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ANTI-CORRUPTION POLICY

 

 

At Spire Events, we have several fundamental principles and values which we believe are the foundation of sound and fair business practice, including a zero tolerance position in relation to corruption, wherever and in whatever form that may be encountered. This page is to clearly state the standards and principles required to ensure conformance to legal requirements within the countries in which our company operate.

 

Legal Obligation

 

It is our policy to comply with all laws, rules and regulations governing anti bribery and corruption law, in all the countries in which we operate. We take our legal obligations in this area very seriously. 

We believe it is a fundamental principle of good business practice to respect local laws and customs when operating internationally. However, as Spire Events is incorporated in Singapore, we are bound by the laws of Singapore, which governs our conduct both at home and abroad.

 

Under Singapore’s Prevention of Corruption Act: 

 

  • Corruption in Singapore is broadly defined as a bribe offered in return for a favour. The bribe can be in the form of monetary or non-monetary nature

  • A person convicted of bribery and corruption shall be liable to a fine not exceeding $100,000 or to imprisonment for a term not exceeding 5 years or to both, for each count of corruption

  • Singapore has extra-territorial powers to deal with corrupt acts committed by a Singapore citizen outside Singapore as though these were committed in Singapore.

 

We are required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

 

Anti-Corruption Policy

 

Our Anti-Corruption Policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with Spire Events. 

 

Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for ourselves or another party.

 

No bribes of any sort may be paid to or accepted from customers, suppliers, politicians, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions. Charitable contributions must not be used as a way of concealing a bribe. When dealing with Public Officials, employees will refrain from providing any Gifts or Business Entertainment without the prior written approval of the Managing Director.

 

This policy does not prohibit the following practices providing they are customary in a particular market, or are proportionate and are properly recorded:

  • Normal and appropriate hospitality (given or received)

  • The giving of a small gift on a festival or at another special time

 

We recognise that market practice varies across the international arena in which we operate and what is normal and acceptable in one place may not be in another. We also appreciate that to refuse a gift in certain circumstances and/or countries may cause offence to our trading partners. The test to be applied in all circumstances is whether the gift or entertainment is reasonable, justifiable and not lavish. Special care must be taken in accepting or giving gifts and/or entertainment and these are not permitted if it would create a real or perceived conflict of interest.

 

Working with Third Parties

 

Our expectations on vendors and suppliers, contractors and other parties with whom Spire Events does business are also set out in contractual documents.  We do not condone the action of, nor do we wish to be held liable for, any of our third parties who may have acted in a corrupt manner or in a manner inconsistent with our Anti-Corruption Policy, whilst acting for us, whether with or without our knowledge. Accordingly, the necessary requisite and proper due diligence of all third parties representing us or providing services to us, is undertaken before we engage such third parties. These third parties should also undertake not to engage in any form of bribery or corruption. A violation of this Policy by any third party with which we contract or otherwise do business will lead to termination of any contractual arrangements.

 

Our Expectations

 

The prevention, detection and reporting of bribery and corruption is the responsibility of all of our employees. If anyone is in doubt as to whether a potential act constitutes bribery/corruption, the matter should be referred to a member of our leadership team. If you are an external party and wish to raise any concerns, please contact us here and a representative of Spire Events will follow-up any matters raised in confidence.

 

As a Singapore based Singapore, Spire Events is committed to upholding Singapore's reputation as a country that is clean, honest and trustworthy, and one which emphasises the highest levels of integrity and incorruptibility.

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