits — whether tangible or intangible.
Government Official
Any officer or employee of a government agency, political party, public international organisation, or state-owned enterprise.
Third Party
Any agent, consultant, contractor, vendor, or intermediary acting on behalf of LHS Group.
Conflict of Interest
A situation where personal interest interferes, or appears to interfere, with professional duties or the interests of LHS Group.
Responsibilities & 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.
Ethical Principles
Anti-Bribery and Corruption
LHS Group 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.
Gifts and Entertainment
Modest, customary gifts are permitted only if they are not intended to gain improper advantage and comply with LHS policy.
Gifts exceeding S$100 must be reported to Management.
Third-Party Dealings
Due diligence must be conducted before engaging third parties. Contractual clauses on ethical conduct must be included. Relationships with third parties who violate ethical standards will be terminated.
Sponsorships and Contributions
Charitable, political, or religious contributions must be approved by senior management and must not be used as a disguise for improper benefits
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.
Conflicts of Interest
Any actual or potential conflicts must be disclosed to a supervisor or the Managing Director. Employees must not use their position at LHS Group for personal gain.
Record Keeping
Accurate records must be maintained for all transactions, including gifts, entertainment, donations, and sponsorships.
Workplace Conduct & Culture
Equal Opportunity
LHS Group provides a fair and respectful workplace and prohibits discrimination of any kind.
Harassment and Safety
Harassment, violence, and substance abuse are strictly prohibited. All employees must comply with workplace safety protocols.
Environmental Responsibility
LHS Group is committed to sustainability and minimising environmental impact in its operations.
Whistleblowing & Protection
Reports made in good faith will be protected from retaliation. Retaliation against whistleblowers is strictly prohibited. False reports made maliciously may result in disciplinary action.
Whistleblower contact: whistleblower@lhse.com
Training & Certification
All employees will undergo anti-corruption and ethics training. New hires must sign a declaration acknowledging their understanding of and commitment to this Code.
Monitoring & Review
This Code will be reviewed at least once every two years. Updates will be communicated to all employees.
Employees are encouraged to suggest improvements via compliance@lhse.com