Anti-Bribery & Anti-Corruption

Ethical business conduct across every relationship.

ENGIC is committed to conducting business lawfully, ethically, transparently, and responsibly, including in accordance with Singapore's Prevention of Corruption Act 1960 and other anti-bribery laws that apply to a transaction or person.

We do not tolerate bribery, corruption, facilitation payments, kickbacks, improper commissions, false invoices, hidden incentives, sham arrangements, document falsification, or any other improper conduct intended to win, retain, influence, or reward business.

This position applies across ENGIC's work in engineering, procurement, industrial supply, manufacturing coordination, documentation and inspection support, asset management, maintenance, modification, operations, partnerships, supplier relationships, investor discussions, and project execution.

ENGIC expects employees, directors, suppliers, manufacturers, distributors, subcontractors, agents, consultants, inspection agencies, logistics providers, partners, investors, and other counterparties to act with integrity and comply with applicable anti-bribery and anti-corruption laws.

Effective: 23 September 2026
Last reviewed: 23 September 2026
Primary jurisdiction: Singapore

Our position

No commercial opportunity is worth improper conduct.

ENGIC's position is clear:

"We do not pay, request, accept, authorise, conceal, or facilitate bribes or improper advantages."

We expect all business to be won and performed based on capability, quality, technical fit, commercial competitiveness, compliance, delivery performance, and responsible conduct.

ENGIC may decline, suspend, terminate, or report any engagement where bribery, corruption, improper influence, document manipulation, or unethical conduct is suspected.

Scope

This policy applies to all ENGIC-related business activity, including:

→Client engagement
→Procurement
→Supplier selection
→Manufacturer coordination
→Tendering
→Quotation
→Project execution
→Inspection and certification
→Logistics and customs
→Partner relationships
→Investor discussions
→Vendor registration
→Pre-qualification
→Recruitment
→Gifts and hospitality
→Agents, consultants, and intermediaries
→Public-sector and government-linked interactions
→Private-sector commercial transactions

Prohibited conduct

ENGIC does not support or tolerate:

→Bribes
→Kickbacks
→Facilitation payments
→Secret commissions
→Hidden rebates
→Improper gifts or hospitality
→Improper political or charitable contributions
→False invoices
→Inflated invoices
→Sham consulting arrangements
→Improper referral payments
→Payments to influence inspection, certification, customs, or approvals
→Payments to win or retain business improperly
→Undisclosed conflicts of interest
→Misuse of agents or intermediaries
→Document falsification
→Certificate manipulation
→False origin declarations
→Any arrangement designed to conceal improper benefit

Gifts, hospitality & business courtesies

Modest, transparent, and legitimate only.

ENGIC recognises that reasonable business courtesies may occur in some commercial environments. However, gifts, meals, hospitality, travel, entertainment, sponsorships, or similar benefits must never be used to improperly influence a decision.

ENGIC does not permit gifts, hospitality, or benefits that create improper influence, reputational risk, conflict of interest, or appearance of corruption.

Any gift or hospitality connected to ENGIC business must be:

→Lawful
→Modest
→Transparent
→Infrequent
→Properly recorded where required
→Reasonable in value
→Connected to a legitimate business purpose
→Not intended to influence a decision improperly
→Not offered during sensitive tender or procurement decisions where inappropriate
→Not in cash or cash equivalents

Public officials & government-linked entities

Higher risk requires higher caution.

ENGIC may work in markets where projects involve public-sector entities, government-linked companies, state-owned enterprises, regulators, customs authorities, port authorities, utilities, certification bodies, or approval agencies.

Interactions involving public officials or government-linked entities require particular care.

ENGIC does not permit improper payments, gifts, benefits, facilitation payments, or inducements to influence public officials, regulators, customs officers, inspectors, project authorities, or public-sector decision-makers.

Singapore law can apply outside Singapore to acts by Singapore citizens. Location, local custom, a third-party intermediary, or a small payment does not remove the need for review and approval.

Suppliers, partners, agents & intermediaries

Responsible conduct across the supply chain.

ENGIC expects suppliers, manufacturers, distributors, agents, consultants, subcontractors, inspection agencies, logistics providers, and partners to conduct business ethically and transparently.

Third parties must not be used to do anything that ENGIC would not do directly.

ENGIC may review or reject third parties based on:

→Ownership and control information
→Reputation and adverse conduct risk
→Anti-bribery and anti-corruption position
→Trade compliance suitability
→Documentation integrity
→Conflict-of-interest concerns
→Unusual payment requests
→Relationship to client or public officials
→Commercial justification for fees or commissions

Red flags

ENGIC may investigate, reject, or escalate situations involving:

→Requests for cash payments
→Requests for payments to unrelated third parties
→Unusual commissions or success fees
→Vague consulting arrangements
→Refusal to provide company or ownership information
→Refusal to document services properly
→Requests to alter invoices or documents
→Requests to hide beneficial ownership
→Requests to influence inspection or certification
→Requests to bypass procurement rules
→Unusual urgency without clear justification
→Close personal relationship with a decision-maker
→Poor reputation or adverse media
→Lack of relevant capability for the proposed role

Accurate records

No false invoices or hidden arrangements.

ENGIC requires accurate books, records, invoices, certificates, commercial documents, and project records.

Accurate records are part of ethical business conduct and project trust.

We do not support:

→False invoices
→Misleading descriptions
→Undisclosed commissions
→Off-book payments
→Altered documents
→False certificates
→Misclassified payments
→Inflated expenses
→Hidden arrangements
→Misleading commercial records

Reporting concerns

Raise concerns through ENGIC's reporting channel.

ENGIC encourages employees, suppliers, clients, partners, contractors, investors, and stakeholders to report bribery, corruption, unethical conduct, improper payment requests, false documentation, or suspicious commercial behaviour.

Concerns may be raised through ENGIC's designated reporting channel or contact process.

ENGIC does not support retaliation against persons who raise concerns in good faith.

Open ethics reporting →

Reports should include, where possible:

→Description of the concern
→Parties involved
→Dates and locations
→Relevant documents or messages
→Whether immediate action is required
→Whether confidentiality is requested

Consequences of breach

Breach of ENGIC's anti-bribery and anti-corruption position may result in:

→Rejection of enquiry
→Suspension of engagement
→Termination of supplier or partner relationship
→Cancellation of commercial discussions
→Internal disciplinary action
→Reporting to authorities where required
→Legal action where appropriate
→Removal from ENGIC's supplier or partner network

Legal framework and review

This policy was reviewed on 23 September 2026 against Singapore's Prevention of Corruption Act 1960. Other laws may apply because of a party's nationality, the project location, the payment route, or contractual requirements.

This page provides ENGIC's public anti-bribery and anti-corruption position. It does not replace applicable laws, contract terms, employment policies, supplier agreements, investor agreements, client requirements, project procedures, or formal internal controls.

Where a specific written policy or agreement applies, that document will govern the relevant relationship.

Report a concern

Report an anti-bribery or corruption concern.

If you have a concern involving improper payments, bribery, corruption, false invoices, hidden commissions, document manipulation, or unethical business conduct, contact ENGIC through the appropriate reporting channel.

Report a Concern →