GIL is committed to conducting its business in accordance with all applicable laws, rules and regulations and the highest ethical standards, and this commitment is embodied in its Code of Conduct. The purpose of this Policy is to reiterate GIL’s commitment to full compliance by the company, its subsidiaries and affiliates, and its officers, directors, employees and agents with the Prevention of Corruption Act (Cap 241) and any applicable anti-bribery or anti-corruption laws.

This Policy applies to all executive and non-executive directors, officers, and employees (collectively “Officers”) of GIL.


Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage. Bribery and corruption can take many forms, including the provision or acceptance of:

  1. Improper influence or special treatment;
  2. Cash payments;
  3. Phony jobs or “consulting” relationships;
  4. Kickbacks;
  5. Political contributions;
  6. Charitable contributions; or
  7. Gifts, travel, hospitality, and reimbursement of expenses.

GIL personnel and agents are strictly prohibited from offering, paying, promising, or authorising:

any corrupt payment or other thing of value to any person directly or indirectly through or to a third party for the purpose of: (i.e., in exchange for);

  • causing the person to act or fail to act in violation of a legal duty;
  • causing the person to abuse or misuse their position; or
  • securing an improper advantage, contract or concession;

for or on behalf of GIL or its Manager.

(“Improper Payment Activity”)

To promote compliance with anti-corruption laws in Singapore and other applicable jurisdictions, no GIL personnel shall undertake any Improper Payment Activity in respect of a foreign official, a domestic official, or a person doing business in the private sector.

Dealing with Third Party Representatives

When interacting with third parties, GIL personnel are expected to clearly communicate GIL’s zero tolerance approach towards corruption. Third parties also have an obligation to ensure that subcontractors understand and comply with this policy and applicable anti-corruption laws. GIL may be liable for the actions of third parties who offer or give something of value to benefit GIL’s business.

This may include the payment of commissions or fees to intermediaries who are engaged in promoting GIL’s business. GIL personnel should remain alert for the following red flags when dealing with third parties and subcontractors:

  1. a third party who has a reputation for offering or accepting bribes;
  2. a third party who provides minimal detail on invoices or expense claims, or lump-sum requests (particularly for people who interact with the government);
  3. a third party who requests for advanced or unreasonably large commissions or payments, or that payments be made through a intermediaries, or via another country; and
  4. a third party who insists on using a specific consultant or one who provides little or no obvious added value.

If any GIL personnel become aware of any of these red flags, they should seek the Board’s approval before continuing with the transaction with the said third party.