Vendor Code Of Conduct
Updated as of 1 December 2025
1. Preamble
This Vendor Code of Conduct (“Code”) is intended to be read consistently and in conjunction with the terms and conditions in the relevant Subcontractor Contract or Purchase Order (“PO”) as the case may be. In the event of any conflict or inconsistency between the terms and conditions herein and:
(a) the Special Conditions and/or Standard Conditions of the Subcontractor Contract; or
(b) the Terms and Conditions in the PO and/or Standard Terms and Conditions Appendiced to the PO,
priority shall be accorded in line with Clause 2 of the Standard Conditions of the Subcontractor Contract or Clause 1 of the Standard Terms and Conditions Appendiced to the PO, as the case may be.
2. Scope and Objectives
(a) This Code sets out the minimum standards of conduct to which DLE M&E Pte Ltd’s (“DLE”) suppliers, contractors, and sub-contractors (“Vendor(s)”) are expected to adhere.
(b) This Code applies to all current and future Vendors of DLE and their related entities, subsidiaries, and employees.
(c) This Code may be amended by DLE from time to time without notice. Vendors are expected to keep themselves updated as to the prevailing applicable standards and obligations under this Code.
3. Compliance with Laws
Vendors shall comply with all applicable laws, regulations and authority requirements. Where standards under this Code differ from the applicable laws or regulations, Vendors shall abide by the stricter requirements.
4. Anti-corruption and Anti-bribery
DLE takes a zero-tolerance stance towards any form of corruption and bribery. Vendors are expected to operate with a high degree of honesty and integrity and to have in place internal policies and systems to this end.
(a) Vendors shall not directly or indirectly solicit or receive, or agree to receive for themselves or for any other person, any bribe, unauthorized payment, kickback, inappropriate incentive or benefit in order to gain an improper advantage.
(b) Vendors shall comply with all anti-corruption and anti-bribery laws and regulations, including but not limited to the Prevention of Corruption Act 1960.
5. Anti-Money Laundering
Vendors shall comply with all applicable anti-money laundering laws and regulations, and shall refrain from engaging in or supporting any activity which infringes or circumvents the applicable laws and regulations against money laundering.
6. Adverse Business Conduct
(a) Vendors shall observe strict confidentiality and shall not access or disclose to any party information and/or documents gained from or arising out of its contractual relationship with DLE. This obligation shall survive the expiry or earlier termination of any contractual relationship between a Vendor and DLE.
(b) Vendors shall remain free from conflicts of interest that may adversely affect their business relationship with DLE. In the event of any actual, perceived or potential conflict of interest, Vendors shall promptly disclose the same to DLE.
(c) To the extent permitted under law, Vendors shall not, whether directly or indirectly, solicit, entice or induce any employee or customer of DLE to terminate or alter their relationship with DLE.
(d) Vendors shall not engage in any activity or conduct that is likely to result in DLE’s business operations and reputation being compromised. This includes but shall not be limited to the unauthorised use of DLE’s name, logo, trademarks, or any other intellectual property, and engaging in any activity or conduct which may have the effect of associating DLE with dishonest or unethical business practices.
7. Workplace Health and Safety
Vendors are expected to have in place effective health and safety policies and/or systems to:
(a) Provide a safe working environment to all its employees;
(b) Identify and assess health and safety risks in the workplace, and take action to prevent, reduce or control such risks to an acceptable level; and
(c) Comply with all applicable legal and regulatory requirements relating to workplace health and safety, including under the Workplace Health and Safety Act 2006, as well as any additional requirements that may be imposed from time to time under the contractual relationship between DLE and the Vendor.
8. Privacy and Data Protection
(a) Vendors are expected to comply with all applicable privacy and data protection laws and regulations, including but not limited to the Privacy and Data Protection Act 2012.
(b) Any Vendor that accesses, handles, collects, or processes data and/or information from DLE or on DLE’s behalf is expected to have in place sufficient measures and internal policies to protect such data and/or information from unauthorised use or access.
(c) Vendors are expected to notify DLE without undue delay if they become aware of any data breach or incident that may affect DLE, and will work with DLE to respond to such breach or incident.
9. Compliance
(a) Vendors are expected to adhere to and monitor compliance with the Code at their own cost. The execution of the relevant Subcontractor Contract or Purchase Order incorporating this Code shall be taken as the Vendor’s acknowledgement and confirmation that its operations are in full compliance with this Code.
(b) Vendors are expected to communicate the requirements under this Code to their own suppliers, subcontractors, and employees to secure their compliance with the same.
(c) Vendors shall provide their full cooperation and assistance to DLE in any investigation or assessment relating to the compliance with this Code.
(d) DLE reserves the right to audit Vendors based on this Code.
(e) The Vendor agrees that any failure of a Vendor to comply with this Code shall constitute a breach of the Subcontract or PO as the case may be, and may result in further action being taken against it by DLE, including suspension or termination of existing contract(s) or the business relationship, suspension of payments, setting off any costs of enforcement incurred by DLE against any payments due to the Vendor as may be (or shall become) certified by DLE, and/or legal action. For the avoidance of doubt, any costs of legal action or enforcement taken by DLE pursuant to this Code shall be at the Vendor’s cost, and DLE reserves all rights to recover the aforesaid costs from the Vendor.
10. Reporting Concerns
(a) Any person may raise or report concerns regarding any actual or suspected breach of this Code to DLE at hrteam@dle.com.sg or
by arranging a meeting with the Managing Director and/or Human Resource Director. All such reports should be accompanied by supporting evidence or sufficient details where available, to support DLE’s investigation into the reported breach.
(b) Any person making a report in relation to this Code is not required to reveal their identity unless they choose to do so.
(c) All reports made in relation to this Code shall be treated with strict confidentiality, subject to any disclosure requirements required under law.
(d) DLE shall not tolerate harassment or retaliation of any kind against a person who submits a report in good faith. If any person believes that they are being subject to harassment or retaliation for reporting their concerns, they should immediately report these acts to the Managing Director of DLE.