The standard we are held to.
Deltara sits between international principals and Southeast Asia's industrial buyers. Both sides are entitled to know exactly how this company conducts itself. Our Code of Business Conduct is that answer, in writing.
An operating standard, not a statement of aspiration.
The distributors with genuine market access in this region rarely meet institutional compliance standards, and those that meet the standards rarely have the access. Deltara exists to be both. Our Code is the written half of that promise — the part a principal, a bank or a regulator can hold us to.
It binds every person who acts in Deltara's name, and it is enforced. Where a commercial opportunity and the Code cannot both be satisfied, the opportunity is declined. Deltara has declined business on this basis and will do so again.
We are a young company and a deliberately small one. That is not a reason to hold a lower standard — it is the reason to hold a higher one. A firm of our size cannot absorb a compliance failure, and a principal appointing us is lending us its name in this region.
We apply the stricter standard, not the local one.
Deltara applies these regimes to all of its dealings — whether or not a particular statute governs the transaction in front of us. Where local law, a principal’s supplier code or a customer’s procurement policy sets a higher standard, the higher standard applies.
Bribery Act 2010
Applied in full to every Deltara dealing, including the failure-to-prevent standard for associated persons.
Foreign Corrupt Practices Act
Applied to all dealings, with State-owned enterprise staff treated as public officials throughout.
Prevention of Corruption Act
The governing anti-corruption law of our jurisdiction of incorporation, alongside the PDPA 2012.
Vietnam anti-corruption law
Applied across our principal operating market, in addition to the international regimes above.
Thirteen obligations. No discretionary ones.
The Code binds every director, officer and employee of Deltara; every collaborator, commission agent and contractor engaged by it; and every third party appointed to act in Deltara’s name.
- 01Bribery and corruption — including public officials and State-owned enterprises, facilitation payments, and gifts, hospitality and entertainment.
- 02Agents, intermediaries and third parties — risk-proportionate due diligence, written contracts, audit rights and fees matched to service performed.
- 03Sanctions and trade restrictions — UN, Singapore, United States, European Union and United Kingdom regimes.
- 04End use, export control and customs — end-user and end-use established and recorded for every consignment.
- 05Money laundering and counterparty due diligence — know-your-customer clearance before any payment is made or received.
- 06Accurate books and records — Singapore Financial Reporting Standards; no off-book funds, accounts or assets.
- 07Product stewardship and safety documentation — principals’ technical and safety documentation is never altered or selectively presented.
- 08Confidential information — information barriers between competing principals; PDPA 2012 and applicable Vietnamese law.
- 09Conflicts of interest — prompt written disclosure; a conflict involving the Managing Director goes to the Board.
- 10Fair competition — no arrangement on price, terms, the division of markets, or the manipulation of a tender.
- 11Political activity, charitable giving and the media — no political contribution of any kind, in any jurisdiction.
- 12Our people — no forced, bonded, indentured, prison or child labour; freely chosen employment; merit-based decisions.
- 13Speaking up — two reporting channels, anonymous reports accepted, and no retaliation in any form.
The controls that actually govern a transaction.
State-owned customers
A significant share of Deltara’s customers are enterprises owned or controlled by the State. Their directors, procurement officers, plant managers, engineers and technical evaluators are treated as public officials in everything we do — whether or not they hold any government post.
Nothing of value may be offered to any of them, or to a member of their family, without the prior written approval of the Managing Director. Cash and cash equivalents may never be offered, in any amount, with or without approval.
Facilitation payments
Prohibited absolutely. There is no approval route and no exception. Demurrage, storage cost, a missed vessel and local practice are not reasons.
Where a person is threatened with harm or unlawful detention, their safety comes first: pay, then tell the Managing Director within twenty-four hours so the payment is recorded for exactly what it was and disclosed to any affected principal.
Gifts and hospitality
Modest and occasional business courtesy is acceptable between commercial parties. It stops being acceptable when it is connected to a pending decision, tender or negotiation.
Any gift or hospitality worth more than S$200 per recipient per year requires prior written approval. Cash, cash equivalents, vouchers and loans are never permitted. Every approval and refusal is recorded in a register open to any principal on request.
Counterparties and payment
Every counterparty and its known owners are screened before the first transaction and periodically afterwards. If a counterparty becomes designated mid-transaction, the transaction stops.
Payment is made to the party that supplied the goods, into an account in that party’s name, in the country where it is incorporated or performs. Deltara does not make or accept cash payment for commercial transactions.
Named people, not a process.
Deltara does not operate a compliance department, and the Code does not pretend otherwise. Accountability sits with named individuals instead.
- i.The Board of Directors owns the Code and reviews it at least annually, and on any material change to Deltara’s business or regulatory exposure.
- ii.The Managing Director is accountable for the Code and holds the approval, disclosure and gift registers.
- iii.The Country Director (Singapore) holds the governance function of the Singapore entity and operates the alternative reporting channel.
- iv.Records kept under the Code — approvals, disclosures, screening results and investigation files — are retained for seven years.
- v.Those records are made available to a principal, auditor or regulator on request.
Raise a concern.
The Code works only if people raise concerns early, and only if they are safe doing it. Anyone — inside Deltara or outside it — may use either channel. Reports may be made in Vietnamese or in English, and anonymous reports are accepted and acted on.
The primary channel for any breach or suspected breach of the Code.
Use this channel where the concern involves the Managing Director, or simply where you would rather not go to him. It is not accessible to the Managing Director.
Deltara does not tolerate retaliation in any form against a person who raises a concern in good faith or assists an investigation — no dismissal, no reduction in commission, no removal from an account, no quiet sidelining. Retaliation is gross misconduct in its own right. That protection holds even if the concern turns out, on investigation, to be mistaken.
Assessing Deltara as a distribution partner?
We respond to compliance questionnaires, supplier-code confirmations and counterparty due diligence requests directly. Tell us what your onboarding requires.
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