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THE STRAITS TRADING COMPANY LIMITED ANNUAL REPORT 2011
REPORT ON
CORPORATE GOVERNANCE
a process for follow-up actions to be taken promptly to minimise unnecessary lapses. Nothing has come to the attention of
the Directors to indicate that any material breakdown in the controls has occurred during the year under review.
The Directors and the Audit Committee, having reviewed the Group’s system of internal controls, including financial, operational
and compliance risks, are of the opinion that, in the absence of any evidence to the contrary, the system of internal controls
in place is adequate in meeting the current scope of the Group’s business operations.
WHISTLEBLOWER POLICY
The Company has a whistle-blowing procedure in place for staff to raise matters of impropriety in confidence. The policy
aims to foster a workplace conducive to open communication regarding the Company’s business practices and to protect
employees from unlawful retaliation and discrimination for the proper disclosing or reporting of illegal or unethical conduct
in good faith.
Complaints may be made to the designated officers by telephone, email or under confidential mail. All cases reported will
be investigated objectively and thoroughly and appropriate action will be taken where warranted. A summary of the reports
received, investigation results and subsequent actions taken will be reported to the Audit Committee on a quarterly basis.
Under certain circumstances, the Audit Committee will be informed, as soon as practicable, of a reported case.
INTERNAL AUDIT (Principle 13)
The Company has an internal audit department that is independent of the activities it audits. The internal auditors report
directly to the Chairman of the Audit Committee on audit matters and to the Executive Chairman on administrative matters.
In discharging its functions, the Audit Committee is provided with adequate resources, has full access to and co-operation
of the Management and the internal auditors, and has full discretion to invite any Director or executive officer to attend its
meetings. All major findings and recommendations are brought to the attention of the Board of Directors.
The Audit Committee reviews and approves the annual internal audit plans and ensures that the internal audit functions are
adequately resourced with competence, and has appropriate standing within the Group to carry out its duties effectively.
COMMUNICATION WITH SHAREHOLDERS (Principle 14)
The Company takes a serious view of maintaining full and adequate disclosure, in a timely manner, of material events and
matters concerning its businesses through SGXNET, public announcements, press releases, circulars to shareholders and
Annual Reports.
In addition, shareholders and the public can access information pertaining to the Company’s businesses, media releases
and other corporate information via its website. The Company’s Corporate Affairs and Communications department also
facilitates effective and unbiased communications with shareholders, analysts, fund managers and the media.