SUSTAINABILITY & GOVERNANCE 106 Whistle Blowing Policy Our Approach TheManagershave inplaceacomprehensivewhistleblowing policy that sets out the procedure for employees, directors as well as third parties to raise any concerns on possible improprieties in confidence and good faith without any fear of reprisals. The whistleblowing policy is incorporated into all new employees’ orientation training and is publicly accessible on CDLHT’s website. Any concerns raised will be independently investigated and appropriate actions will be taken as necessary. Moreover, all our hotels maintain an open-door policy through their human resource departments, providing employees with a safe and open channel to report any incidences of non-compliance or violations. The Managers’ ARCs maintain oversight and review of whistleblowing incidents at its scheduled meetings, to ensure continuous monitoring and accountability. Our Performance There were zero incidences of whistleblowing complaints received via CDLHT’s whistleblowing channels in FY 2023. Anti-bribery And Code of Conduct Our Approach CDLHT upholds a zero-tolerance stance against bribery, corruption, or fraud. The Managers are committed to conducting business with integrity and adherence to all relevant laws and regulations. To further strengthen this commitment, CDLHT has implemented comprehensive policies and guidelines to provide direction to all employees of the Managers, maintaining the highest standards of integrity in their work and business dealings. There is also an Internal Code of Business and Ethical Conduct, alongside a Business Hospitality and Gifts Policy, that outlines the proper protocols for handling gifts (monetary or in kind), entertainment or concessionary offerings. Furthermore, all employees of the Managers undergo refresher training sessions periodically to re-acquaint themselves with anti-corruption policies and procedures. Our Performance The Managers strive to maintain zero incidences of corruption, bribery and misconduct. In FY 2023, there were no such incidences reported. We continuously conduct training sessions on relevant policies as part of the orientation for new hires, and keep our employees informed of any development to applicable policies and regulations. Compliance With Social And Environmental Regulations As an organisation with a global portfolio, CDLHT is conscious of remaining compliant with all the social and environmental regulations applicable within the countries in which we operate. Our Approach We vigilantly monitor changes to requirements through monthly interaction with our hotel operating partners in each country. This process allows us to ensure that each asset adheres to local and national regulations, and promotes responsible and lawful operations. Our Performance In FY 2023, CDLHT had zero incidences of non-compliance with social and environmental laws, and no significant fines and sanctions. CDLHT aims to maintain zero incidences of non-compliance with social and environmental laws and regulations, mitigating the risk of substantial fines and sanctions. Data Privacy And Protection Our Approach The Managers have implemented a Data Protection Handbook in place to safeguard personal data processed, adhering to relevant legal requirements outlined in the Personal Data Protection Act and the Securities and Futures Act in Singapore. Furthermore, all lessees and hotel managers diligently comply with local data and privacy laws within their respective jurisdictions. Our Performance In FY 2023, there were no complaints received by the Data Protection Officer on data privacy breaches. The portfolio properties will continue to maintain its best practices in data protection measures, both within our operations in Singapore and overseas. Safe and Liveable Buildings At CDLHT, we understand that developing infrastructure that positively influences our occupants, is a crucial step towards creating a liveable city. We are committed to delivering high standards of building safety and ensuring the comfort of our guests, visitors and tenants. Liveable buildings also directly contribute to the quality and service reputation at our hotel assets, and quality of spaces and tenant satisfaction at our commercial assets. Our buildings are equipped with amenities that provide universal and family-friendly accessibility to our building facilities. Our Approach The Manager ensures that buildings comply with their respective regulations and best practices on building safety, accessibility, and liveability. For our assets in Singapore, the Managers ensure that the buildings comply with BCA’s Code on Accessibility in the built environment and where requirements are not met, to retrofit the buildings as expediently as practical. SUSTAINABILITY REPORT
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