1. Introduction

NetLink NBN Trust and its subsidiaries (collectively referred to as the “Trust Group”) recognise the importance of, and are committed to conducting business with the highest standards of integrity and ethics, and minimizing our impact on the environment. The Trust Group’s commitment extends to its procurement activities, and the Trust Group therefore requires all of its Suppliers to meet the minimum standards set out in this Code.

The Trust Group expects Suppliers to establish and maintain the necessary internal management systems to ensure compliance to this Code by its employees, agents, subcontractors or other relevant third parties in the supply chain.

For the avoidance of doubt, the Suppliers’ obligations under this Code are not exhaustive, and may be supplemented by additional obligations set out in the specific contracts between the Suppliers and the Trust Group.

2. Laws and Regulations

Suppliers must fully comply with all laws and regulations that apply to them in the countries that they operate in. Such laws and regulations shall include, but not limited to those governing corruption, competition, labour and the environment.

3. Anti-Corruption

The Trust Group observes a zero-tolerance policy with regards to any form of unlawful, improper or dishonest practices, including but not limited to bribery, corruption, fraud or misrepresentation.

Suppliers must not give, promise or offer to any of the Trust Group’s directors, officers, employees or representatives (or their respective family members), be it directly or indirectly, money, gifts, entertainment or any other inappropriate financial and/or non-financial benefit for the purpose of securing contracts or business transactions, or to obtain a business advantage.

In the event that any director, officer, employee or representative of the Trust Group requests for any improper benefits that would cause a Supplier to breach its obligations under this Code, that Supplier must report the request for improper benefits to the whistleblowing channels stated in Clause 12 below.

4. Conflicts of Interest

Suppliers must promptly report any actual or potential conflict of interests between the Supplier and the Trust Group as and when such conflicts arise or are anticipated to arise. A conflict of interest may be professional or personal in nature. An example of a conflict of interest which is personal in nature is where the employee who is negotiating a transaction with the Trust Group on the Supplier’s behalf is a family member of the Trust Group’s employee who is involved in evaluating the said transaction.

If the Supplier is unsure whether a conflict of interest exists, the Supplier should err on the side of caution and declare the circumstances to the Trust Group, via an email to This email address is being protected from spambots. You need JavaScript enabled to view it..

5. Anti-Competitive Practices

The Trust Group expects all Suppliers to submit their proposals in good faith. This means that Suppliers must not enter into any arrangements with other suppliers (related or otherwise) to do any of the following:

  1. fix or adjust the price or other terms of any proposals;

  2. submit any form of non-competitive proposal;

  3. withdraw or vary any proposal after submission; and/or

  4. otherwise collude with any person in any manner whatsoever.

Suppliers shall provide honest and accurate representations concerning itself and its goods and services. Suppliers must not mislead or deceive the Trust Group prior to or in the course of any contractual or business dealings with the Trust Group.

6. Human Rights, Discrimination and Labour Standards

The Trust Group is committed to treating all people equally with respect, care and dignity. Suppliers are accordingly expected to adopt policies that promote respect for human rights, and adoption of fair and ethical employment practices. Such policies should include, but are not limited to, the following:

  1. Suppliers must create and maintain a meritocratic working environment that provides equal opportunity for all of their employees. Suppliers should not discriminate on grounds of race, language, religion, age, gender, marital status, political convictions, pregnancy or disability.

  2. Employment terms must meet the minimum requirements and standards under the applicable laws and regulations. For example, Suppliers are expected to provide employees with:

    1. i. Timely and full payment of wages, provident fund contributions, and other benefits prescribed under the applicable laws; and
    2. ii. Reasonable working hours and conditions for its employees with proper rest days and breaks. All work, including overtime work, should be voluntary.

  3. Child, forced or involuntary labour are strictly prohibited. Suppliers must have procedures in place to verify an employee’s age and legal right to work in the country prior to employment.

7. Health and Safety

Suppliers are expected to create a safe and healthy work environment for their employees. In this regard, Suppliers should have an effective occupational health and safety program (e.g. OHSAS 18001) in place to promote workplace health and safety. The program should involve inter alia the implementation of workplace health and safety policies, risk assessments to identify and eliminate safety hazards, safety audits and external certification of the occupational health and safety program.

Suppliers shall also ensure that its employees and subcontractors are not under the influence of alcohol, drugs, or other incapacitating substances when provisioning goods or services to the Trust Group.

8. Environmental Protection

Suppliers should continually assess their operations and have the relevant procedures in place to ensure that environmental laws are not breached. For example, factory emissions should be kept within the regulated limits, hazardous and non-hazardous waste should be disposed through the channels prescribed under the relevant laws and regulations.

Suppliers should minimize the environmental impact of their business operations and implement the appropriate measures for the protection of the environment. This includes the implementation of green initiatives to reduce waste and carbon emissions, and to promote recycling programs, where relevant.

9. Access to the Trust Group’s Information Systems

Suppliers may be given access to the Trust Group’s information systems during the course of supplying goods and services to the Trust Group. In such cases, Suppliers must comply with all of the procedures and policies put in place by the Trust Group to protect the availability, confidentiality and integrity of the Trust Group’s information, which may require the adoption of the following non-exhaustive list of measures:

  1. Ensuring that any software or hardware used to access the Trust Group’s information systems are free of harmful code;

  2. Obtaining and maintaining valid licences for the use of all software used to access the Trust Group’s information systems;

  3. Implementing the appropriate internal systems for the purpose of safeguarding any personal data and confidential information stored on the Trust Group’s information systems;

  4. Installation of antivirus software on the equipment used to interface with the Trust Group’s information systems; and

  5. Setting up secure passwords and access credentials.

10. Rendering Assistance to Trust Group

Suppliers shall cooperate with the Trust Group in its investigations into any allegations of non-compliance with this Code.

11. Consequences

If a Supplier notes a non-compliance issue, the Supplier should report this promptly to This email address is being protected from spambots. You need JavaScript enabled to view it.. Such notification must include details of the steps that the Supplier will implement to rectify the non-compliance and to prevent further non-compliances.

For breach of ethical standards on the part of any of the Trust Group’s director, officer, employee or representative, this should be reported to the whistleblowing channels stated in Clause 12 below.

The Trust Group reserves the right to conduct an independent investigation into any breach of this Code and to take such actions that it deems fit in its discretion, including issuing warnings, or enforcing its legal rights against the Supplier.

12. Reporting Channels

For any queries related to this Code, please send an email to This email address is being protected from spambots. You need JavaScript enabled to view it..

Whistleblowing reports can be made through the following channels:

  1. Web portal: https://www.kpmgethicsline.com.sg/

  2. Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

  3. Telephone number: +65 6213 3232

  4. Post: KPMG Services Pte. Ltd.
        16 Raffles Quay
        #22-00 Hong Leong Building Singapore 048581
        Attn: KPMG EthicsLine Manager (KPMG Forensic)

  5. Fax: +65 6223 0428

13. Conclusion

For the avoidance of doubt, this Code does not create any binding obligations on the Trust Group (or any entity within the Trust Group). This Code may be amended from time to time at the Trust Group’s discretion, and the latest copy of this Code will be made available at http://netlinktrust.com/about-us/about/supplier-code-of-conduct.html. Suppliers are encouraged to check the website from time to time.