The standard governing every transaction.
The Code of Business Conduct binds Deltara, its personnel and those who act on its behalf, in every market and on every transaction. It is approved and issued by the Board of Directors.
Binding, not aspirational.
Compliance with the Code is a condition of employment or engagement. Where applicable law, a Principal's supplier code or a customer's procurement policy imposes a stricter requirement, the stricter requirement prevails.
Controls are applied on a risk-based basis, proportionate to the nature and complexity of the Company's activities. Proportionality governs the depth of due diligence and the extent of documentation required. It does not qualify any prohibition expressed as absolute.
Defined authority at every level of the Code.
Board of Directors
Adopts the Code, approves any amendment, and reviews it annually and upon material change to the Company’s risk profile.
Compliance Function
Holds the registers, grants the approvals reserved under the Code, conducts counterparty screening, and reports to the Board.
Country Director (Singapore)
Independent reporting channel, not accessible to the Managing Director. Escalates to the Board where warranted.
State-Owned Enterprises
Officers and employees of a State-Owned Enterprise are treated as Government Officials, whether or not they hold a governmental post.
Governing statutes, applied as a minimum.
Prevention of Corruption Act 1960
Applied with the Personal Data Protection Act 2012 in the jurisdiction of incorporation.
Law on Anti-Corruption 2018
Applied across the principal operating market.
Foreign Corrupt Practices Act
Applied to all dealings as a minimum standard, irrespective of governing law.
Bribery Act 2010
Applied in full, including to Business Partners constituting associated persons.
The control framework has been designed having regard to the guidance on adequate procedures issued under the UK Bribery Act 2010, the principles of ISO 37001:2016 and the recommendations of the Financial Action Task Force.
The Company makes no representation that it holds certification under any of those standards.
Reporting channels.
Reports may be made in Vietnamese or in English. Anonymous reports are accepted and acted upon. Retaliation against a person who reports in good faith is prohibited, whether or not the matter is substantiated.
Primary channel for any breach or suspected breach of the Code.
Independent channel, for matters concerning the Managing Director. Not accessible to him.
Documents and disclosure.
The Code and the records maintained under it — approvals, conflict disclosures, screening results and reports — are made available to a Principal, auditor or regulatory authority on request. The Company responds directly to compliance questionnaires and supplier-code confirmations.