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Introduction

Business ethics is relevant to the conduct of individuals and also to the conduct of the organization as a whole. As such, Hotel Royal Limited ("Royal") is committed to maintaining strong ethical standards in all its business activities. The importance of the continued success of the company lies on us, as employees, to behave with honesty, integrity and in compliance with all applicable legal and regulatory requirements.

This policy is put in place to all Royal staff to set out the fundamental standards. All employees are to adhere to this policy in their everyday actions to safeguard the business including our own reputation. Behaving with responsibility and with complete honesty will earn the trust and confidence of one another, our customers and suppliers, our shareholders and the communities in which we serve.


Responsibilities of all Employees

These procedures and standards in the conduct of the Company's business are to be maintained by all employees. The company must handle, in a manner consistent with these standards and related policies, all actual and apparent conflicts of interest among personal and professional relationships and all other matters governed by this Code and such related policies.

Managers must ensure all their employees are aware of this policy and their responsibilities to act in accordance with this policy and that failure to do so will be viewed as a serious disciplinary issue.


Reporting Procedures

In the event when you are made aware of any possible infringement of the standards set out in this policy, you must disclose the facts promptly to your line manager, your HR representative or General Manager of your hotel, who will ensure the matter is investigated and the appropriate action is taken place.

A report can be made outside your line management in the event if you feel your concern will not be taken seriously, or because it involves your work place.

The confidential whistle-blowing reporting procedures are put in place in each of the Group's regional operations. The procedures include the details on how to make a report. In case of doubt on how to make the confidential report, please send an email to whistleblowing@hotelroyal.com.sg.


February 2015