Being based in Singapore, the Journal strives to conduct itself according to the highest standards of ethical conduct. Throughout its operations, the Journal seeks to avoid even the appearance of impropriety in the actions of its members and officers.
This policy reiterates our commitment to integrity and explains the specific requirements and prohibitions applicable to our operations under anti-corruption laws, including, but not limited to, the Singapore Prevention of Corruption Act of 1960 (the “PCA”). This policy contains information intended to reduce the risk of corruption and bribery from occurring with the Journal's activities. The Journal strictly prohibits all forms of corruption and bribery and will take all necessary steps to ensure that corruption and bribery do not occur in its business activities.
This policy is applicable throughout the Journal’s operations. This policy applies to all of the Journal's editorial team, staffers, authors, reviewers, agents, consultants, partners and any other third-party representatives (collectively as “stakeholders”) that, on behalf of the Journal, have conducted or likely to conduct business outside the Singapore when interacting with non-Singapore government officials.
1. Under the PCA, it is illegal for Singapore persons, including Singapore organisations, and stakeholders to bribe non-Singapore government. The concept of prohibiting bribery is simple. However, understanding the full scope of the PCA is essential as this law directly affects everyday business interactions between the Journal and non-Singapore governments and government-owned or government-controlled entities.
2. Violations of the PCA can also result in violations of other Singapore laws, including anti-money laundering, mail and wire fraud and conspiracy. The penalties for violating the PCA are severe. In addition to being subject to the Journal’s disciplinary policies (including termination), individuals who violate the PCA may also be subject to imprisonment and fines. Aside from the PCA, the Journal may also be subject to other non-Singapore anti-corruption laws, in addition to the local laws of the countries in which the Journal conducts business. This policy generally sets forth the expectations and requirements for compliance with those laws, including, without limitation, the PCA.
3. The Journal’s editor, staff or consultant are prohibited from directly or indirectly making, promising, authorising or offering anything of value to a non-Singapore government official on behalf of the Journal to secure an improper advantage, obtain or retain business, or direct business to any other person or entity. This prohibition includes payments to third parties where the Journal's editor, staff or consultant knows, or has reason to know, that the third-party will use any part of the payment for bribes. Although the PCA prohibits such payments to non-Singapore government officials, the Journal also prohibits editor, staff or consultant from making such payments to Singapore government officials.
A. Cash and Non-Cash Payments: “Anything of Value”
Payments that violate the PCA may arise in a variety of settings and include a broad range of payments beyond the obvious cash bribe or kickback. The PCA prohibits giving “anything of value” for an improper purpose. This term is very broad and can include, for example:
Gifts
Travel, meals, lodging, entertainment, or gift cards
Loans or non-arm's length transaction
Chartible or polictical donations
Business, employment or investment opportunities
B. Non-Singapore Government Official
The PCA broadly defines the term non-Singapore government official to include:
Payments that violate the PCA may arise in a variety of settings and include a broad range of payments beyond the obvious cash bribe or kickback. The PCA prohibits giving “anything of value” for an improper purpose. This term is very broad and can include, for example:
Officers or employees of a non-Singapore government or any department, agency or instrumentality thereof
Officers or employees of a company or business owned in whole or in part by a non-Singapore government (state owned or controlled enterprises).
Officers or employees of a public international organization (such as the United Nations, World Bank or the European Union)
Non-Singapore political parties or officials thereof
Candidates for non-Singapore political office
This term also includes anyone acting on behalf of the above. On occasion, a non-Singapore government official may attempt to solicit or extort improper payments or anything of value from the Association’s employees or agents. Such employees or agents must inform the non-Singapore government official that the Association does not engage in such conduct and immediately contact the Director of Compliance in Legal Services.
C. Commercial Bribery
Bribery involving commercial (non-governmental parties) is also prohibited under this policy. To this end, the Journal employees and agents shall not offer, promise, authorise the payment of, or pay or provide anything of value to any employee, agent, or representative of another company to induce or reward the improper performance of any function or any business-related activity. The Journal's editor, staff, or consultant also shall not request, agree to receive, or accept anything of value from any employee, agent, or representative of another company or entity as an inducement or reward for the improper performance of any function or business-related activity.
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