Page 116 - Annual Report 2014

Whistle Blowing Policy
StarHub takes a zero tolerance stance towards fraud and ethical
violations. As such, the Group has instituted a robust procedure for and the Corporate Gift and Hospitality Policy are available on both
the purpose of providing third parties and employees with accessible StarHub’s intranet and corporate website for easy access.
channels for reporting suspected fraud, corruption, financial
impropriety, unethical conduct and other criminal or dishonest
practices. Such channels include the employees’ immediate
supervisors, the relevant Heads of Department or the Head of
Human Resource (as may be appropriate), as well as the AC.
The Investigation Committee (constituting representatives
from the Senior Management) will investigate the suspected
wrongdoing and implement rectification and prevention
measures. Any personnel with a conflict of interest (actual or
potential) will be barred from appointment to the Investigation
Committee. All cases of wrongdoing will also be reported to and
reviewed by the AC.
In cases of suspected wrongdoing involving the CEO and/or CFO,
the Investigation Committee will be chaired by the AC Chairman
(or his nominee). Upon completing the investigations for each
case of suspected wrongdoing, the Investigation Committee may
at its discretion decide whether to circulate the findings of the
investigations to all employees, taking into account the interests
of the Group.
The Group’s whistle-blowing policy aims to encourage the
reporting of such matters in good faith, by lending confidence
that whistle-blowers will be treated fairly and accorded with
protection against reprisals. StarHub will take disciplinary action
against any party who victimises whistle-blowers. Further,
StarHub does not disregard anonymous complaints but will give
such complaints appropriate weight. The Group’s whistle-blowing
policy is available on StarHub’s intranet and corporate website for
easy access by all employees and members of the public.
Employee Code of Conduct and Rules on
Business Conduct
To guide employees in carrying out their duties and
responsibilities with high standards of personal and corporate
integrity when dealing with StarHub, its competitors, customers,
suppliers and the community, StarHub has the following in place:
• StarHub’s Employee Code of Conduct;
• Ethics Policy;
• Corporate Gift and Hospitality Policy; and
• Supplier and Vendor Policy.
StarHub’s Employee Code of Conduct, the Ethics Policy and the
Corporate Gift and Hospitality Policy cover business conduct
(including employees’ compliance with anti-corruption and anti-
bribery laws), conduct in the workplace, protection of StarHub’s
assets, proprietary and confidential information and intellectual
property, conflict of interest, non-solicitation of customers and
employees, and workplace health and safety. In parallel, the
Supplier and Vendor Policy covers internal controls on tenders,
vendor selection and purchasing to ensure transparency,
objectivity and compliance.
StarHub Ltd | Annual Report 2014
The Employee Code of Conduct and the Supplier and Vendor Overview
Policy are available on StarHub’s intranet, while the Ethics Policy
Strategy
Performance
Compliance Leave Policy
StarHub has a Compliance Leave Policy which applies to Governance
employees who hold Senior Manager position and above, finance
advocates and employees with sensitive job functions such as Financials
handling monies, inventories, payroll processing and approvals,
risk management and purchasing of goods and services. Under
the Compliance Leave Policy, such employees are required to go
on mandatory block leave of at least five consecutive working
days each calendar year. This arrangement allows covering
officers to fully step into the duties of the employee on leave, as
an additional check and balance against any breaches. This is
an additional risk mitigation measure voluntarily put in place to
enhance governance.
Document Classification Policy
StarHub has a document classification policy to guide employees
in their handling of information and documents relating to the
Group’s business, activities and operations. Such information and
documents are required to be classified as “Confidential”, “For
Internal Use” or “For Public Distribution”. This classification helps
to safeguard the information and documents, ensures that only
appropriate persons have access to that information and that
access is on a need-to-know basis only.
Strategic Business Continuity
Management (BCM)
StarHub was the first Info-Communications company in Singapore
to be successfully certified to Singapore Standards SS540: 2008
for Business Continuity Management (BCM) in May 2011. In May
2014, StarHub successfully converted to ISO 22301:2013 which
is the ISO standard for BCM. StarHub’s BCM program focuses
on Info-Communications Network, Infrastructure and Support
Services for Mobile, Television, Broadband and Fixed. The BCM
program is also supplemented by Pandemic Plan, Haze Response
Plan and Crisis Communication Plans to ensure StarHub is able to
address different crisis situations.
Security Measures for Data Protection
In addition to the Laptop Encryption Solution, StarHub has
implemented Mobile Device Management (MDM) to ensure
commercially sensitive and confidential corporate emails and
information accessed by employees using their mobile devices
are protected. In the event an employee’s mobile device is
lost or stolen, MDM will remove corporate data stored on the
mobile device by performing a remote factory reset. Both the
Laptop Encryption Solution and the MDM enhance the security
of StarHub’s commercially sensitive and confidential corporate
data accessed through or stored on such mobile devices and
laptops by employees. On an on-going basis, StarHub continually
evaluates new technologies which may further enhance the
security of its confidential and sensitive information. StarHub
has put in place a comprehensive Personal Data Protection
compliance program to ensure compliance with the law.
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