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Human Rights Policy

VICOM’s Human Rights Commitment is guided by the Universal Declaration of Human Rights and the United Nations Global Compact’s Principles on Human Rights in aspects of our employment practices as well as Workplace Health and Safety.

This policy highlights our responsibility and response in relation to protecting the rights of employees within VICOM in all locations where we operate.

1. Prohibition of Unethical Labour Practices

VICOM does not engage in nor tolerate unethical labour practices such as child labour or forced labour. We strive to uphold and honour relevant local, national, and international laws and conventions where we operate and implement measures to ensure no unethical labour practices exist within the Group.

2. Fair Employment Practices

We adhere to applicable employment-related legislations and guidance in locations where we operate. Specifically, in Singapore, we are committed to the Tripartite Guidelines for Fair Employment Practices released by the Tripartite Alliance for Fair and Progressive Employment Practices. The working hours of VICOM’s employees shall comply with applicable legislations where they are situated.

In relation to our Sustainability Framework, VICOM strives to:

3. Growing Our People

At VICOM, growing our Talent Base is one of our three key strategies for success. Our people must be prepared and equipped with the right mindset, skills, and competencies for the future. We approach development inclusively, aiming to develop leaders at all levels systematically with a focus on continual learning and team collaboration.

In relation to our Sustainability Framework, VICOM strives to ensure inclusive and equitable quality education and promote lifelong learning opportunities for all.

VICOM is committed to providing a challenging environment with ample opportunities for growth so that our talent can realize their full potential.

4. Diversity & Inclusion

VICOM embraces diversity. We believe in creating an inclusive environment where employees treat each other equally and with respect. We nurture a culture where diverse perspectives drive progress and equal opportunities are given to all staff.

VICOM is committed to creating a culture of diversity, inclusion, and equal opportunity. We provide a fair and supportive work environment for all employees, regardless of age, sex, marital status, sexual orientation, disability, race, colour, nationality, ethnic or national origin, religion, or affiliation to any political party or trade union. We value each employee’s contributions, both individually and as part of VICOM.

Beyond physical safety, VICOM ensures a safe psychological environment where employees can express diverse views without fear of repercussions or discrimination.

5. Freedom of Association and Right to Collective Bargaining

VICOM recognizes and respects employees’ freedom of association and rights to representation through appointed trade unions.

We are committed to Tripartism and strive to build and maintain progressive relationships with Trade Unions and their representatives.

6. Fair and Safe Working Conditions

As outlined in VICOM’s Sustainability Framework, one of our key pillars is “Prioritising our people, communities, and society with a responsible and philanthropic lens.” The health and safety of our customers, employees, and the public are fundamental to our business.

Our focus on safety is reflected in VICOM’s policies, procedures, and training. We take all safety incidents seriously and continuously work towards achieving zero fatalities and injury rates below Workplace Safety and Health (WSH) or national averages in our locations of operation.

Whistle Blowing Policy

1. WHAT IS WHISTLEBLOWING?

As employees are expected to abide by the principles of the Code of Business Conduct (“Code”) and also maintain and demonstrate the highest professional standards and ethical conduct in the performance of their duties, they are encouraged to bring to the attention of Management any violations of the Code; and/or any unethical or unlawful business conduct or dealings, with the intention for necessary corrective actions to be taken to address the violations.

2. WHO IS A WHISTLEBLOWER?

A whistleblower may be an employee or external party who, in the course of his/her duties or personal engagement with the Company or employee, has witnessed or who has knowledge that another fellow employee has previously engaged, is currently engaging or will be engaging in practices/activities that will be in violation of the Code, or unethical or unlawful business conduct or dealings, and decides to highlight these practices to Management with a view that necessary corrective actions will be taken to prevent the occurrence of such undesired practices/activities.

Whistleblowing is not a means by which anyone including a disgruntled employee can abuse, wreak revenge on, or sabotage another person or fellow employee without any just cause or to hold an employee at ransom. Any action of whistleblowing must be genuine, substantiated with proper evidence, and directed to the VICOM Alert Line within a reasonable time. Where necessary, employees must be prepared to testify or provide a statement of such actions. It should not be unfounded or malicious allegations made against another employee. VICOM will not tolerate the abuse of this Whistleblowing process.

A whistleblower need not have to be directly or indirectly affected by or have a personal interest in the outcome of the actions giving rise to the whistleblowing. So long as an employee has a genuine concern and reasonable grounds to believe that the actions of a fellow employee are in breach or will be in breach of the Code or principles of ethical conduct and fair dealing, he can be a whistleblower. However, the whistleblower must act in good faith at all times.

The Policy allows for reporting by Employees or External Parties of such matters, without fear of reprisal, discrimination, or adverse consequences, and also permits VICOM to address such reports by taking appropriate action including, but not limited to, disciplining or terminating the employment and/or services of those responsible.

(v) VICOM Alert Line

The VICOM Alert Line comprising the following personnel has been set up to facilitate the reporting of incidents and the handling of information or evidence on matters that will give rise to whistleblowing:

The ARC is responsible for the independent oversight and monitoring of whistleblowing, including the investigations conducted by Group Internal Audit.

All reports of incidents, including information and evidence provided, on matters relating to whistleblowing will be handled discreetly, and every effort will be made to maintain the confidentiality of the information provided, within the limits of the law. Whistleblowing in letters or other sources like those received by the Corporate Communications / Human Resource departments will also be circulated to the GCIAO.

Reported incidents will be dealt with promptly and thoroughly. GCIAO will administer and assess the cases, except for incidents involving GCIAO. For significant cases, GCIAO will propose to the ARC Chairman to proceed with an investigation.

Group Internal Audit will lead the investigation and work with VICOM’s Human Resource department or the Business Unit to which the case relates. The outcome of the investigation will be formally reported to Management and the ARC.

After consultation with relevant senior management of VICOM, appropriate and fair disciplinary action, including dismissal, may be meted out against those who are found guilty. In instances where the relevant laws have been infringed, VICOM will report such infringement to the relevant regulatory authorities. Where appropriate, internal control measures and procedures will be improved upon or additional measures put in place to prevent the recurrence of such incidents.

The number of whistleblowing cases that proceed for investigation will be tracked and recorded by GCIAO, and will be updated to the ARC quarterly.

To ensure that employees who whistleblow are not victimised, black-listed or discriminated by his/her supervisors or fellow colleagues, VICOM will not reveal the employees’ identities or information leading to their identities being known. VICOM views such victimisation, black-listing or discrimination seriously and will not hesitate to take disciplinary action against those who are involved in such practices.

All employees are responsible to ensure the highest standards of ethics, honesty, openness and accountability in line with VICOM’s commitment to enhance good governance, transparency and safeguard the integrity of VICOM. Training is provided regularly to remind staff to adhere to this Policy.

VICOM will periodically review this Policy to ensure its continued effectiveness.

Diversity, Equity and Inclusion

VICOM is committed to fostering, cultivating and preserving a culture of diversity, equity and inclusion.

Our human capital is our most valuable resource. The collective sum of our people’s individual differences, life experiences, knowledge, creativity, innovation, self-expression, unique capabilities and talent represents a significant part of our culture.

We embrace our employees’ differences in age, colour, nationality, disability, ethnicity, family or marital status, gender, language, physical and mental ability, political affiliation, race, religion, socio-economic status, and other characteristics that make our employees unique.

VICOM’s DEI initiatives are applicable but not limited to our practices and policies on recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; layoffs; terminations; and the ongoing development of a work environment built on the premise of diversity, equality and inclusion.

The Board drives VICOM’s DEI Policy by setting the example of ensuring that the composition of Directors is a balance of tripartite experience from government, labour and business in order to appreciate the values of collective consensus and avoid unproductive group-think and biasness. All employees share the same values to facilitate inclusive discussions to push for innovative business developments.

All employees of VICOM have a responsibility to always treat one another with dignity and respect. All employees are expected to exhibit teamwork, cooperation and conduct that reflects inclusion at all times.

All employees are also required to attend the DEI Policy awareness training to enhance their knowledge and deepen their understanding of their responsibilities. Any employee who is found to have exhibited any inappropriate conduct or behaviour against others may be subject to disciplinary action. Employees who believe they have been subjected to any kind of discrimination that conflicts with the company’s DEI Policy and initiatives should seek assistance from a supervisor or a Human Resource representative.

VICOM reserves the right to modify, suspend, change or terminate this Policy at any time in accordance with local law. This Policy does not create any contractual rights or obligations, whether expressed or implied. Subject to local law, the English-language version will prevail.

Safety Policies

In VICOM, we are committed to providing a safe and health risk-free workplace for all our employees and stakeholders. The management pledges that no employee will be asked to carry out any work that can compromise his or her safety.

We resolve to provide the necessary support and resources to eliminate or reduce workplace risks to the lowest possible level by implementing reasonably practicable control measures, ensuring injury and ill-health are prevented. We believe that no work is so important that it cannot be done safely.

We are committed to complying with all relevant Occupational Safety and Health legislative and other requirements that the organization subscribes to. We strive for continual improvement in our safety & health management system and performance through setting and meeting safety objectives and targets.

We promote open sharing of information and encourage all employees to provide feedback or report any dangers or hazards that may undermine workplace safety.

The responsibility for occupational safety & health ultimately rests upon the Accountable Manager. However, each Director, Manager, and Head of Department has their respective responsibility in implementing the safety & health management system in their areas. Every individual in VICOM has the responsibility to participate and contribute to safety. We shall provide the necessary provisions so that every employee can be adequately trained and informed of safety requirements.

This policy may be made available to anyone who requests it in writing. It shall be reviewed regularly to ensure its suitability and effectiveness, reflecting our philosophy and management approach toward workplace safety and risk management. All VICOM staff shall read, embrace, and commit to our Safety & Health Management System.

Data Protection Policy

VICOM strives to comply with the regulatory requirements of the Personal Data Protection Act (PDPA) and requirements for Data Protection Trust Mark (DPTM) certification and henceforth has established the following policies in its effort to fulfil the 10 (ten) obligations of PDPA as follows:

5.1 CONSENT OBLIGATION
VICOM shall seek the prior written consent of an individual in its collection of personal data and such consent shall be documented. Despite given their consent, the individual is allowed to change their mind and withdraw their consent at any time.

5.2 PURPOSE LIMITATION OBLIGATION
VICOM shall explicitly state its purpose of collecting personal data and such purpose shall be considered appropriate by a reasonable person who provides the personal data.

5.3 NOTIFICATION OBLIGATION
VICOM shall notify the individual of the purpose/s for which it intends to collect, use or disclose the individual’s personal data on or before such collection, use or disclosure of the personal data.

5.4 ACCESS AND CORRECTION OBLIGATION
VICOM shall provide reasonable access to individual whose personal data it possesses or under its control for the latter to verify and make corrections should there be any amendments / update required.

5.5 ACCURACY OBLIGATION
VICOM shall make a reasonable effort to ensure that the personal data collected is accurate and complete for the purpose of its collection. It shall provide suitable way for an individual to access their record and make the necessary amendment/update on it.

5.6 PROTECTION OBLIGATION
VICOM shall strive to protect personal data in its possession or under its control by establishing suitable and reasonable security arrangement to prevent undesirable incidents eg unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

5.7 RETENTION LIMITATION OBLIGATION
VICOM shall determine the appropriate retention period/s of all documents (including electronic storage) and shall dispose, delete or remove appropriately such documents when it reaches its retention time limit or when such retention no longer serve the purpose for its collection or when such retention is no longer necessary for legal or business purposes.

5.8 TRANSFER LIMITATION OBLIGATION
VICOM does transfer personal data to overseas 3rd party scheme owner in United Kingdom (UK). However, such personal data transfer is in the form of a prescribed format from the latter. The type and number of information collected from individuals are based on requirements set by the scheme owner.

5.9 DATA BREACH NOTIFICATION OBLIGATION
VICOM shall establish a robust data breach management plan in order to manage and respond to data breaches more effectively. In the event of a data breach, VICOM shall notify (where required) the PDPC, affected individuals and/or scheme owners should the breach likely result in significant harm or impact to individuals or of a significant scale.

5.10 ACCOUNTABILITY OBLIGATION
VICOM shall establish and make publicly known its policies and practices in meeting the requirements of PDPA. It shall identify the Data Protection Officer (DPO) to whom the public or relevant individuals are able to provide feedback and comments on our policies and practices.

Environmental Policy

VICOM is committed to sustainable growth, based on our principles of integrity, quality, safety, and social and environmental responsibility. VICOM strives to conduct its business activities in an environmentally sound manner and has established policies, programmes and practices to reduce risks posed to the environment and the organisation.

The Management and Staff of VICOM are committed to the effective implementation of the established environmental management system and will: