A Practical Anti-corruption Guide For Businesses In Singapore

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PACTA PRACTICALANTI-CORRUPTIONGUIDE FOR BUSINESSESIN SINGAPOREC O R R U P T P R A C T I C E S I N V E S T I G AT I O N B U R E A U3

ContentsDirector’s Foreword02Further Resources & Appendices35Corruption & Business0338Quick Facts05PACT Framework10i. Appendix A - Extracts fromThe Prevention of CorruptionAct, Penal Code andCriminal Procedure CodePledge12ii. Appendix B - Sample ofAnti-Corruption Policy41Assess1542Control & Communicate19iii. Appendix C - Sample ofCode of ConductTrack2243Case Studies24iv. Appendix D - Sample ofDeclaration Form for Gifts andEntertainmentv. Appendix E - Sample ofDeclaration Form for Conflictof Interest44vi. Appendix F – Sample of RiskAssessment Checklist46

The Corrupt PracticesInvestigation Bureauconstantly strives to keepSingapore corruption-freethrough swift and sure, firmbut fair action.1

Director’s ForewordEach of us must continue to doour part and stamp out corruption.Only then can Singapore remain aconducive place for investmentsand businesses.Singapore is recognised as one of the leastcorrupt countries in the world. Singaporeans andforeigners alike have benefited immensely fromthe incorruptible and clean system. Our people,public service and businesses are well-reputedto be efficient, honest and transparent.The Corrupt Practices Investigation Bureau’s(CPIB) constant vigilance has contributed to thisgood reputation, with many helping hands. Wehave worked with different stakeholders includingthe public and private sectors, the communityand the students to keep corruption at bay.Each of us must continue to do our part andstamp out corruption. Only then can Singaporeremain a conducive place for investments andbusinesses.2The CPIB remains resolute and committed tocombating corruption relentlessly without fearor favour. Taking our commitment further, wehave designed PACT: A Practical Anti-CorruptionGuide for Businesses in Singapore, which setsout to guide business owners in developing andimplementing an anti-corruption system in aclear and easy-to-understand manner.We hope you will find PACT useful, as youjourney with our nation in maintaining a zerotolerance towards corruption.Mr Wong Hong KuanDirectorCorrupt Practices Investigation Bureau

CORRUPTION& BUSINESSWhy do I need to think about corruption?3

Corruption & Business Why do I need to think about corruption?Corruption has far reachingconsequencesCorruption is a serious matter, and comes fromweakness of human nature – greed, temptation,the desire to amass wealth or to obtain businessthrough unfair means. Even with harsh penalties,corruption cannot be eradicated completely.If allowed to take root in society, corruption canlead to a breakdown in social order, tarnish thereputation of an entire country and result in aloss in overseas investor confidence. Corruptioncan even affect lives by impeding people fromaccessing basic and essential services.Although corruption in Singapore remains low,the clean system we have in place here shouldnot be taken for granted.How does corruption affect mybusinessCorruption undermines healthy competition,raises the cost of business operations, destroyscorporate and individual integrity and posesreputational risks for private businesses. It isillegal in Singapore and in most countries, andcan have severe consequences for businesses.In Singapore, individuals and companies foundto be engaging in corrupt activities and violatingthe law could face severe legal ramifications orbe blacklisted from doing business.For companies which conduct operationsabroad, falling afoul of international laws suchas the United Kingdom Bribery Act or the UnitedStates Foreign Corrupt Practices Act (FCPA)4could mean having to pay significant amountsof money to reach a settlement, amongst otherpenalties.What are the benefits of acorruption-free businessA clean business protects your company andemployees from being caught in thorny andcompromising situations. It also boosts yourcompany’s reputation and staff morale, andmakes doing business with your company moreattractive for your partners and customers. Yourbusiness’ competitive edge will be enhanced.How do I protect my companyDealing with bribery may seem daunting forcompanies which lack sophisticated compliancesystems and have limited resources. To helplocal companies combat corruption, PACTprovides practical information and guidance, andan easy-to-implement anti-corruption framework.For local companies which have overseasbusiness ties, or which are interested inimplementing a more comprehensive anti-briberymanagement and compliance system, they mayconsider ISO 37001: Anti-Bribery ManagementStandard certification.For more information on ISO 37001 certification,please visit the Singapore Accreditation Councilwebsite. ISO 37001 and SS ISO 37001 areavailable for purchase at the SPRING SingaporeStandards eShop:www.singaporestandardseshop.sg

QUICKFACTSWhat I need to know aboutcorruption in Singapore5

Quick Facts What I need to know about corruption in SingaporeWhat is corruptionThe Prevention of Corruption ActCorruption1 is receiving, asking for or giving anygratification as an inducement or reward for aperson to do a favour with a corrupt intent.There are many kinds of gratification or bribes,including money, sexual acts, properties,promises and services. In return, a person mayask for favours which can include unfairbusiness advantages, confidential informationand other special privileges.The Prevention of Corruption Act (PCA) is theprimary anti-corruption legislation in Singapore.The PCA defines and governs corruptionand their punishments, as well as empowersthe CPIB, the main agency charged withinvestigating corruption in eiverThe PCA has extra-territorial powers over aSingapore citizen to deal with corrupt actsoutside Singapore as though it were committedin Singapore. Non-citizens may also beinvestigated and prosecuted in Singapore if theyabet the commission of a corruption offencerelated to Singapore.More information on the PCA can be found onthe Singapore Statutes website.Link: https://sso.agc.gov.sg1Some jurisdictions follow the United Nations Convention Against Corruption (UNCAC) definition of corruption which besides briberyoffences, includes embezzlement offences. In the Singapore context, corruption is tantamount to bribery offences which CPIBenforces while embezzlement offences are under Commercial Affairs Department’s (CAD) purview.6

Quick Facts What I need to know about corruption in SingaporeOther anti-corruption lawsEnhanced punishment and penaltiesThe Corruption, Drug Trafficking and OtherSerious Crimes (Confiscation of Benefits) Act(Cap 65A) (CDSA) works in tandem with thePCA by punishing the laundering of bribe money.The CDSA provides for the State to confiscatecorrupt benefits.If it is proven that any matter or transaction is inrelation to contract or a proposal for a contractwith the Government, the punishment wouldbe a fine not exceeding S 100,000 orimprisonment not exceeding 7 years or both.The Penal Code (Sections 161 to 165) alsostates that it is a punishable offence for publicofficials to accept or attempt to accept bribes.Under the Criminal Procedure Code (Section424), it is also the legal duty of any personwho is aware of any public officials engagingin corruption activities to immediately reportand give information to the Police. Bribery ofwitnesses to give false information is also illegalunder the Penal Code (Section 204B).Punishment and penaltiesAny person found guilty of corruption shall beliable on conviction to a fine not exceedingS 100,000 or to imprisonment for a term notexceeding 5 years, or to both.Refer to Appendix A for extracts of the PCA,Penal Code and Criminal Procedure Code.Case In Point Cash For InformationRichard Yow Wah was a DefenceContractor and managing director ofCertified Aerospace Singapore. His jobinvolved securing business contracts.CPIB investigations revealed that betweenMay to August 2008, Yow had providedloans amounting to S 53,100 to Phua PohSim, a captain in the Singapore ArmedForces (SAF). In return for the loans, Yowobtained confidential information on SAFmilitary projects from Phua, which Yowbelieved would help him secure businessopportunities.Yow was charged for corruptly givinggratifications in the form of loans of loansamounting to S 53,100. In December2011, Yow was sentenced to 8 weeks’imprisonment.7

Quick Facts What I need to know about corruption in SingaporeThe Corrupt Practices InvestigationBureauThe Corrupt Practices Investigation Bureau(CPIB) is an independent government agencyresponsible for investigating and preventingcorruption in both the public and private sectorsin Singapore. The CPIB is under the PrimeMinister’s Office and reports directly to the PrimeMinister of Singapore.The Prevention of Corruption Act (PCA) providesthe CPIB with the powers to investigatecorruption and other arrestable offences whichare disclosed in the course of a corruptioninvestigation.The CPIB takes a serious view of any corruptpractices, and will not hesitate to take actionagainst any party involved in such acts.Underpinned by strong political will, the CPIB,together with effective laws, an independentjudiciary, and a responsive Public Service, formsan effective corruption control framework thatkeeps Singapore clean.RESPONSIVEPUBLIC ECTIVE LAWSZERO TOLERANCETO CORRUPTIONPOLITICAL WILLSingapore’s Corruption Control Framework8

Quick Facts What I need to know about corruption in SingaporeReporting corruptionPublic education talksThe CPIB takes each corruption complaintseriously. Those with information on suspectedcorrupt activities are strongly encouraged to usethe following reporting channels:Besides rigorous enforcement, the CPIBcontinues to focus on public education andoutreach to spread the anti-corruption message.The CPIB regularly conducts corruptionprevention talks for government agencies andprivate companies where participants canexpect to learn:Visit us at the CorruptionReporting & Heritage Centre @247 Whitley Road, S297830 orCPIB Headquarters @ 2 LengkokBahru, S159047Call the CPIB Duty Officer at1800-376-0000Lodge an e-Complaint athttp://www.cpib.gov.sg/e-complaintOr email us atcpib website email@cpib.gov.sg Definition of corruption Singapore’s success in keeping corruptionunder control Preventive measures Case studiesSubmit a request online:www.cpib.gov.sg/public-education-talkYou will be informed if your booking is successful.Fax us at 6270 0320Write to us at CorruptionReporting & Heritage Centre @247 Whitley Road, S297830 orCPIB Headquarters @ 2 LengkokBahru, S1590479

PLEDGECONTROL & COMMUNICATE10ASSESSTRACK

PACT is designed tobe a simple andeasy-to-use 4-stepguide for companieslooking for practical stepsto prevent corruptionNote: This publication outlines typical corruption-related risk areas for companies and describes how corruptionrisks can be identified. Conformance with the guidance outlined in this publication cannot provide assurance that nobribery has occurred or will take place in relation to the organisation or company.11

PLEDGE12

PACT PledgeTone from the top is keyPreventing corruption in your company starts atthe top. Senior management (such as owners,Chief Executive Officers and Board of Directors)must pledge and be committed towards zerotolerance of corruption.The tone from the top has a large impact on thevalues by which the company’s employees andbusiness partners operate.With strong and visible supportby senior management againstcorruption, fundamental valuessuch as integrity, meritocracy andtransparency can be developed.Implement an anti-corruption policyThe pledge and commitment from the top forzero-tolerance towards corruption needs to betranslated into action. This can be articulatedthrough the formulation of a clear and visibleanti-corruption policy, which formalises thefair and honest practices for your company’semployees and business partners througha prescribed set of rules and principles.Besides lowering the likelihood of corruption,implementing a strong anti-corruption policywould also advance your company’s professionalreputation.An effective anti-corruption policy should beclear, visible and easy to understand. Thepolicy should also be formally documentedand communicated to all parties within andoutside the company to enhance awarenessand effective implementation. A strong anticorruption policy would reinforce the deterrenceof corruption amongst employees and businesspartners, and provide confidence to whistleblowers on possible wrong-doing.Key features of an effectiveanti-corruption policyDeclaration to abide bySingapore’s anti-corruption lawsDenouncement of any form ofcorruption and briberyUndertaking to set-up, maintainand regularly review corruptionsusceptible operational processesSupporting and protectingwhistle-blowersCompliance to regular monitoringand auditingA sample Anti-Corruption Policy can be found inAppendix B.13

PACT PledgeCreate a code of conductThe next course of action would be to createa company code of conduct. The businessenvironment is complex. Not all businessactivities are clear-cut, and distinguishingbetween legal and corrupt practices issometimes made more difficult due to differingtraditional customs and common businesspractices.A code of conduct serves as a comprehensive,unambiguous guide for all employees on a uniformstandard of conduct and ethics in all areas ofbusiness activities where corrupt practices arelikely to occur. It is an important document thatall employees can refer to in order to safeguardthemselves from falling foul of the law.A well-defined code of conduct should includeguidelines relating to the high-risk areas wherecorruption can occur. The code of conduct mustalso be clearly communicated to all employees.This can be done by displaying it prominentlyin common office areas, and incorporating thecode of conduct into the staff manual, staff passor letter of appointment.The code of conduct should also becommunicated widely to all external parties suchas business partners to thwart any party fromengaging or attempting to engage in corruptactivities.14Key areas to address in code of conductCorrupt behaviour – what isand what is not toleratedConflict of interestGifts and entertainmentObtaining personal loansfrom clients/customersA sample Code of Conduct can be found inAppendix C.

A SSESS15

PACT AssessCommon corruption risk areasGifts and entertainmentOne may think that giving gifts and providingentertainment are common business practicesfor relationship-building and expression ofappreciation. However, lavish or frequent giftsand entertainment made with the deliberateintention of gaining or trying to gain an unfairbusiness advantage can constitute an act ofcorruption. Meals, gift hampers and even redpackets can constitute bribes.It is imperative to conductperiodical risk assessmentsto safeguard the integrity andinterests of your business.A basic risk assessment focusingon vulnerable job functions andprocesses would greatly enhanceyour company’s corruptionprevention capability.16The receiver of such gifts and entertainment isalso liable for corruption, regardless of whetheror not they are able to fulfil the request made bythe giver. Due to their nature of work, employeesinvolved in procurement and sales/marketing areparticularly vulnerable to such corrupt practices.There is no one-size-fits-all solution. Somecompanies may prefer a “No Gift/Entertainment”standard, while others may opt for giving orreceiving and entertainment within clear andtransparent boundaries. As a general rule,to protect your company, agree on whenit is appropriate to give or receive gifts andentertainment and include this as part of yourcompany’s code of conduct. This way, theprocess is transparent and avoids ambiguity andunnecessary suspicion.A sample Declaration Form for Gifts andEntertainment Received can be found inAppendix D.

PACT AssessConflict of interestConflict of interest can happen in any company.A conflict of interest occurs when the individual’sinterest conflicts with the company’s interest,and can result in dishonest actions and corruptactivities.Examples of conflict of interestAccepting gifts andentertainment disproportionateto normal practicesPurchasing services orapproving quotes fromcompanies managed by familymembers or friendsFavouring business deals withcompanies in which they havea financial investmentTo safeguard your company’s business interest,you should require all employees to declareany actual or perceived conflicts of interest.In addition, companies can also considerconducting due diligence to uncover conflictof interest amongst employees and businesspartners. These guidelines to reduce conflictof interest should also be worked into thecompany’s code of conduct.A sample Declaration Form for Conflict ofInterest can be found in Appendix E.Contributions and sponsorshipsContributions and sponsorships should notbe related to a business deal, and mustprovide real or measurable benefits to thecompany, such as increased publicity or visiblebrand enhancement. Any contributions orsponsorships in monetary form should alsoalways be only given to the organisation and notto an individual.To further reduce the risk of corruption, theobjective and amount of the contribution and/orsponsorship should be recorded down clearly inthe company’s accounts.17

PACT AssessIdentify your company’s risksConduct a risk assessmentCompanies face a variety of corruption risks.Your company’s risk areas depend on manyfactors; such as industry, company size andbusiness operations. Besides being familiarwith Singapore’s anti-corruption laws and thecommon corruption risk areas, there are a fewother practical ways you can identify risks.Having identified your company’s risks, your nextstep would be to conduct a risk assessment.It is imperative to conduct periodical riskassessments to safeguard the integrityand interests of your business. A basic riskassessment focusing on vulnerable job functionsand processes would greatly enhance yourcompany’s corruption prevention capability.Ways to identify corruption risksConduct consultationsessions with your employeeswhose job functions arevulnerable to corruptionNetwork with businesspartners to share bestpractices and knowledgeHire external professionalconsultants18A sample Risk Assessment Checklist can befound in Appendix F.

CONTROL &COMMUNICATE19

PACT Control & CommunicateGood internal controlsNo company is immune from corruption. Whilea carefully-crafted anti-corruption policy anda code of conduct remains key to preventingcorruption, it is not sufficient. A single rogueemployee who fails to comply can causesignificant damage to the company.Strong internal controls are capableof exposing irregularities which couldturn out to be corrupt practices.Internal controls serve as a necessary check andbalance to ensure that employees are compliantto the company’s anti-corruption policy, code ofconduct and prescribed business processes.Accurate recordsAccurate records are essential. They are usefulin detecting irregularities and weaknesses,and should be readily available for inspectionwhen there is a need to explain a transaction.All transactions, assets and liabilities should beproperly reflected in the company’s records,and supported by original documentation.A meticulous and diligent record system willmake it more difficult for rogue employees to trytheir luck.20Examples of documents to be recordedFinancial documents (includingledgers, payment vouchers andgoods receipt notes)Contractual documents(including tender invitations,contracts and evaluation papers)Administrative documents(including meeting minutes,approval memos andappointment letters)Clear operating proceduresNon-compliance to standard operatingprocedures can raise red flags and detectsuspected corruption. Standard operatingprocedures need to be clearly-written, accessibleand clearly-communicated to all employees.Standard operating procedures should be drawnup for vulnerable areas such as procurement andfinancial approval.Audit checksTo minimise corruption loopholes, regular auditchecks should be performed to ensure thatcompany procedures are adhered to. Auditchecks can be done periodically or at random.It may also be conducted internally oroutsourced to an independent external thirdparty who can then make recommendations forimprovement.

PACT Control & CommunicateRobust reporting systemA robust reporting or whistle-blowing system isa key function to control bribery and corruptionrisks. Employees should be encouraged to makea report if they suspect something is amiss,without fear of reprisal or reprimand if donein good faith. Anonymous reporting providesthe best protection for employees againstidentification, but there is also the possibility ofabuse of the process through malicious or falsereports.Reporting mechanisms may include adesignated company email address, phonenumber, address, or even a drop-box situated ina discreet area.Features of an effective reporting systemClear reporting chain suchas a suitably appointedperson/team to follow-up onsuspected corruptionConveniently accessiblereporting mechanism (such asa designated phone number/email address)Diligent follow-up with thecomplainant (if known) on theoutcome of the investigationWhen violations of your company’s anticorruption policy and code of conduct aredetected, it is crucial to address these violationsto demonstrate your company’s zero-tolerancetowards to corruption. When in doubt, contactthe CPIB for assistance.Communication across all levelsYour company’s anti-corruption policy, codeof conduct, internal controls and reportingsystem should be open, transparent, andwidely communicated on a regular basis toall employees, business partners and otherstakeholders (where appropriate). Awarenessand understanding of your company’s anticorruption policies and controls will equipstakeholders with the necessary information andskills to counter corruption-related situations.Communication can be done at variousemployee career milestones or business touchpoints, such as: Employee induction programme; Corporate training programmes, seminars,videos and in-house courses; Company intranet/website, emails, newsletter,posters and contractual obligations; Company town-halls and retreats; and Via middle-managers/supervisors, to reachout to employees who are off-site and do nothave access to emails.21

T RACK22

PACT TrackTracking and evaluation criteriaReview and improveTimely tracking and evaluation of yourcompany’s anti-corruption system and policy areimportant to determine whether improvementsor modifications are required. Measurementcycles can be planned in advance by seniormanagement.Improvements/modifications to your company’santi-corruption system could be required in thefollowing scenarios:Basic assessment criteriaEfficacy of the existingsystem to prevent corruptionEfficiency in keepingoperation costs lowSustainability of the systemto combat corruption in thelong runJust as the business environment isalways evolving, your anti-corruptionsystem needs to stay robust andwould require updates over time. Company reorganisation; Expansion of the company’s operationsresulting in new business processes; New legal requirements and/or international/national anti-bribery standards; and Shifts in the business operating environment.Sources of information that can help in yourevaluation include the rate of compliance toestablished internal controls (record-keeping,standard operating procedures and internal/external audits). Another source is feedback fromemployees and/or business partners, which canbe gathered via surveys or focus groups. Whenreviewing, it is also useful to look out for newanti-corruption benchmarks (established by othercompanies) in the same industry.When the evaluation has been completed,the results and subsequent modifications/improvements should be communicated toall employees to reiterate your company’scommitment to keeping corruption at bay.23

CASESTUDIESThe following case studiesare actual CPIB cases whichillustrate the various forms ofcorrupt activities that have beencommitted by corporation andpersons in the private sector andwho were brought to task.24

Case StudiesA corporation’s corrupt commissionFederal Hardware Engineering Co Pte Ltd(Federal), a hardware engineering company basedin Singapore, had supplied pipes and valvesfor a chemical plant project undertaken in 2000by Japan-based company Toyo EngineeringCorporation (Toyo) in Kuala Lumpur, Malaysia.Federal had dealings with one NakamuraTomohiro, who was the project manager for thesaid project undertaken by Toyo.Investigation by the CPIB revealed that on anoccasion in early 2001, Nakamura asked for acommission of 20% to 30% from Federal,in return for awarding more business from Toyo(in the form of sales orders) to Federal. Federalagreed to the request, and transferred a sumof US 17,500 to Nakamura’s bank account.The amount of US 17,500 was Nakamura’scommission for awarding Toyo sales ordersworth a total of US 247,088 to Federal betweenApril 2001 to May 2001.In 2004, the appointed representative ofFederal pleaded guilty to corruptly giving a bribeand Federal was ordered to pay a penalty ofS 60,000.25

Case StudiesFine line between tradition and corruptionTay Ee Tiong is the owner of Wealthy SeafoodProduct and Enterprise. During his course ofwork, he had personally approached each headchef and promised them commissions in returnfor showing favour to Wealthy Seafood. Manyof these chefs were from well-known Chineserestaurants and hotels in Singapore. These chefswere prominent and established, and had theauthority to make decisions on the choice ofsuppliers for their respective restaurants.The CPIB’s investigations found that fromFebruary 2006 and August 2009, Tay had givenbribes to 19 chefs ranging from S 200 andS 24,000. Tay would approach these chefs26and promise them commissions, based on apercentage of the total value of the seafoodproducts bought. The chefs would receive thecash from Tay once every two to three months.In return, they would continue to place theirseafood orders from Tay’s company.Tay Ee Tiong was eventually charged with 223counts of corruption and sentenced to 18months’ imprisonment in September 2011 forgiving out nearly S 1 million in bribes. The chefsinvolved were also convicted with corruptlyaccepting bribes from Tay and received theirrespective sentences, with exception of one whowas acquitted.

Case StudiesA little coffee money “did no harm”Sheith Yusof Bin Sheith Ibrahim was a trainer ofAbsolute Kinetics Consultancy Pte Ltd wherehe coached trainees attending the weldingcourse on the theoretical and practical aspectsof welding. In addition, his duties also includedassisting the external welding testers during thewelding test. Any trainee who passed the testwould receive a welder pass which is recognizedby the Ministry of Manpower.Investigations by the CPIB revealed thatfrom November 2012 to March 2013, hetook advantage of his position as a trainer toobtain bribes from course trainees on severaloccasions. These bribe amounts which rangedfrom S 5 to S 50 were given in return forshowing leniency during the welding coursesand tests.Sheith Yusof Bin Sheith Ibrahim admitted thathe had obtained money from his trainees duringthe two courses conducted in 2012. In January2014, Yusof was fined S 8,000 and a penaltyof S 199 for the corruption offences. The 11foreign workers who gave the bribes were givenconditional warnings.27

Case StudiesConcealed act uncoveredLo Keng Foo was the Director of the FailureAnalysis and Reliability Engineering Section atChartered Semiconductor Manufacturing PteLtd (CSM). His job scope involved studyingand acquiring new technologically advancedtest devices to measure the reliability ofsemiconductor products manufactured by CSM.The CPIB acted on information receivedand investigated the case. In 1994, Lo gotto know Lim Cheng Hock, Chairman of ZenVoce Manufacturing Pte Ltd, after he becamea supplier of CSM for Test Solution Products.Sometime in 1997, Lo had a discussion with LimCheng Hock. Lo said he could help Zen Vocesecure sales orders from CSM in return for a28cut of their profits. From March 1998 to August2002, Lo obtained S 1,017,343 from Lim asa reward for helping Zen Voce. Subsequentlyfrom August 1997 to July 2000, Lo obtainedS 211,400 from Chng Peng Hion, ManagingDirector of ESA Electronics Pte Ltd (ESA), as areward for helping ESA secured contracts withCSM. To camouflage the accounts of Zen Voceand ESA and cover these illicit payments, Locreated fictitious invoices to mislead Zen Voceand ESA.On 24 January 2006, Lo Keng Foo wassentenced to 4 years’ imprisonment and orderedto pay a penalty of S 1,228,743 for corruptionoffences.

Case StudiesBrothers in cahootsGoh Peng Choy was a Senior ProcurementExecutive with Advanced Material EngineeringPte Ltd (AME), a wholly owned subsidiary ofST Kinetics Ltd. He had abused his position toobtain bribes from several contractors of AME inreturn for divulging AME’s internal price list whichis confidential information or showing favour tothe contractors. All the bribe monies were givenin cash to Goh Peng Choy.Goh Peng Choy had concealed the bribemonies with the assistance of his brother, GohPeng Kee. The latter had hidden the cash in hisresidence. Goh Peng Choy had also instructedhis brother and sister-in-law to open bankaccounts to deposit part of bribe monies.S 385,000 was found in Goh Peng Kee’s safe.A further S 100,767.03 was recovered from thebank accounts.Goh Peng Choy was subsequently charged forboth corruption and money laundering offences.On 17 February 2014, he pleaded guilty to 4corruption charges and one money launderingoffence

have designed PACT: A Practical Anti-Corruption Guide for Businesses in Singapore, which sets out to guide business owners in developing and implementing an anti-corruption system in a clear and easy-to-understand manner. We hope you will find PACT useful, as you journey with our nation in maintaining a zero . tolerance towards corruption.

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