1. Code of Conduct
We have a clear set of standards and principles incorporated in our Code of Conduct (the “Code”). The Code provides the foundation for establishing a corporate culture of high integrity, both real and perceived, and sets out our expectations for legal and ethical behaviour for all employees. It not only outlines the legal responsibilities and ethical tone for the expected behaviour of all employees but also guides daily interactions with fellow employees, customers, vendors, government officials and business partners.
2. Anti-corruption
NagaCorp has zero tolerance for involvement in corruption or bribery activities of any kind. Our Anti-corruption Policy reinforces the Code and provides additional guidance regarding compliance with laws and regulations related to bribery and corruption. We also published the Anti-corruption Handbook to help our employees and subsidiaries achieve a better understanding of corruption, how to avoid it, and what to do when confronted with it.
We are sensitive to the risks of unsuitable associations and the need to comply with legal and regulatory requirements. Due diligence is conducted to avoid impropriety and even the appearance of impropriety by employees engaged in business dealings.
In 2022, 89% of our employees completed the annual anti-corruption training. Conducted online in English and Khmer on our Learning Management System, the contents of the training covered NagaCorp’s zero-tolerance stance on corruption, various acts of corruption (e.g. bribery, extortion, fraud, collusion, money laundering and other related offences), legal penalties and reporting mechanisms.
During 2022, no legal case regarding corruption was brought against the Company or our employees.
3. Whistle-blowing
Employees, suppliers and other business partners can report potential allegations anonymously through email or made in person to the Head of Internal Audit.
Whistleblowing reports are reviewed, and investigated promptly. Reported matters of significance are referred to the Audit Committee for further assessment, and the next course of appropriate action.
4. Anti-money Laundering
Internal controls on Anti-money Laundering (“AML”) are firmly in place to ensure that we maintain a high standard for compliance and integrity. The Board reviews and assesses the adequacy and effectiveness of the Group’s internal control system on AML through the AML Oversight Committee and the reports from an independent AML specialist firm.
The AML Oversight Committee formulates the development and implementation of AML programmes’ policies and strategies, ensures quality control, and oversees AML matters.
To ensure a high standard for compliance and integrity on AML, we established a programme designed to protect our reputation and mitigate AML risks. The programme is underpinned by a four-tier AML control structure comprising a Management Committee, Board Oversight Committee, periodical internal audits and regular review by an external auditor.
To the best of the knowledge, information and belief of the Directors, neither NagaCorp nor our employees are subject to any actual, pending or threatened cases regarding any corrupt practice or any allegation of unethical practice during the Year.