Corporate Governance

THE BUSINESS SUSTAINABILITY POLICY

The FLS Group is committed to develop sustainable business in harmony with the environment and society throughout the business value chain in accordance with the expectations of stakeholders, the principles of the United Nations Global Compact (UNGC, refer: https://unglobalcompact.org), Sustainable Development Goals (UN SDGs, refer: https://www.undp.org/sustainable-development-goals), and other international standards.

The FLS Group has announced its Business Sustainability Policy, to cover the topic of sustainability of current business operations, group companies and further businesses both domestically and abroad. 

In order to fulfill the above commitments, the FLS Group shall,

1. Comply with all applicable laws and regulations in all countries in which we operate, including follow international practices and guidelines.

2.Conduct business in an economically, socially, and environmentally sustainable manner. Including maintaining a balance of interests of various groups of stakeholders. To ensure that the business will grow sustainably.

3.Raise awareness of business sustainability policies and promote sustainable practices among business partners. To increase business sustainability throughout the value chain.

4.Promote the continuous development of innovation and technology for the benefit of the environment and sustainable society.

5.Follow the principles of corporate citizenship and contribute to improving the well-being of communities by leveraging FLS Group’s logistics expertise to promote sustainability for all.

6.Reveal policy Management guidelines and operating results, as well as being a role model for creating a sustainable business culture.

    The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

    All FLS Group executives and employees are responsible for understanding, participating in, driving, and implementing the Business Sustainability Policy and Framework.

    CORPORATE COMPLIANCE POLICY

    FLS Group has established this Corporate Compliance Policy to enable the businesses of FLS Group to comply with applicable laws and regulations of within country and other countries, achieve acceptance from various stakeholders, and avert risks arising from non-compliance with laws and regulations by its managements and employees. 

    1. Antitrust and Competition Law, while advocating free and fair business competition without discrimination or taking advantage of others,

    2. Anti-corruption and Anti-bribery Law involving public and private sectors worldwide,

    3. Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Law,

    4. Legislation on labor, human rights, human dignity, and respect for the freedom and equality of those granted protection,

    5. Intellectual Property Laws, while respecting others’ intellectual property rights, promoting works regarded as intellectual property rights, and safeguarding FLS Group’s intellectual property rights against infringement,

    6. Anti-Strategic Litigation Against Public Participation (Anti-SLAPP),

    7. Applicable laws and regulations in all countries related to FLS Group and its subsidiaries’ businesses where the office is located, including the country where the FLS Group is operating its activities, and

    8. FLS Group’s various policies, including standards, code of conduct, operating guidelines or manuals and actions regarded as proper for FLS Group and subsidiaries, although it has not been explicitly covered by this policy.

      To achieve objectives and goals of this policy. FLS Group Executives are responsible for following good practice, as an example. All employees must be aware of and follow this example.

      The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

      ANTI-CORRUPTION and ANTI-BRIBERY POLICY

      The FLS Group is committed to conducting its business in compliance with laws against corruption and bribery involving government officials and private sectors both domestically and internationally. Violating these laws is inappropriate and inconsistent with the Corporate Compliance policy. The executives and employees at all levels must be aware of the effects of all forms of corruption and must resist and refrain from such acts.

      The FLS Group, therefore, has established the Anti-Corruption and Anti-Bribery policy in accordance with the Ethics and the Business Code of Conduct of the Company, the measures of the Office of the National Anti-Corruption Commission, the United Nations Convention against Corruption (UNCAC, refer: https://www.unodc.org/unodc/en/corruption/uncac.html ), the U.S. Foreign Corrupt Practices Act (FCPA, refer: https://www.justice.gov/criminal/criminal-fraud/foreign-corrupt-practices-act ) and the UK Bribery Act:2010 (UKBA:2010, refer: https://www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance.pdf ), including the other laws related to preventing and combating the corruptions.

      Whereas, FLS Group has determined the practice guidance as follows:

      1. The executives and employees of the company and outsource parties who were hired to carry out activities on behalf of the company, in all regions or countries in which the Company operates, must have a duty to comply the Anti-Corruption and Anti-Bribery policy, Ethics and Business Code of Conduct. Including national/international anti-corruption and anti-bribery laws.

      2. Do not get involved in any form of corruption or present anything with the intention of corruption. Including giving or receiving bribes to/from the company’s stakeholders. This shall include any actions through the work duties of personnel that are performed under their responsibility, whether directly or indirectly, in order to gain benefits for the organization, employees, or related persons.

      3. Do not neglect or ignore any act that can be considered corruption related to the company.
      This is the duty of the employees to report such subjects to the board of directors or authorized committee, as well as fully cooperate with any investigation that may follow.

      4. In conducting business that may cause corruption. Company employees must strictly adhere to the following instructions:

      a. Offering or receiving a gift, entertainment or any expenses must be complied with good practices in the Ethics and Business Code of Conduct, and the requirements of this policy.

      b. Donations on behalf of a company that aims to benefit society. The receiving organization must be legitimate and trustworthy. Donations must be complied with the company guidelines, meet the objectives, transparent, and there is no issue of bribery.

      c. Any operations in regard to business relations, procurement, the contacts with officials in both public and private sectors, and the stakeholders of the company either within or outside the country, must be carried out in a transparent and honest manner in accordance with applicable laws. 

      d. FLS Group has a neutral political policy. Each employee has legal political rights and freedoms. However, they must be aware that they must not use company resources for any political activities that may affect the neutrality of the company or be held liable for participating in or supporting such politics.

      5. The executives and employees of the company and outsource parties who were hired to carry out activities on behalf of the company, in all regions or countries in which the Company operates, must have a duty to comply the Anti-Corruption and Anti-Bribery policy, Ethics and Business Code of Conduct. Including national/international anti-corruption and anti-bribery laws.

      6. Do not get involved in any form of corruption or present anything with the intention of corruption. Including giving or receiving bribes to/from the company’s stakeholders. This shall include any actions through the work duties of personnel that are performed under their responsibility, whether directly or indirectly, in order to gain benefits for the organization, employees, or related persons.

      7. Do not neglect or ignore any act that can be considered corruption related to the company.

      8. In conducting business that may cause corruption. Company employees must strictly adhere to the following instructions

        PRIVACY POLICY

        The FLS Group fully respects the privacy rights of the stakeholders and other related parties Therefore, the FLS Group has established The Privacy policy as a guideline to ensure that the company has appropriate mechanisms, regulatory measures, and personal information management in place, to protect and act in accordance with relevant the Personal Data Protection Act (PDPA).

        Definition

        Personal DataAny information relating to an individual which enables that individual identity, whether directly or indirectly. But it does not include information about the specific person who has passed away.
        Sensitive Personal DataAny information that is legally classified as sensitive personal data under the Personal Data Protection Act (PDPA), such as race or ethnicity, political opinions, ideologies, religious or philosophical beliefs, sexual behavior, criminal history, health information, disability information, union information, genetic information, and biometric data, including information that may affect the data owner in the same way.
        Closed-Circuit Television (CCTV)Television systems used for basic safety and security monitoring, and do not broadcast the signal to the public.

        Personal Data

        1. Collection of the Personal Data

              The Company will collect personal information, whether directly or indirectly, from the data owner or other sources than the data from the owner, in accordance with the lawful purposes, scope, and methods, whereas,

              • The Company collects personal information for Company purposes only and must be within the scope of the law.
              • The Company must inform the necessary personal information details of the data owner, as required by law.
                • The company must obtain written consent from the data owner whether in electronic or other form.
                • Where the Company collects the Sensitive Personal Data, the Company must request for consent from the data owner in writing prior to the collection, unless the collection of Sensitive Personal Data can rely on an exception under the Personal Data Protection Act or other laws.

              The Company may need to collect Personal Data for the performance of a contract, to enter into a contract, or for compliance with laws, including fulfilling the purpose of the company.

              Refusal to provide the necessary Personal Data may result in the inability to perform a contract, enter into a contract with the data owner, comply with the laws which the company is subjected, and/or inability to fulfil the purpose for the collection, use, and disclosure Personal Data.

              2. Purpose of the Collection or Use of Personal Data

                The Company collects or uses personal information the purpose of business only, such as procurement, contracting, financial transactions, activities in the company, coordination or to improve the operations, such as creating a database, analyzing, and developing the company’s business, including other purposes that are not prohibited by law or regulations related to the Company’s business.

                The Company maintains and uses Personal Data only as necessary to fulfill the purposes notified to the data owner, or as required by law.

                The company will not act other than as specified in the purpose of collecting the Personal Data, except

                a. The data owner is informed of the new purpose and accepts the new consent notice.

                b. The Company is required to comply with the Personal Data Protection Act or related laws.

                  3. Personal Data Storage and Retention Period

                    The company may store Personal Data in hard copies and/or electronic formats. 

                    Personal Data will be stored only as necessary to fulfil the purposes of the collection, use, and disclosure of Personal Data.

                    The retention period is relying on a legal basis to collect, use, and/or disclose such Personal data, or specified period by law, or permitted by laws or as long as the company has the right.

                    4. Personal Data Protection Measures

                      The Company has established Personal Data Security Measures in accordance with laws, regulations, rules, and guidelines regarding the protection of personal information of the Company’s stakeholders. Including supporting and promoting employees to have knowledge and awareness of their duties and responsibilities in collecting, using, and disclosing Personal Data.

                      All employees must be aware of compliance with the Privacy Policy, to promote effective legal compliance.

                      CLOSED-CIRCUIT TELEVISION (CCTV)

                      1. Collection of the personal data by CCTV

                        The company has installed CCTV cameras for safety and security and may record Personal Data of employees and other people while the CCTV is operating. This includes any photo and/or video format. Therefore, the Company is responsible for taking care of Personal Data in accordance with the requirements of this policy.

                        2. Purpose of the Collection or Use of Personal Data

                          The Company collects, uses, and discloses Personal Data for the following purposes:

                          • To control access to buildings and premises and to observe, prevent, protect and (if necessary) investigate unauthorized entry into buildings and premises. 
                          • To take care of safety around the company’s buildings and premises.
                          • To maintain the safety of life and property of employees, customers, contractors and business partners, visitors, as well as property in the possession of the company.
                          • To control access to and secure the Company’s information technology resources and databases.
                          • To inspect, investigate, and manage complaints within the company, such as in cases where employees are bullied or harassed.
                          • Safety during work time.
                          • To inspect and investigate the facts in the event of an incident occurring in the company.

                          3. Personal Data Storage and Retention Period

                            Personal Data is recorded in electronic format and limited for accessing. The retention period does not exceed 14 days from the date of recording, the image records by the CCTV will be deleted after expired automatically.

                            4. Security Measures

                              The Company has adequate and strict security measures to protect Personal Data from access, use, change, modification, loss, delete, and to prohibit unauthorized or illegal use of Personal Data.

                              However, the HSE manager assigned by the company can access recorded CCTV images to monitor the operation of the CCTV system.

                              The Company limits access to the CCTV system at high-level, which is password protected, and Personal Data cannot be accessed without permission from the HSE manager or the Board of Directors.

                              Disclosure of Personal data

                              The Company may disclose the Personal Data as the data owner consents.

                              The Company also may be required to disclose the Personal Data to affiliated companies or other parties located in the country or abroad, such as the service providers related Personal Data for the benefit of the Company’s operations or providing services to the data owner.

                              In disclosing Personal Data to such parties, the company is responsible to ensure that those parties maintain the confidentiality of the Personal Data and will not use Personal Data for the purpose other than the company specified.

                              In addition, the Company may disclose Personal Data as required by law, such as disclosure to government agencies or regulatory agencies. This includes cases where there is a request to disclose Personal Data as permitted by laws, such as a request to disclose information for legal proceedings, or requests from private organizations or third parties related to legal proceedings, and/or the Company is required to disclose such Personal Data by laws.

                              Rights of Data Owner

                              The data subject has the following rights:

                              1. Withdraw consent to collect, use and/or disclose Personal Data. Whereas the withdrawal of this consent will not affect the collection, use, or disclosure of Personal Data for which consent was previously obtained.

                              2. Access and obtain a copy of Personal Data, including the right to request the disclosure of acquisition of Personal Data obtained without consent.

                              3. Rectifying, deleting, restricting the use, transferring, and processing of Personal Data.

                              4. Make a complaint to the Human Resources Department (HRD), which is the custodian of Personal Data.

                                Contact channels

                                Enquires or questions on the Personal Data Protection can be addressed to the following channels,

                                FLS Holding Pte Ltd.

                                Vision Exchange, 2 Venture Drive

                                #08-01, Singapore 608526

                                Website: fls-group.com   

                                The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

                                All FLS Group executives and employees are responsible for understanding, participating in, driving, and implementing the Privacy Policy.

                                THE QUALITY, OCCUPATIONAL HEALTH, SAFETY, SECURITY and ENVIRONMENTAL POLICY

                                FLS Group operates the logistics business with expertise in all modes of cargo logistics, including handling, transportation, yard, warehousing, and chartering, both domestic and overseas. Especially, FLS Group is capable of handling and transporting the project cargo and heavy lift. 

                                FLS Group is committed to continuously improving the efficiency and effectiveness of its operations, in terms of quality, occupational health, safety, security, and the environment to be able to,

                                • Ensure that the FLS Group has the ability and efficiency to meet customer expectations and requirements.
                                • Take care of and encourage the company’s personnel, stakeholders and people in the community are healthy, safe, and secure.
                                • Ensure that the property of our customers, companies, employees, contractors, and nearby communities is protected and secure.
                                • Take care and preserve the environment as well as not creating an impact on the ecosystem and neighboring communities.

                                To achieve the objectives of this policy, the FLS Group shall,

                                1. Conduct the company’s business and activities in accordance with laws, regulations, and requirements related to the management system of quality, occupational health, safety, security, environment, and business sustainability. Including customer requirements, standards, regulations, and specific requirements related to the businesses.

                                2. Establish business plans in accordance with customer expectations, including the related laws, regulations, and other requirements. To ensure that operations can meet expectations with quality, safety, and without impact on the environment.

                                3. Implement total quality management systems, organizational know-how and continuously improves the efficiency of our core processes and support processes. To achieve the expectation and enhance satisfaction of the customers.

                                4. Carry out risk management,

                                a. Loss of business opportunities that may be caused by internal or external factors.,

                                b. Hazards that may affect the health, safety, and security of persons and property both inside and outside, and

                                c. Environmental aspects that may arise from the FLS Group’s business operations, which affect the environment, ecosystem, and the community, as well as promote the appropriate and efficient use of resources. To reduce the loss of resources

                                5. Recognize security threats and establish guidelines for emergency management to protect people, property, information, and business sustainability of the FLS Group.

                                6. Provide and maintain safe and secure workplace for the personnel and other related parties, as well as being able to prevent important issues that may affect the environment, ecosystems, and communities. 

                                7. Promote and support all employees to comply with policies, procedures, and achieve key performance indicators. As well as having a feedback system for developing processes and procedures. This will lead to complete integration of policies throughout the organization.

                                  The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

                                  All FLS Group executives and employees are responsible for understanding, participating in, driving, and implementing the Quality, Health, Safety, Security and Environment Policy.

                                  ALCOHOL and SUBSTANCE ABUSE POLICY

                                  The FLS Group recognizes that employees having alcohol, drugs or substance abuse in their system may impair their work performance, and may have serious consequences for oneself, Co-workers and companies, other parties, and possibly the community.

                                  The Company has developed an ALCOHOL and SUBSTANCE ABUSE POLICY that describes the effects of alcohol and drug use in the workplace. This policy is based on the belief that a drug and alcohol-free work environment is good for health, safer and more efficient for all employees and others. This policy complies with applicable law. Including local laws that may be more stringent.

                                  To achieve this policy, the company is committed to managing, administrating, and controlling employees and contractors.

                                  1. Do not use, sell, buy, produce, or possess narcotic drugs or drug paraphernalia while on duties, in the company areas or while operating machinery, equipment, or vehicles owned or rented by the Company.

                                  2. Do not possess, serve, consume, or be under the influence of alcohol while on duties, in the company areas or while operating machinery, equipment, or vehicles owned or rented by the Company.

                                    The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

                                    All FLS Group executives and employees are responsible for understanding, participating in, driving, and implementing the Alcohol and Substance Abuse Policy.

                                    The policy is effective from onwards.

                                    Torbjörn Larisch

                                    Chief Executive Officer

                                    FLS Holding Pte Ltd.

                                    1 January 2024