Legal & Compliance
ADRA PTE. LTD. is committed to the highest standards of integrity, transparency, and regulatory compliance in all our business operations.
ADRA Anti-Bribery & Corruption Compliance Policy and Code of Conduct
1. Purpose
ADRA PTE. LTD. is committed to conducting business with integrity, transparency, and in compliance with all applicable anti-bribery and anti-corruption laws and regulations. This Policy sets out our zero-tolerance stance on bribery and corruption and applies to all employees, suppliers, contractors, agents, customers, and business partners.
2. Scope
This Policy applies globally to:
Covered Parties
- All employees, directors, and officers of ADRA PTE. LTD.
- All third parties acting on behalf of the Company (agents, intermediaries, consultants).
- All suppliers, customers, and joint venture partners.
3. Definitions
Key Terms
- Bribery is the offering, giving, receiving, or soliciting of anything of value to improperly influence a business or government decision.
- Corruption includes bribery but also extends to abuse of entrusted power for private gain.
- Facilitation Payments are unofficial payments made to secure or expedite routine government actions — these are strictly prohibited.
4. Prohibited Conduct
4.1 Employees, Suppliers, and Customers Must Not:
- Offer, give, request, or accept bribes or kickbacks in any form.
- Provide or accept gifts, hospitality, or entertainment that may influence business decisions.
- Make facilitation payments, regardless of local customs or practices.
- Use third parties to indirectly engage in corrupt practices.
- Conceal or disguise payments or transactions in accounting records.
5. Gifts and Hospitality
Allowed if they are:
- Infrequent, reasonable in value, and for legitimate business purposes.
- Not intended to influence or appear to influence decisions.
Not Allowed if they:
- Are lavish, frequent, or cash-equivalent.
- Involve government officials without proper due diligence and approvals.
6. Third Party Due Diligence
Before entering into any agreement or relationship with third parties (agents, brokers, distributors, suppliers, or consultants), the Company will conduct comprehensive due diligence to ensure compliance with this policy and applicable laws.
7. Political Contributions and Charitable Donations
Requirements:
- Must not be used to gain an improper business advantage.
- Require prior written approval from Compliance or Senior Management.
- Must be transparent, properly recorded, and lawful under applicable laws.
8. Record Keeping
Documentation Requirements:
- All payments and transactions must be accurately and transparently recorded in the Company's books and records.
- No off-book accounts or false entries are permitted.
- All records must be maintained in accordance with applicable retention policies.
9. Reporting Concerns
Employees and third parties are encouraged to report any suspected bribery or corruption through designated channels. All reports will be investigated confidentially and without retaliation.
Reporting Channels:
- Direct email to compliance@adra.sg
- Anonymous reporting via our secure compliance hotline
- Direct communication with the Chief Compliance Officer
10. Compliance and Disciplinary Action
Violations of this Policy may lead to:
- Disciplinary action (including termination).
- Civil or criminal liability.
- Termination of contracts with suppliers or customers.
- Regulatory sanctions and penalties.
Questions About This Policy?
Contact our compliance team for clarification or reporting concerns.