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Anti-Bribery and Corruption (ABC) Policy

1. Introduction

Rankpage Pte. Ltd. (“the Company”) is committed to conducting all business activities with integrity, transparency, and accountability. This Anti-Bribery and Corruption (ABC) Policy outlines the Company’s zero-tolerance stance against bribery and corrupt practices in all business dealings, particularly in relation to operations connected to Singapore and any Singapore-based stakeholders.

This Policy is designed to comply with Singapore’s Prevention of Corruption Act (PCA) and applicable anti-corruption standards enforced by the Corrupt Practices Investigation Bureau (CPIB).

2. Compliance with Singapore Law

The Company strictly complies with the Prevention of Corruption Act (Cap. 241) of Singapore.

Under the PCA, it is an offence to:

  • Offer, give, request, or receive any gratification as an inducement or reward for doing or not doing anything in connection with a business transaction or public duty.
  • Engage in corrupt conduct whether directly or indirectly, including through third parties.

Singapore law applies to both domestic and overseas acts involving Singapore-linked business activities, and individuals and companies may be held liable regardless of where the act occurs.

3. Application and Scope

This Policy applies to all individuals and entities acting on behalf of or in connection with Rankpage, including:

Employees

  • Full-time, part-time, probationary, contract, and temporary employees
  • Directors and senior management

Third Parties

  • Customers and clients
  • Business partners and vendors
  • White-label partners, resellers, agents, contractors, and consultants
  • Any other persons or entities performing services for or on behalf of the Company

4. Prohibited Conduct

4.1 Bribery and Corrupt Gratification

Employees and associated third parties must not, directly or indirectly:

  • Offer, promise, give, request, or accept any gratification (financial or non-financial)
  • Engage in conduct intended to improperly influence a business decision or outcome
  • Use intermediaries or agents to conceal corrupt practices

“Gratification” includes money, gifts, loans, fees, rewards, commissions, employment opportunities, or any other benefit.

4.2 Facilitation Payments

Facilitation payments (payments made to expedite routine administrative actions) are strictly prohibited, even if common practice in certain jurisdictions. Any request for such payments must be:

  • Declined immediately; and
  • Reported to Management or Compliance without delay

5. Gifts, Hospitality, and Entertainment

The Company recognises that reasonable hospitality and gifts may form part of legitimate business relationships. However, they must:

  • Be modest, appropriate, and proportionate
  • Not create an obligation or expectation of favour
  • Not influence or appear to influence business decisions
  • Be transparent and properly recorded where applicable

Gifts or hospitality must never be offered or accepted in circumstances where they could be perceived as improper inducements.

6. Third-Party Due Diligence and Contractual Controls

The Company will conduct appropriate due diligence on all third parties prior to engagement or renewal of contracts.

All agreements must include:

  • Anti-bribery and corruption clauses
  • The right for the Company to audit or request compliance confirmation
  • The right to terminate contracts in the event of suspected or actual corruption

6.1 Conflict of Interest

Employees and third parties must avoid any situation where personal interests conflict, or may appear to conflict, with the interests of the Company.

All actual, potential, or perceived conflicts of interest must be:

  • Disclosed promptly to Management
  • Properly documented
  • Managed to ensure fair and independent decision-making

Individuals with conflicts must recuse themselves from related decisions unless formally approved otherwise.

7. Whistleblowing and Reporting

The Company encourages reporting of any actual or suspected breaches of this Policy.

Reports may be made confidentially via: [email protected]

All reports will be handled seriously, confidentially, and investigated appropriately.
The Company strictly prohibits retaliation against any individual who raises concerns in good faith.

8. Monitoring, Compliance, and Enforcement

The Board of Directors is responsible for overseeing compliance with this Policy and ensuring periodic review to maintain alignment with Singapore legal and regulatory expectations.

Failure to comply with this Policy may result in:

  • Disciplinary action (including termination of employment or contract)
  • Contract termination
  • Civil or criminal liability under Singapore law