2022 Communication on Progress

City Developments Limited

Published date

June 29, 2022

No. of questions

72

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    CDL's ISR 2022 comprises the Executive Chairman Statement and Group CEO Statement. The Board Sustainability Committee (BSC) has direct advisory supervision on CDL’s sustainability strategy, material ESG issues, work plans, performance targets and sustainability reporting. It convenes meetings at least twice annually to discuss CDL’s sustainability plans and review its performance. Throughout the year, the CSO updates the BSC on CDL’s ESG performance and initiatives, as well as global and local ESG trends through the quarterly sustainability reports and meetings, when necessary.

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    CDL's corporate policies provide guiding principles on business conduct and ethics that all employees and stakeholders across our value chain should practise to support CDL’s commitment to sustainability. To enhance transparency, the corporate policies and guidelines are publicly available on our corporate website (www.cdl.com.sg), dedicated sustainability microsite (www.cdlsustainability.com) and staff intranet.

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    CDL's business principles and practices regarding matters that may have ethical implications are encapsulated in the CDL Code of Business Conduct and Ethics. It communicates CDL’s principles such as honesty, integrity, responsibility and accountability at all organisational levels. Staff are to observe these principles when conducting official business in dealing with customers, suppliers and colleagues. CDL also has a Supplier Code of Conduct that provides comprehensive guiding principles for our vendors and suppliers to comply with CDL’s expectations of ethical standards, including environmental sustainability. Other relevant policies include our Human Rights Policy, Supplier Code of Conduct, Biodiversity Policy, Climate Change Policy, Environmental, Health and Safety (EHS) Policy and Green Building Policy.

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    To achieve effective integration of sustainability throughout CDL, the Chief Sustainability Officer chairs the Sustainability Committee, which comprises members across all departments and operational units. For good corporate governance, all corporate policies are reviewed and approved by our Board of Directors, the relevant board committees and Senior Management. New directors are provided with an onboarding e-manual that includes all our corporate policies for their knowledge and compliance.

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    To achieve effective integration of sustainability throughout CDL, the Chief Sustainability Officer (CSO) chairs the Sustainability Committee, which comprises members across all departments and operational units. The sub-committees are: Environment, Corporate Governance and Fair Operating Practices, Labour Practices and Human Rights, Stakeholder Engagement and Consumer Issues, and Community Involvement and Development. The CSO reports to the Board Sustainability Committee, which then reports to the Board of Directors. In addition, all CDL employees are represented in the EHS Working Committee through their department representatives. Staff can highlight their concerns, including WSH issues, directly to the EHS team. Initiatives and activities planned by this committee are part of a continual process to ensure and promote the health, safety, and well-being of all employees. The committee convenes at least once annually to discuss and review CDL’s approach to health and safety management. The Management Risk Committee surfaces significant risk issues, including corruption, for discussion with the Audit and Risk Committee and the Board, to keep them fully informed in a timely and accurate manner.

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    CDL Group adopts an integrated top-down and bottom-up risk review process that enables systematic identification and prioritisation of all material risks. An integral part of the process towards effective risk management is continuous communication and consultation with internal and external stakeholders. This enables the Group to understand the importance of risk management, to appreciate the decisions that are taken within the Group, and to implement the best policies and practices necessary for the benefit of the Group. Since 2018, CDL has been conducting climate change scenario planning to better understand how different levels of global mean temperature change and socioeconomic development can impact our business. Facilitated by a third-party consultant, CDL also conducted climate change scenario analyses which identified and categorised climate-related risks based on their financial impacts as provided by TCFD. These risks are considered strategic business risks and managed under CDL’s Enterprise Risk Management (ERM) framework. In 2021, close to 100 management and operation staff of CDL Group attended a virtual Corporate Sustainability Workshop on supply chain risks and climate risks conducted by external consultants. The workshop shared findings from two major studies that CDL had completed in 2020 — the Supply Chain Segmentation Study and the second climate change scenario analysis for a 1.5°C warmer scenario. During the workshop, we discussed topics such as migrant and forced labour risks, and raw material sourcing risks, in alignment with international best practices in the construction industry.

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    As per ISR 2022 page 78, In the supply chain segmentation study, environmental and social risks, such as embodied carbon intensity and forced labour, were assessed for CDL's top 100 suppliers and top five building materials procured for our developments. The study helped to strengthen our understanding of potential risk hotspots within the supply chain and improved our supply chain strategy.

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    Our employees and business partners can seek advice and raise concerns in confidence about possible improprieties, relating to accounting, financial reporting, internal controls and auditing matters or other matters, to the CDL Ethics Officer through a dedicated email account, toll-free numbers or by mail, regarding violation of business ethics, serious breaches of Group policies, fraud, corruption, collusion with suppliers/contractors and/or conflicts of interest. Toll-free lines for callers from Singapore, China, Thailand, the UK, and the US are also available. The reporting channels are published on our corporate website and staff intranet. Besides this, the CDL Workplace Anti-Harassment and Anti-Bullying Policy communicate CDL’s stance for all employees to be treated with respect and dignity. The policy also provides guidance on the reporting and investigation processes, including disciplinary action.

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Breaches to human rights, labour rights/decent work and anti-corruption are causes for termination.

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    9

    Male (%)

    78

    Female (%)

    22

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    11

    Above 50 years old (%)

    89

    From minority or vulnerable groups (%)

    0

    Executive (%)

    22

    Independent (%)

    67

    13. Do you produce sustainability reporting according to:

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    CDL's Integrated Sustainability Report 2021 continues to be externally assured to validate the accuracy and reliability of its content. Ernst & Young LLP (EY) was engaged to provide independent reasonable assurance of this Report against the GRI Standards for sustainability reporting and the Construction & Real Estate Sector Supplement and SASB disclosures; and independent limited assurance for CDSB framework (with the exception of Principle 1 on materiality) and TCFD reporting.

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    CDL's 2021 materiality assessment affirms the following human rights-related issues prioritised by our stakeholders: Occupational Health, Safety and Well-being; Diversity and Inclusion; Responsible Supply Chain; Cyber-readiness, Security and Data Privacy; Future-ready Workforce; and Human Rights and Labour Conditions. Ref: ISR 2022, pg

    Commitment

    2. Does the company have a policy commitment in relation to the following human rights issues?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    CDL Human Rights Policy was last reviewed in December 2021. https://cdlsustainability.com/wp-content/uploads/2021/03/CDL-Human-Rights-Policy-web.pdf For Digital Security/privacy specifically, we have a Privacy Policy last reviewed on 19 January 2021.

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    CDL's Privacy Policy is available at https://cdl.com.sg/index.php/privacy-policy

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving human rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of expression

    Digital security / privacy

    Rights of women and/or girls

    Access to culture

    Rights of indigenous peoples

    Free, prior and informed consent

    Rights of refugees and migrants

    Access to water and sanitation

    Optional comment
    https://cdl.com.sg/index.php/privacy-policy Aligned with European Union (“EU”) General Data Protection Regulation.

    Prevention

    3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing /mitigating the risks/impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Information security materials are made available to better educate stakeholders on prevailing risks, especially in the handling of sensitive corporate data. Since 2014, we have implemented a Data Privacy Policy which informs stakeholders on how CDL manages personal data in compliance with the Singapore Personal Data Protection Act (No. 26 of 2012). Customers and business partners can get in touch with our Data Protection Officer by mail, email and phone on matters concerning their personal data with CDL. The Data Privacy Policy is available to the public on our corporate website. Ref: CDL ISR 2022, pg 85.

    4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Information security materials are made available to better educate stakeholders on prevailing risks, especially in the handling of sensitive corporate data. Since 2014, we have implemented a Data Privacy Policy which informs stakeholders on how CDL manages personal data in compliance with the Singapore Personal Data Protection Act (No. 26 of 2012). Customers and business partners can get in touch with our Data Protection Officer by mail, email and phone on matters concerning their personal data with CDL. The Data Privacy Policy is available to the public on our corporate website. Ref: CDL ISR 2022, pg 85.

    5. Who receives training for the following human rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Besides establishing holistic IT governance structures and developing robust detection and mitigation measures to protect CDL’s critical business systems and data, our response plans are tested by internal auditors and an external professional firm and aligned with industry best practices. Given the recent developments in data privacy regulations and the increasing impact of potential data privacy breaches, CDL’s risk assessment framework has identified data privacy as a key risk. As such, CDL has been carrying out various mitigating measures including staff awareness training, as well as the monitoring of local and international data privacy developments that are relevant to our businesses. Ref: ISR 2022, pg 35.

    Response

    7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    In 2021, there were no substantiated complaints concerning breaches of customer privacy, theft, leak and loss of customer data or critical information. Ref: ISR 2022, pg 86

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2021, close to 100 management and operation staff of CDL Group attended a virtual Corporate Sustainability Workshop on supply chain risks and climate risks conducted by external consultants. The workshop shared findings from two major studies that CDL had completed in 2020 — the Supply Chain Segmentation Study and the second climate change scenario analysis for a 1.5°C warmer scenario. During the workshop, we discussed topics such as migrant and forced labour risks, and raw material sourcing risks, in alignment with international best practices in the construction industry. Ref: ISR 2022, pg 78. CDL engages our contractors and suppliers to abide by our fundamental principles and policies such as the Supplier Code of Conduct, Human Rights Policy, and Universal Design Policy. Since 2001, the CDL 5-Star EHS Assessment – an independent audit tool to assess, measure, and improve the main contractors’ EHS management and performance – has been in place to ensure a comprehensive, audited, and appraised approach. To help our workforce adapt to Work From Home arrangements, CDL ensured that our staff were equipped with the knowledge to use digital tools to facilitate effective communication. CDL conducts a biennial employee engagement survey to understand our employees’ concerns and engagement levels, enabling CDL to be an employer of choice. Ref: ISR 2022, pg 36.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    The CDL Human Rights Policy was last reviewed in March 2021.

    Forced labour

    The CDL Human Rights Policy was last reviewed in March 2021.

    Child labour

    The CDL Human Rights Policy was last reviewed in March 2021.

    Non-discrimination in respect of employment and occupation

    The CDL Human Rights Policy was last reviewed in March 2021.

    Occupational safety and health

    The EHS Policy was last reviewed in March 2021.

    Working conditions (wages, working hours)

    The CDL Human Rights Policy was last reviewed in March 2021.

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    This item is part of our human rights policy https://cdlsustainability.com/wp-content/uploads/2021/03/CDL-Human-Rights-Policy-web.pdf and stakeholders/representatives are free to discuss issues with the organization if they deem necessary

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    CDL continues to be recognised as a long-serving bizSAFE Mentor. bizSAFE Mentors are organisations that have demonstrated excellent Workplace Safety Health (WSH) performance and leadership. As a role model, a bizSAFE Mentor shares good practices and nurtures bizSAFE Enterprises in their WSH, guiding them as they progress in the programme. Ref: ISR 2022, pg 87.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    CDL is represented in the Construction Industry Joint Committee in Singapore.

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Since 2001, the CDL 5-Star EHS Assessment – an independent audit tool to assess, measure, and improve the main contractors’ EHS management and performance – has been in place to ensure a comprehensive, audited, and appraised approach. All CDL main contractors undergo quarterly EHS inspections and audits conducted by an independent audit firm recognised by the Ministry of Manpower, and are appraised on a scale of one to five stars. Results are then presented to the management and site supervisors of the contractors and project consultants during the quarterly CDL 5-Star EHS Seminars. These seminars serve as an invaluable platform to promote sharing of best practices and peer learning, which encourages better EHS performance amongst our builders. The collective action with other stakeholders are initiated through the supplier code of conduct https://cdlsustainability.com/wp-content/uploads/2021/02/CDL-Supplier-Code-of-Conduct.pdf

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    All employees are made aware of these labor rights issues through the annual refresher of the human rights and EHS policy. Contractors are communicated on these requirements in our contractor code of conduct https://cdlsustainability.com/wp-content/uploads/2021/02/CDL-Supplier-Code-of-Conduct.pdf

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    CDL respects all employees’ fundamental rights to freedom of association and the right to be members of trade unions. Although CDL is not a unionised company, we are guided by the Industrial Relations Act which allows trade unions to represent our employees for collective bargaining, providing our employees with an avenue to seek redress for disputes. Our key subsidiaries Millennium & Copthorne Hotels Limited (M&C), CBM Pte Ltd and The Tower Club have staff who are trade union members, providing them with a channel for collective bargaining.

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    Optional comment
    CDL respects all employees’ fundamental rights to freedom of association and the right to be members of trade unions. Although CDL is not a unionised company, we are guided by the Industrial Relations Act which allows trade unions to represent our employees for collective bargaining, providing our employees with an avenue to seek redress for disputes. Our key subsidiaries Millennium & Copthorne Hotels Limited (M&C), CBM Pte Ltd and The Tower Club have staff who are trade union members, providing them with a channel for collective bargaining. Ref: ISR 2022, pg 96.

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    Optional comment
    CDL respects all employees’ fundamental rights to freedom of association and the right to be members of trade unions. Although CDL is not a unionised company, we are guided by the Industrial Relations Act which allows trade unions to represent our employees for collective bargaining, providing our employees with an avenue to seek redress for disputes. Our key subsidiaries Millennium & Copthorne Hotels Limited (M&C), CBM Pte Ltd and The Tower Club have staff who are trade union members, providing them with a channel for collective bargaining. Ref: ISR 2022, pg 96.

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    47

    Non-executive board

    29
    Optional comment
    Refer to ISR 2022, pg 94 for gender breakdown of Heads of Departments at CDL's Corporate Office. Out of 7 non-executive board members, two (29%) are females (Mrs Wong Ai Ai and Carol Fong).

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    93.6
    Optional comment
    CDL discloses the gender pay gap across executive, non-management and management employee categories. The average of these three were calculated for this question. Refer to ISR 2022 pg 96 for details on CDL's disclosures on gender pay gap.

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0
    Optional comment
    There were zero injuries at the CDL Corporate Office in 2021. At our Managed Properties, Lost-Time Injury Frequency Rate (number of lost-time injuries per million manhours worked) was 6.76. For our Construction Site, the Lost-Time Injury Frequency Rate was 0.92. Refer to ISR 2022, pg 88-91 for more details.

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0
    Optional comment
    There were zero injuries at the CDL Corporate Office in 2021. At our Managed Properties, Lost-Time Injury Frequency Rate (number of lost time injuries per million manhours worked) was 6.76. For our Construction Site, the Lost-Time Injury Frequency Rate was 0.92. Refer to ISR 2022, pg 88-91 for more details.

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    There were no incidents of breach to these risks, hence no remedy was involved.

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    The CDL Workplace Anti-Harassment and Anti-Bullying Policy communicate CDL’s stance for all employees to be treated with respect and dignity. No employee shall be subject to any physical, psychological, verbal or sexual abuse. Our employees should be culturally sensitive, tolerant and respectful towards one another at all times. This policy also extends to dealing with incidents involving external customers and stakeholders who conduct themselves in a manner that constitutes harassment of the employees, within and beyond company premises. In 2021, CDL had one incident of discrimination. Swift and thorough investigation and rectifications were taken to resolve the matter. To reinforce our firm stance on anti-harassment and anti-bullying, a compulsory workshop on professional workplace boundaries was launched in January 2021 for all staff, including a session for management focusing on their roles as managers. Ref: ISR 2022, pg 95.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    CDL's Climate Change Policy was last reviewed in December 2019.

    Water

    CDL's EHS Policy was last review in March 2021.

    Oceans

    Not applicable to the Singapore real estate industry. There are existing strict regulations on water discharge into water bodies.

    Forests / Biodiversity / Land Use

    CDL's Biodiversity Policy was first rolled out in 2020.

    Air Pollution

    CDL's EHS Policy was last review in March 2021.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    CDL's EHS Policy was last review in March 2021.

    Energy & Resource Use

    This is encapsulated in CDL's Green Building Policy (last update: Feb 2021), EHS Policy (last update: Mar 2021), Climate Change Policy (last update: Dec 2019).

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    CDL's ESG polices and commitments can be found in https://cdlsustainability.com/over-20-years-of-value-creation/corporate-policies-and-esg-commitments/

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Ocean - pioneering work with public education and ocean bound plastics. We also have a Green Gallery Exhibition focused on this topic and other sustainability related topics https://cdlsustainability.com/sdg-stakeholder-partnerships/cdl-green-gallery/change-the-present-save-the-ocean-climate-action-exhibition/

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Advocacy

    Water

    Oceans

    Advocacy

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Established in 2017, the CDL Future Value 2030 Sustainability Blueprint sets out our strategic ESG goals. Our key 2030 and interim annual goals, targets and progress are tracked and reported quarterly and annually. In December 2021, CDL successfully raised the carbon reduction targets that were assessed and validated by the SBTi, aligned with a 1.5°C warmer scenario. The revised targets also support CDL’s World Green Building Council’s (WorldGBC) Net Zero Carbon Buildings Commitment. In December 2021, CDL commenced our third study to include relevant climate-related impacts of COVID-19 and key COP26 outcomes, building on the previous studies. The findings will be based on latest7 research and scenario analysis from IPCC, IEA, the Network for Greening the Financial System (NGFS), World Bank and other relevant climate science datasets.

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Under the CDL Future Value 2030 Sustainability Blueprint, CDL pledged to achieve science-based target of reducing carbon emissions intensity by 59% from 2007 levels by 2030 (Intensity figures were calculated based on per unit net lettable floor area). The interim annual target for 2021 was 42% reduction. In December 2021, we successfully raised the carbon reduction targets to 63% that were assessed and validated by the SBTi, aligned with a 1.5°C warmer scenario. The revised targets also support CDL’s World Green Building Council’s (WorldGBC) Net Zero Carbon Buildings Commitment. Total carbon emissions intensity reduction in 2021 is based on our previous baseline year of 2007 as CDL’s renewed SBTi targets were validated in December 2021. CDL will start reporting carbon emissions intensity reduction rates based on the new 2016 baseline year from 2022 onwards.

    Energy & Resource Use

    Under the CDL Future Value 2030 Sustainability Blueprint, CDL pledged the following 2030 and interim annual targets. Asset Management (AM) – Office & Industrial - Reduce energy use intensity by 45% from 2007 levels by 2030 (2021 target: 37% reduction) - Reduce water use intensity by 50% from 2007 levels by 2030 (2021 target: 43.5% reduction) - Reduce waste intensity by 16% from 2016 levels (2021 target: 14% reduction) Asset Management (AM) – Retail - Reduce energy use intensity by 18% from 2010 levels by 2030 (2021 target: 18% reduction) - Reduce water use intensity by 9% from 2010 levels by 2030 (2021 target: 8% reduction) - Reduce waste intensity by 12% from 2016 levels (2021 target: 10.7% reduction) Corporate Office - Reduce energy use intensity by 31% from 2007 levels by 2030 (2021 target: 29% reduction) Property Development (PD) - Achieve an energy use intensity of 95 kWh/m2 by 2030 (2021 target: ≤105 kWh/m2) - Achieve a water use intensity of 1.54m3/m2 by 2030 (2021 target: ≤1.75 m3/m2) - Achieve a waste intensity of 40 kg/m2 by 2030 (2021 target: ≤50kg/m2) - Reduce embodied carbon of building materials by 24% compared to their conventional equivalents by 2030 (2021 target: 7% reduction for new projects awarded from 2018 onwards)

    Water

    Under FV2030 as noted in our ISR 2022, our 2021 annual targets are to reduce water use intensity by 43.5% from 2007 (Office and Industrial), 8% from 2010 (Retails), <1.75 m3/m2 (Property Development)

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Under FV2030 goals as noted in our ISR 2022, our 2021 targets are 14% reduction in waste intensity from 2016 (office and Industrial), 10.7% (retail) and <50 kg/m2 (Property Development)

    Oceans

    Optional comment
    Refer to ISR 2022, pg 22-23 for the environmental targets under the CDL Future Value 2030 Sustainability Blueprint.

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    Optional comment
    Established in 2017, the CDL Future Value 2030 Sustainability Blueprint sets goals for our integrated sustainability strategy towards 2030 – a milestone year for UN SDGs and the net zero climate agenda. Since July 2017, we have also been voluntarily publishing an online quarterly sustainability report that updates stakeholders of our progress towards key goals and targets that are set under the CDL Future Value 2030 Sustainability Blueprint. In addition, the Board Sustainability Committee convenes meetings at least twice annually to discuss CDL’s sustainability plans and review its ESG performance, including progress of the targets set under the CDL Future Value 2030 Sustainability Blueprint.

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    There was no requirements for any remedial actions

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    2645

    Scope 2 Emissions

    Emissions (tCO2e)

    12640

    Scope 3 Emissions

    Emissions (tCO2e)

    6199
    Optional comment
    For Scope 2 Emission, Market Based GHG emission is 11906 tCO2e. The above GHG emissions cover CDL Corporate office, Managed Buildings and Construction Sites

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    0.3
    Optional comment
    R&D cost was 6,926,395 vs total revenue of 2,625,853,000

    8. Has the organization acted to support climate change adaptation and resilience?

    Optional comment
    In December 2021, CDL commenced our third study to include relevant climate-related impacts of COVID-19 and key COP26 outcomes, building on the previous studies. The findings will be based on latest7 research and scenario analysis from IPCC, IEA, the Network for Greening the Financial System (NGFS), World Bank and other relevant climate science datasets.

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    4.17
    Optional comment
    This value includes Renewable energy generated on site (69889 kWh) plus purchased RECs (1800 mWh)

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    86.5
    Made up of Investment Properties and Development Properties

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    345

    Groundwater:

    Surface water:

    293

    Rainwater:

    Wastewater:

    52

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    100

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    345

    Groundwater:

    Included into surface water as no specified breakdown

    Surface water:

    293

    Rainwater:

    Included into surface water as no specified breakdown

    Wastewater:

    52

    Percentage of water consumed in regions with high or extremely high water stress (%)

    100
    Optional comment
    We consider surface water as seawater and hence include seawater into the sum for surface water. For reference, seawater is 122 Megaliters and water from other surface sources is 171 Megaliters

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    1.05
    Optional comment
    As we do not measure water use per revenue, we will provide water use per floor area (m3 of water/m2 of floor area) for CDL operations (Corporate, Managed Buildings, Construction sites). As Singapore is considered to be highly water stressed, all water utilized for operations will be accounted into the intensity As per ISR 2022, the specific water intensity (m3/m2) for Corporate office is 0.36, Office is 0.4, Retail is 2.0, Industrial is 0.2, Construction site is 1.5

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    0

    Hectares

    None of our sites are located next to protected areas
    Optional comment
    None of our sites are located next to protected areas noted in ISR 2022 page 81

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    0
    Optional comment
    There were no areas converted within the reported period

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    - CDL bought 250 VCS credits which covers 17 Hectares of the REDD+ Project for Caribbean Guatemala: the conservation coast Project. - CDL bought 750 VCS credits which covers 44 Hectares of the The Kasigau Corridor REDD Project - Phase II The Community Ranches Project.

    Other ecosystem restoration

    Reforestation

    - DL bought 750 VCS credits which covers 155 Hectares of the Qianxinan Afforestation Project in Guizhou Province Project. - CDL bought 500 VCS credits which covers 172 Hectares of the Guinan Afforestation Project.

    Natural regeneration

    - CDL bought 700 VCS credits which covers 338 Hectares of the Cordillera Azul National Park REDD Project.

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    - CDL bought 550 VCS credits which covers 9 Hectares of the Rimba Raya Biodiversity Reserve Project. - CDL bought 750 VCS credits which covers 65 Hectares of the Evio Kuiñaji Ese´Eja Cuana, To Mitigate Climate Change, Madre de Dios – Perú Project.

    Other (please specify in text box)

    Optional comment
    Community Wide Outreach: CDL bought a total of 750 VCS credits which covers 111 Hectares of the Kariba REDD+ Project.

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    15138
    Optional comment
    As per ISR 2022 page 76

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    0
    Optional comment
    As per ISR page 74, CDL generates negligible hazardous waste from our operations

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Single-use plastics is not a raw material of CDL operations
    Optional comment
    Single-use plastic is not part of the raw material used by CDL

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In December 2021, we successfully raised the carbon reduction targets that were assessed and validated by the SBTi, aligned with a 1.5°C warmer scenario. In November 2021, CDL was the only Singapore real estate company amongst 19 pioneering companies invited to Climate Impact X’s pilot auction. Climate Impact X is a partnership by SGX, DBS, Standard Chartered and Temasek to provide a global exchange and marketplace for companies to access high-quality carbon credits. Through the auction, we successfully secured carbon credits from eight global natural climate solutions projects. These credits will be utilised over the next three years to offset an estimated 6% to 7% of emissions from our operations per year to complement CDL’s net zero targets by 2030. We also commenced our third climate change scenario study, considering COP26 outcomes and the impact of COVID-19 In 2021, CDL partnered with ALBA E-waste Smart Recycling to set up e-waste bins at City Square Mall and Quayside Isle, to collect regulated consumer electrical and electronic waste across Singapore for proper treatment and recycling. Other CDL developments are being considered for pilot trials. In 2021, we updated our 3S Green Building Framework to align with the latest BCA Green Mark 2021, an internationally recognised green building certification scheme, to stay focused on advancing our commitment to sustainability. The revised framework also includes net-zero targets such as embodied carbon management, to guide our stakeholders to adopt sustainable building practices such as low embodied carbon materials. In December 2021, we rolled out our Sustainable Investment Principles (SIP). This reinforces CDL’s commitment in taking proactive action in assessing potential portfolio risks and opportunities for sustainable investment decisions. In 2021, CDL partnered with a social enterprise, Seven Clean Seas (SCS), to certify 11 Tampines Concourse, one of our commercial properties, under the Ocean Bound Plastic (OBP) Neutrality Certification. The novel certification programme aims to encourage OBP recycling by compensating the plastic footprint of companies via neutralisation certificates (i.e. plastic credits), which are used by organisations, like SCS, to collect and treat non-recyclable OBP waste. All these alongside our year on year consistent pursuit for energy, water, and waste efficiencies continue to guide the company towards prevention and/or remediation of impact to the environment

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    The CDL Anti-corruption Policy was last reviewed in August 2012.
    Optional comment
    This sets out the responsibilities of the Group companies and of each employee in observing and upholding CDL’s position against all forms of corruption, bribery and extortion. The Anti-Corruption Policy also provides information and guidance to employees on how to recognise, address, resolve, avoid and prevent instances of corruption, bribery and extortion which may arise in the course of their work. In line with this commitment to maintain high ethical standards which are integral to our corporate identity and our business, it is CDL’s policy to adopt a ‘zero-tolerance’ approach against all forms of corruption, bribery and extortion. Ref: https://ir.cdl.com.sg/static-files/9e9b11d4-a103-4190-8ecc-aaed8b0dbbf2

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    CDL's Conflict of Interest Guidelines (available in our staff intranet) prevents any unjustified appointment of vendors and reduce possible suggestions that unethical actions were taken by employees due to their relationship with an external vendor. Refer to ISR 2022, pg 84.

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    Annually, all our full- and part-time employees are required to complete a compulsory online declaration to acknowledge that they are aware of, have read, and are in compliance with CDL’s corporate policies and guidelines before the start of the calendar year. Awareness bulletins are published on CDL’s intranet for a quick refresher anytime on key elements of CDL’s stance against corruption. Fraud risk awareness training and assessments covering topics such as bribery and conflicts of interest were also conducted for selected front-line business units. New hires, as part of their orientation programme, are required to learn about CDL’s Code of Business Conduct and Ethics, as well as other related corporate policies including Anti-Corruption, Fraud, Competition, and Whistleblowing. They are also required to complete a self-paced, interactive e-learning module (accessible for all employees as well) that provides information and guidance to recognise, address, resolve, avoid, and prevent instances of corruption. In 2021, 100% of our new hires were educated with anti-corruption knowledge. Ref: ISR 2022, pg 86.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    Annually, all our full- and part-time employees are required to complete a compulsory online declaration to acknowledge that they are aware of, have read, and are in compliance with CDL’s corporate policies and guidelines before the start of the calendar year. Awareness bulletins are published on CDL’s intranet for a quick refresher anytime on key elements of CDL’s stance against corruption. Fraud risk awareness training and assessments covering topics such as bribery and conflicts of interest were also conducted for selected front-line business units. New hires, as part of their orientation programme, are required to learn about CDL’s Code of Business Conduct and Ethics, as well as other related corporate policies including Anti-Corruption, Fraud, Competition, and Whistleblowing. They are also required to complete a self-paced, interactive e-learning module (accessible for all employees as well) that provides information and guidance to recognise, address, resolve, avoid, and prevent instances of corruption. In 2021, 100% of our new hires were educated with anti-corruption knowledge. Ref: ISR 2022, pg 86.

    4. Does the company monitor its anti-corruption compliance programme?

    Optional comment
    The line managers of respective business and support functions are accountable and responsible for implementing and executing effective controls to manage the risks arising from their business activities. This includes establishing adequate managerial and supervisory controls to ensure compliance with policies, risk appetite, threshold limits and effective risk controls, and to highlight gaps, the inadequacy of processes and unexpected risk events. Whistle-blowing Procedure - Our employees and business partners can seek advice and raise concerns in confidence about possible improprieties, relating to accounting, financial reporting, internal controls and auditing matters or other matters, to the CDL Ethics Officer through a dedicated email account, toll-free numbers or by mail, regarding violation of business ethics, serious breaches of Group policies, fraud, corruption, collusion with suppliers/contractors and/or conflicts of interest. Toll-free lines for callers from Singapore, China, Thailand, the UK, and the US are also available. The reporting channels are published on our corporate website and staff intranet. The ARC has overall authority and oversight of the Whistleblowing Policy, which is administered with the assistance of the Head of Internal Audit. Procedures are in place for independent investigation and for appropriate follow-up actions to be taken. Any improprieties involving the Head of Internal Audit (also the CDL Ethics Officer) may be reported to the Chairman of the ARC. (Ref: ISR 2022, pg 85)

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    As of 31 December 2021, there were zero incidents of corruption, fraud, and money laundering activity across CDL’s business operations wholly-owned and directly-managed by CDL's headquarters in Singapore.

    Confirmed during the current year, and related to this year

    0
    As of 31 December 2021, there were zero incidents of corruption, fraud, and money laundering activity across CDL’s business operations wholly-owned and directly-managed by CDL's headquarters in Singapore. (Ref: ISR 2022, pg 85)

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    During the year, the Group’s Enterprise Risk Management (ERM) function implemented several initiatives targeted at strengthening risk management practices which are key elements to our risk management framework. Some of the notable initiatives include: • Conducting customised compliance training sessions covering anti-money laundering / counter-terrorism financing, cyber threat and data privacy, to raise the level of awareness and understanding, as well as improve the capabilities of our first line of defence against such risks. • Enhancing data handling and protection policies, and using technology tools to improve processes to ensure policy enforcement. • Completing a Group-wide risk transfer strategy review, which involves reviewing the Group’s key risk exposures and optimising our global insurance structure for coverage consistency to achieve economies of scale. • Updating the control self-assessment programme, with the assessment targeting risk drivers of identified key risks, to facilitate early identification of control gaps and areas for improvement. • Proactive monitoring of developments related to the impact of the COVID-19 outbreak and adjusting our business continuity plans and measures accordingly to minimise any operational disruptions. (Ref: AR 2021, pg 57)