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
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.
The ‘Educate & Reinforce’ pillar is Yinson’s Anti-Bribery and Anti-Corruption (“ABAC”) training programme. Through this programme, Yinson employees are educated on the principles of ABAC Policy and the consequences of non-compliance. The ABAC Policy 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 Policy 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 2021 under review, a total of approximately 425 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 include our registered suppliers and vendors as well as key business partners. Surveys are also conducted to assess the effectiveness of the ABAC online training programme and to obtain feedback on areas which require 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.
For FYE2021, 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 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 Group policies.
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.
Yinson’s compliance framework
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.
We are committed in raising compliance awareness and rolling out compliance-based training and communication across the Group and key third parties.
All employees are required to undergo an online ABAC 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.
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. We are currently migrating the online ABAC training module and assessment to the VRP as part of our efforts to streamline the vendors' ABAC training under a single procurement platform.
As of 1st January 2021, one vendor has been terminated due to Anti-Bribery Management System (“ABMS”) Violations.
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.
Alternatively, you may also submit your disclosure through any of the following channels: -
: +60111-662 2738Department : Yinson’s Governance, Risk Management and Compliance : [email protected]
*All disclosures will be treated in the strictest confidence
For more information, kindly refer toYinson’s Whistleblowing Policy and Procedure.
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 asb. 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.
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