Description 4

 

At Yinson, compliance and ethical conduct is established at the highest level. Our Code of Conduct and Business Ethics provides guidance for all Yinsonites to perform their jobs with upmost integrity, and forms the basis for building a compliance culture throughout the company in perfect cohesion with our corporate culture and core values, R.O.A.D.S. In line with Yinson's Anti-Bribery and Anti-Corruption ("ABAC") Policy, the Group also practices ZERO tolerance for bribery and corruption.

Group Chief Executive Officer, Lim Chern Yuan

Overview

At Yinson, compliance is a system of controls intended to provide a cost-beneficial level of assurance that the Group complies with all applicable laws, regulatory requirements and internal policies. Yinson is committed to conducting our business responsibly, in accordance with the laws of the countries where we operate in. This is done through the continuous compliance awareness communication and adoption of Yinson’s policies and procedures in our business activities.

COMPLIANCE CULTURE

Compliance commitment

Tone from the top

Compliance responsibility

Code of Conduct & Business Ethics

Integrating compliance in business processes

The ‘Educate & Reinforce’ pillar is Yinson’s Anti-Bribery and Anti-Corruption (“ABAC”) online training programme. Through this programme, Yinson employees are educated on the principles of ABAC Policy & Procedure and the consequences of non-compliance. The ABAC Policy & Procedure was established in 2018, taking into consideration various other anti-bribery legislation such as the UK Bribery Act 2010, and the US Foreign Corrupt Practices Act (“FCPA”). The ABAC Policy & Procedure covers key components such as gifts, hospitality and entertainment, facilitation payments, interactions with government officials, conflict of interests and social responsibilities, sponsorship and donations.

For FYE 2023 under review, a total of approximately 500 employees across our global offices have participated in the ABAC online training programme on bribery and corruption. Additionally, Yinson has also extended the ABAC online training to our vendors as well. Surveys were conducted to assess the effectiveness of the ABAC online training programme and to obtain feedback on areas which requires improvement.

Yinson's Governance, Risk Management and Compliance works closely with key departments of the Group to integrate ABAC compliance into respective departmental processes.

The ‘Identify’ pillar refers to regular reviews of business operations based on Enterprise Risk Management (“ERM”) framework as per the principles of the ISO 31000 standard. Bribery Risk Assessment is a key part of the risk identification and assessment process to ensure that bribery and corruption risks are mitigated.

Since FYE 2021, the Group carried out Bribery Risk Assessments for our Kuala Lumpur and Singapore offices. Workshops and brainstorming sessions were conducted with the key heads of departments. From these sessions, key bribery risks were identified and key control measures were proposed to mitigate these risks. Moving forward, the Group will target to include the Bribery Risk Assessments for our other regional offices as part of the ERM framework.

The Group recognises the importance of adequate financial controls being in place to manage the bribery risk across its business. Such financial controls are designed in a way to ensure that financial transactions are managed properly. This entails that the transactions are recorded accurately, completely and in a transparent and timely manner. Among the financial controls in place are reviewing and updating the segregation of duties, reviewing and updating the authority levels for financial transaction approvals and payments, reviewing chart of accounts to ensure transparent recording of transactions and yearly statutory audits and reporting.

Yinson’s whistleblowing channel is another component of the pillar through which the Group identify and monitor compliance risks closely. As per the established Whistleblowing Policy and Procedure, internal and external parties are given the option of anonymous reporting on possible infringements of the Group’s Policies & Procedures.

The ‘Report’ pillar refers to compliance reporting for all three pillars of the compliance matrix. In the event of proven ABAC infringements or corruption, our ‘ZERO tolerance’ policy applies, whereby sanctions and penalties are imposed on involved employees and third parties.

Compliance business units

How Yinson ensures compliance

  •  
    Yinson employees’ ABAC online training completion rate as of 1st
    July 2021 via the newly rolled out Learning Management System in May 2021

Compliance and ethical conduct is established at the highest level at Yinson. This is evident with Yinson Holdings Berhad and Yinson Production Offshore Pte Ltd Singapore being awarded with the ISO 37001 Anti-Bribery Management Systems ("ABMS") certification by Bureau Veritas in October 2021.

Gaining this accreditation means that these entities have exhibited the commitment to an ethical culture in conducting business; demonstrating that our procedures and processes are in line with the ISO 37001 ABMS standard.

Additionally, being accredited enables these entities to promote confidence to both internal and external stakeholders that a robust ABMS is in place and it has been independently assessed.

Yinson’s compliance framework

At the heart of Compliance in Yinson, it is guided by the Code of Conduct and Business Ethics ("COBE"). Other policies namely Anti-Bribery and Anti-Corruption Policy, Anti-Money Laundering Policy, Whistleblowing Policy and Procedure, Data Privacy Policy and Human and Labour Rights Policy complements the overall approach for the COBE on how Yinson employees conduct themselves at Yinson.

Yinson’s compliance strategy

Our compliance strategy is the approach to provide strategic direction on compliance based on the mapped-out framework above. We intend to embed compliance comprehensively throughout the Group as highlighted below.

  1. Promote deeper integration of compliance into our business process
  2. Continuously optimise our training methodology
  3. Expand targeted communications

We are committed in raising compliance awareness and rolling out compliance-based trainings and communications across the Group and key vendors.

All employees are required to undergo the Anti-Bribery and Anti-Corruption (“ABAC”) online training module and assessment. The online module ensures that all Yinson employees across our global offices have equal access to the same ABAC training and communications. Refresher courses are held annually and are compulsory for all employees. All employees also need to acknowledge the ABAC Policy & Procedure to pledge their commitment and and confirm compliance to the policy.

We manage our vendors through a platform called Vendor Registration Platform (“VRP”). This platform screens potential vendors to ensure they are fully vetted. We have also made it a requirement for our vendors to undergo the ABAC online training module and assessment to ensure that they understand and are aware of Yinson’s ABAC policy and principles. The ABAC online training module and assessment has been implemented into the VRP as part of our efforts to streamline both the training module and assessment under a single procurement platform.

 

We are committed to uphold our stakeholders’ trust by adhering to the highest ethical standards of business conduct and promoting a culture of transparency, integrity and accountability.

If you know, or are aware of any improper conduct (misconduct or criminal offence) being committed, or is about to be committed within Yinson, you may come forward and express these concerns through proper channels without fear of unfair treatment or reprisal.

You may report anonymously but do take note that we may not be able to provide feedback due to the anonymity. Furthermore, proper investigation may prove difficult if the information provided cannot be verified and the Prescribed Officer is unable to obtain further information from the person making the report.

 

BLOW THE WHISTLE AT Click here for whistleblowing form

Alternatively, you may also submit your disclosure through any of the following channels: -

: +60111-662 2738
Department : Yinson’s Governance, Risk Management and Compliance
: [email protected]

*All disclosures will be treated in the strictest confidence

For more information, kindly refer to
Yinson’s Whistleblowing Policy and Procedure.

 
Whistleblowing reporting process
    • 1

    • Whistleblower reports the alleged misconduct in good faith through the whistleblower channel.
    • 2

    • Report what happened, when and where, who are the people involved and give evidence if any. Leave your name, ID number and contact details. Anonymous reporting is allowed.
    • 3

    • Prescribed Officer will take note of the report and launch initial investigation. Whistleblower might be contacted to provide further assistance.
    • 4

    • Prescribed Officer will prepare an Incident Report for the Audit Committee Chairperson for review and to decide upon.
    • 5

    • Audit Committee Chairperson will decide the outcome based on final investigation report.
    • 6

    • Upon completion, Prescribed Officer will communicate the outcome of the investigation to the Whistleblower and the subject of the complaint if particulars were given.

We are committed to respect and uphold all internationally-recognised human rights as relevant to our operations.

The Universal Declaration of Human Rights, as well as the eight core conventions set out by the International Labour Organisation’s (“ILO”) Declaration on Fundamental Principles and Rights at Work highlighted elements that include freedom of association, non-discrimination, anti-forced and anti-child labour, among others. In the entirety of Yinson’s sphere of influence, the company seeks to:

a. Protect or maintain all expressed elements of human rights; as well as,
b. Prevent or mitigate activities that may in any way contribute to the infringements of human rights.

Internally, these goals are supported through the establishment of a system of policies and procedures that, among others, include our Code of Conduct and Business Ethics. We remain steadfast in our position and fully expect all external parties whom we have business relations with, including our business partners, suppliers, and any other affiliated entities to abide by the principles set out within the documents mentioned above.

Please refer to our Human and Labour Rights Policy, and Code of Conduct and Business Ethics Policy and Procedure for more details on our stance and approach towards human rights.

Compliance

In line with our ‘Compliance First’ philosophy, Yinson is committed to paying taxes and fulfilling our tax reporting obligations in compliance with relevant laws and regulations, including the accurate and timely submission of tax returns and other required documents.

In addition to the above, Our Code of Conduct and Business Ethics Policy & Procedure provides guidance for all Yinsonites to perform their jobs with upmost integrity and forms the basis for building a compliance culture throughout the company in perfect cohesion with our corporate culture and core values.


Tax management and governance

Yinson aims to accurately identify tax risk such as changes in tax law and practice at the start of a transaction and on an ongoing basis thereafter. We practice an open culture of information sharing between management and related departments and leverage the expertise and experience of external tax specialists to understand and implement evolving best practices.

In addition to above and as part of our tax risk management framework, we have implemented our Group Tax and Structure Tax Manual which documents all relevant tax processes as well as appropriate reporting lines.


Tax strategy

Yinson's tax strategy for financial year 2022, which have been approved by our senior management, is formulated around meeting the needs of all our stakeholders, including governments, tax authorities and our shareholders. It is imperative for us to maintain Yinson's corporate reputation. We have a low appetite for tax risk and our tax planning aims to support the commercial needs of the business by ensuring that our affairs are carried out in a tax efficient manner whilst remaining compliant with the relevant laws.

In addition to the above, Yinson’s tax strategy also complies with Paragraph 19 and paragraph 20 of Schedule 19 of the United Kingdom Finance Act 2016.


Relationship with tax authorities

We act with honesty, sincerity and full transparency when dealing with any relevant tax authority. Yinson develops relationships with tax authorities via various means by using available methods to obtain tax certainty such as rulings or the use of advanced pricing arrangements.

  • © 2023 Yinson Holdings Berhad 199301004410 (259147-A).
    All rights reserved.
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