Corporate Governance

The Board of Directors of Silverlake Axis Ltd. (the “Company” or “SAL”) (the “Board”) recognises the importance of good corporate governance in ensuring greater transparency, protecting the interests of its shareholders as well as strengthening investors’ confidence in its management and financial reporting. Policies, processes and procedures have been instituted and are being regularly reviewed and revised to ensure effective corporate governance.

For more information, the Corporate Governance report is available for download below. You will need Adobe Acrobat Reader to view the pdf file.

Code of Conduct

Silverlake Axis is committed to conducting its business with the highest standards of integrity and professionalism. The Group’s business ethics involve honesty and fairness in dealing with customers, suppliers and competitors, and require employees to avoid any activity or interest which might reflect unfavourably upon their or the Group’s integrity or good name

Our Code of Conduct addresses the standard of business ethics of confidentiality, conflict of interests, fair dealing, anti-corruption, fraud and transparency of which any employee found to have acted in a way that is not consistent with the intent and/or principles of these Codes will be subject to disciplinary action up to and including termination of employment.

The Group also affirms principle of equal opportunities. Workplace harassment, discrimination of any kind and/or any other wrongful behaviour or activity that may create unfavourable working environment for any employee will also be subjected disciplinary action up to and including termination of employment.

The Group’s Code of Conduct has established professional, ethical and legal principles of which all employees are expected to embrace and practise while performing their day-to-day duties.

Whistle-blowing Policy


    • Silverlake Axis Ltd and its subsidiaries (’the Group’) are committed to a high standard of compliance
      with accounting, financial reporting, internal controls, corporate governance and auditing requirements and any legislation relating thereto. In line with this commitment, the Whistleblowing Policy (‘Policy’) aims to provide an avenue for employees and external parties to raise concerns and offer reassurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
    • The Policy is intended to conform to the guidance set out in the Code of Corporate Governance which encourages employees to raise concerns, in confidence, about possible irregularities.

    • This Policy applies to all employees of the Group.

    • Deter wrongdoing and to promote standards of good corporate practices
    • Provision of proper avenues for employees to raise concerns about actual or suspected improprieties in matters of financial reporting or other matters and receive feedback on any action taken
    • Give employees the assurance that they will be protected from reprisals or victimization for whistleblowing in good faith.

    • Some examples of concerns covered by this Policy include (this list is not exhaustive):

      • Concerns about the Group’s accounting, internal controls or auditing matters
      • Breach of or failure to implement or comply with the Group’s policies or code of conduct
      • Impropriety, corruption, acts of fraud, theft and/misuse of the Group’s properties, assets or resources
      • Conduct which is an offence or breach of law
      • Abuse of power or authority
      • Serious conflict of interest without disclosure
      • Intentional provision of incorrect information to public bodies
      • Any other serious improper matters which may cause financial or non-financial loss to the Group, or damage to the Group’s reputation
      • Fraud against investors, or the making of fraudulent statements to the Singapore Exchange Securities Trading Limited, members of the investing public and regulatory authorities
      • Acts to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of the Group
      • Concealing information about any malpractice or misconduct
    • The above list is intended to give an indication of the kind of conduct which might be considered as “wrong-doing”. In cases of doubt, the whistleblower should seek to speak to his or her immediate superior or follow the procedure for reporting under this Policy

    • If an employee raises a genuine concern under this Policy, he or she will not be at risk of losing his or her job or suffering from retribution or harassment as a result. Provided that the employee is acting in good faith, it does not matter if he or she is mistaken.
    • However, the Group does not condone frivolous, mischievous or malicious allegations. Employee(s) making such allegations will face disciplinary action in accordance with the Group’s Disciplinary Procedures.

    • The Group encourages the whistleblower to identify himself/ herself when raising a concern or providing information. All concerns will be treated with strict confidentiality.
    • Exceptional circumstances under which information provided by the whistleblower could or would not be treated with strictest confidentiality include:
      • Where the Group is under a legal obligation to disclose information provided
      • Where the information is already in the public domain
      • Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice
      • Where the information is given to the Police or other authorities for criminal investigation
    • In the event we are faced with a circumstance not covered by the above, and where the whistleblower’s identity is to be revealed, we will endeavour to discuss this with the whistleblower first.

    • Concerns expressed anonymously are much less persuasive and may hinder investigation work as it is more difficult to look into the matter or to protect the whistleblower’s position. Accordingly, the Group will consider anonymous reports, but concerns expressed or information provided anonymously will be investigated on the basis of their merits.

    Who to Report To

    • Report to
    • Internal staff may download the report form from AAMS
    • External parties may use the link provided on our website in the Corporate Governance
    • Concerns or information are preferably raised or provided in writing (letter or e-mail). Ideally, the Group recommends the whistleblower to be detailed in setting out the background and history of events and the reasons for the concern.
    • If the whistleblower is not comfortable about writing in, he or she can telephone or meet the appropriate officer in confidence at a time and location to be determined together.

    • The earlier the concern is raised the easier it is for the Group to take action.
    • The Group expects the whistleblower to provide his/her concern in good faith and to show to the appropriate officer that there are sufficient grounds for his/her concern.
    • The Group also recognises that the whistleblower may wish to seek advice and be represented by his/her trade union officer.

    • The Group assures you that any concern raised or information provided will be investigated, but consideration will be given to these factors:
      • Severity of the issue raised
      • Credibility of the concern or information
      • Likelihood of confirming the concern or information from attributable sources
    • Depending on the nature of the concern raised or information provided, the investigation may be conducted involving one or more of these persons or entities:
      • The Audit Committee
      • The External or Internal Auditor
      • Forensic Professionals
      • The Police or Commercial Affairs Department
    • The amount of contact between the whistleblower and the person(s) investigating the concern raised and information provided will be determined by the nature and clarity of the matter reported. Further information provided may be sought from the whistleblower during the course of the investigation.
    • The investigating officer(s) will communicate the findings of the investigation(s) to the Audit and Risk Committee (“ARC”) for their necessary action.

Making a Report

Kindly download the form at below and email to

Anti-Bribery and Anti-Corruption Policy

Silverlake Axis Ltd (‘SAL’) and its subsidiaries (the ‘Group’) is committed to conduct its business with integrity. In line with this commitment, the Group has adopted a zero-tolerance policy against all forms of bribery and corruption. This Anti-Bribery and Anti-Corruption Policy (‘Policy’) aims to set out the parameters to prevent the occurrence of bribery and corrupt practices within the Group.

Code of Conduct for Third Parties

SAL Group has formulated certain guidelines and good business practices and incorporated the same into this SAL Group Code of Conduct for Third Parties.