Ethics and Compliance

Overview

At Valency ethical business practices and compliance are an integral part of our culture, our organizational DNA and reflects our cherished values. We recognise the fact that a growing organization like ours with a global footprint, operates in very different jurisdictions with their own local norms. Through our documented policies, established internal processes and multiple checks and balances we ensure that we function as a responsible corporate citizen. We reinforce our culture of compliance and ethical way of doing business through training programmes, workshops and targeted messaging from the leadership, both at a regional and global level.

Business Integrity Manual (BIM)

Our Commitment to Integrity
At Valency, we believe that how we do business is just as important as what we do. The Business Integrity Manual (“BIM”) reflects our commitment to ethical, responsible, and transparent conduct across all our operations worldwide. The BIM integrates our Group’s core compliance and ethics policies into a unified framework to promote accountability, fairness, and good governance.

What is the BIM?
The Business Integrity Manual is an internal governance document that defines how Valency ensures ethical conduct through implementation, monitoring, training, and reporting of key compliance policies. It sets out the Group’s expectations from all employees and third parties, and provides clear mechanisms to report, investigate, and mitigate misconduct.

Policies Under the BIM
• Anti-Bribery & Corruption Policy- Prohibits offering or accepting bribes, facilitation payments, or gifts that could influence business decisions. Applies globally across all jurisdictions where Valency operates.
• Anti-Money Laundering (AML) Policy- Prevents Valency from being used to launder illicit funds or finance terrorism. Enforces strict Know Your Customer (KYC) procedures and suspicious activity monitoring.
• Conflict of Interests Policy- Requires disclosure and mitigation of personal, financial, or professional interests that conflict with the interests of Valency. Includes restrictions on employment outside Valency and relationships with vendors or competitors.
• Sanctions Policy- Ensures that the Group does not engage in any transaction or relationship with individuals or entities subject to international sanctions.
• Whistleblower Policy- Protects employees who report ethical concerns or violations. Allows anonymous and confidential reporting through designated channels.
• Due Diligence Policy- Establishes processes to screen third parties, conduct background checks, and assess integrity risks before onboarding.

Our Standards in Practice
Do’s
✔ Uphold all Group policies at all times
✔ Report unethical or suspicious behavior
✔ Disclose conflicts of interest promptly
✔ Complete mandatory compliance training
✔ Exercise due diligence when dealing with third parties

Don’ts
✘ Offer or accept bribes, kickbacks, or facilitation payments
✘ Engage in or overlook money laundering
✘ Conceal or misrepresent facts during reporting or audits
✘ Bypass internal approval procedures
✘ Retaliate against whistleblowers or suppress reports

Governance & Oversight
• All policies under the BIM are reviewed annually by the Audit & Compliance Committee and approved by the Board where substantive changes are required.
• Employees undergo regular and role-specific training sessions to ensure understanding and implementation.
• A Local Point of Contact is appointed in every subsidiary to submit quarterly reports and maintain compliance trackers.

Raising Concerns
Employees, vendors, and stakeholders are encouraged to report concerns relating to:
• Bribery or corruption
• Sanction breaches
• AML violations
• Conflicts of interest
• ESG non-compliance
• Loss of trade license or fines above USD 50,000
Reports can be made directly to the Legal & Compliance Team or escalated to the Chairman of the Audit and Compliance Committee, depending on severity.

Our Message
Integrity is a shared responsibility. By following the Business Integrity Manual, every employee at Valency becomes a steward of our ethical values. Together, we ensure that we grow not only as a business, but as a responsible and trustworthy global organization.

Code of Conduct

Valency’s Code of Conduct (“Code”) is the foundation of our ethical culture. It defines how we work, how we interact with stakeholders, and how we uphold the principles that guide our global operations. The Code applies to all employees, vendors, clients, investors, and third-party associates of the Group, across every country where we operate.

Our Code is built on Valency’s “Shared Values” i.e., SUCCESS
• Sustainability: Dedication to responsible growth and lasting progress.
• Unity: Driven by purpose, connected by pride.
• Customer Focus: Listening, understanding and delivering.
• Collaboration: Teamwork across functions, excellence across results.
• Entrepreneurship: Ownership fuels innovation.
• Scalability: Agile, adaptable, and built to last.
• Synergy: Whole is greater than the sum of its parts.

What Our Code Stands For
We are committed to:
• Thriving with Excellence – Driving continuous improvement.
• Respecting Human Rights – Upholding fairness and dignity.
• Promoting Sustainability – Reducing environmental impact.
• Maintaining Transparency – In communication and transactions.
• Fostering Trust – With customers, partners, and communities.

Key Policies Under the Code
I. Business Integrity Manual (“BIM”)
• Conflict of Interest Policy
• Anti-Money Laundering Policy
• Anti-Bribery & Corruption Policy
• Due Diligence Policy
• Whistleblowers Policy
• Sanctions Policy

II. Human Resource Policies
• Fair Employment Practices Policy
• Business Continuity Plan
• Prohibition of Gender Based Violence & Harassment (GBVH) Policy
• Recruitment and Hiring Policy
• Internal Grievance Redressal Policy
• Social Media Usage & Awareness Policy
• Disciplinary Action Policy
• Dress Code Policy
• Employee Referral Policy
• Employee Separation Policy
• Family Employment Policy
• Medical Benefit Policy
• Remuneration Policy
• Retrenchment Policy
• Human Resources Manual

III. Environment, Health and Safety Policies
• Environmental, Social and Governance Policy

IV. Miscellaneous Policies
• Data Protection and Privacy Policy
• The Litigation Management Policy
• Transfer Pricing Policy

Do’s & Don’ts
Do:
✔ Abide by all laws and Valency’s internal policies
✔ Report misconduct or unethical behavior
✔ Respect diversity and promote inclusion
✔ Protect company and client data
✔ Prioritize safety, sustainability, and fairness

Don’t:
✘ Engage in bribery, fraud, or corruption
✘ Discriminate, harass, or retaliate against others
✘ Share confidential or sensitive information publicly
✘ Ignore sanctions or due diligence procedures
✘ Allow personal interests to influence business decisions

Upholding the Code
• Mandatory Training: All employees must complete onboarding and periodic training.
• Policy Access: Every employee receives a copy of the Code and annexed policies.
• Signed Acknowledgement: A formal undertaking is signed by all team members. • Reporting Mechanisms: Concerns can be reported confidentially and without retaliation.

Why It Matters
Valency’s Code of Conduct is more than just a document—it’s our identity. It shapes our culture, protects our reputation, and fosters long-term trust with clients, partners, and society. By living our values every day, we ensure we remain a respected global organization committed to integrity and impact.

Fair Employment Policy

We are committed to providing all our employees around the globe with a fair and equitable work environment and protect them with robust grievance redressal mechanisms. Our policies cover recruitment processes, gender diversity commitments, gender neutral sexual harassment policies and whistleblowing policy. These policies comply with local and international laws and conventions and reflect our values, culture and purpose.

Supplier Code

Our suppliers are our key stakeholders with whom we partner to deliver on our promises and grow as an organization. We ensure that the products and services we purchase are produced in a socially and environmentally responsible manner. Our suppliers are committed to operate in full compliance with local and international laws and their operations are free from exploitative practices like employing child labour.

Anti-Bribery Policy

We have a zero-tolerance approach for bribery across the jurisdictions that we operate in. As a Singapore headquartered organization we are foremost bound by the (Singapore) Prevention of Corruption Act, as well as the local anti-bribery and corruption laws in the countries where we conduct business. We ensure that our employees across the world are fully aware of local and international anti-corruption and anti-bribery laws and comply with them all times. The same extends to associated persons and entities with whom we do business.

Anti-Money Laundering and Sanctions Policy

Our extensive participation in global cross-border trade makes it imperative for us to have stringent policies in place to combat money-laundering and ensure that we are fully compliant with economic sanctions imposed by recognised supranational and government organisations. We have voluntarily chosen to adhere to The Financial Action Task Force (FATF) principles to align with international best practices in anti-money laundering and combating the financing of terrorism. This commitment and related policies aims to safeguard the company from being exploited for money laundering or terrorism financing in any form.

Whistleblowing

In order to ensure that our ethics and compliance framework truly works for all in our organization, we actively encourage our people and external parties to bring any breach to our immediate notice. Our whistleblowing policy provides secure channels that are easily accessible and totally anonymous.We provide support and protection from any kind of retaliation so that whistleblowers can raise complaints without fear or anxiety. All complaints are taken seriously, promptly escalated if required, thoroughly investigated and appropriate action taken.

Risk Management

In a dynamic global business environment, we consider risk management as a key component of our ethical and financial obligations to our staff, shareholders, customers & regulators. Responsible use of capital is a fundamental pre-requisite to deliver on our strategy and achieving profitable growth. Our Risk Policy clearly states the processes and provides a structured approach to quantify and manage risk.
The expectations and standards established by our risk policy go above and beyond those required by the policy and regulatory guidelines laid out by the local governmental, statutory and regulatory agencies.
The governance framework for our Risk Policy includes a Board Risk Panel (BRP) and a senior level Risk Monitoring Committee (RMC) headed by the Risk Manager with multiple checks and balances. Our Risk Management Policy embeds a culture where risk is everyone’s responsibility with close management oversight.

Sustainability Governance

We are committed to promoting sustainable practices throughout our operations which includes responsible sourcing, efficient use of resources, waste reduction, and minimising the environmental impact of our activities. We strive to adopt sustainable technologies and practices that conserve natural resources and minimise pollution.
We harness the power of our matrix organization structure to ensure that our partnerships in the communities we operate in, are self-sustaining and legally compliant. Traceability in our digitally enabled supply chain is an important element in ensuring that we have constant visibility on businesses across the globe for monitoring purposes.

News Awards & Articles

It is an honour to be recognised by others. In recent years, we have been proud to receive awards for excellence in sustainability, leadership, management, corporate responsibility, investor relations, corporate governance, transparency and the way we manage our workforce.