Manulife US REIT - Annual Report 2021

MANULIFE US REIT 108 Employee Code of Business Conduct and Ethics As a subsidiary of Manulife Group, the Manager adheres to its Code of Business Conduct and Ethics. The Code sets out guiding principles for employees in carrying out their duties to the highest standards of business integrity. It covers areas of conduct in the workplace, business conduct, conflicts of interest, whistle-blowing process as well as prohibitions against bribery and corruption. Employees who violate the Code will be subjected to appropriate disciplinary action, including termination of employment and prosecution. Aligning with the Group’s core value of ‘Do the right thing’, compulsory and voluntary training are available to employees to ensure that they understand their roles and reporting obligations. New hires are subject to mandatory orientation and induction programmes. The compliance team delivers regular updates on legal and organisational standards to the Board of Directors and employees. On an annual basis, all employees are required to undergo training on Anti-Money Laundering and Countering the Financing of Terrorism, Anti-Bribery and Anti-Corruption Compliance, Information Protection and Code of Business Conduct and Ethics so as to ensure that employees are aware of the importance of complying with relevant laws, as well as to educate employees on policies regarding gifts and entertainment. In addition to completing a certification of compliance with the Code of Business Conduct and Ethics annually, employees are also required to update their respective Conflict of Interest Disclosure questionnaire annually and whenever any actual conflict, potential conflict or the appearance of a conflict of interest arises. We are committed to preventing any breaches of sensitive issues that might lead to consequences beyond fines. Therefore, by equipping our employees with the necessary knowledge and skills, we can avoid any potential breaches altogether. The Manager has put in place an orientation programme with formal training to ensure that all newly appointed directors are familiar with MUST’s business, strategies, directions and the regulatory environment in which MUST operates as well as themain corporate governance practices of the Manager. Relevant training on matters such as directors’ duties and responsibilities and code of ethics are also arranged by the Manager for all directors. In 2021, such training sessions included seminars organised by the REIT Association of Singapore (REITAS) and the Singapore Institute of Directors, as well as a one-day course on ESG and Materiality Reporting conducted by the SMU. CMS representative license holders are responsible for functions ranging from asset management, investment management, finance to investor relations. To stay up to date with market regulations, they must attend regular training. As at 31 December 2021, 13 out of 19 full-time employees of the Manager are CMS representative licence holders under the SFA of Singapore. Responsible Supply Chain Responsible business practices are adopted across our supply chain. Vendors who work with MUST are expected to adhere to the Group’s Vendor Code of Conduct, which reinforces the principles of ethical business practices and good governance from suppliers. The Vendor Code of Conduct covers areas pertaining to business conduct, labour practices, health and safety and environmental management. Compliance in our Properties We have a responsibility to ensure that our tenants and users of our properties remain safe from injury in our properties. The Property Manager has a compliance team to manage compliance at the property level. Regular training and engagement sessions are conducted for tenants to raise any relevant issues. Grievancemechanisms such as feedback channels, anonymous hotlines, andwhistle-blowing channels are also available for all other stakeholders. During the reporting year, there were zero incidents of non-compliance and corruption. Recognised for Governance We take pride in establishing strong corporate governance practices that areat the forefront of the industry inSingapore. Being qualified as an SGX Fast Track issuer for the fourth consecutive year, MUST is recognised for its high corporate governance standards and good compliance track record. Companies in this programme enjoy prioritised clearance for selected corporate action submissions to SGX RegCo. Reflecting its robust governance practices that are well aligned with investor interests, MUST was upgraded to an ‘AA’ from ‘A’ in MSCI ESG Ratings 2021, placing us within the top 26% of MSCI All Country World Index constituents. We also maintained our ‘A’ grade in GRESB Public Disclosure Assessment for the second year running for our high level of material sustainability disclosures, ranking 2 nd out of 10 peers in Asia. In the 2021 Sustainalytics ESG Risk Ratings, we achieved the highest ‘Negligible’ risk rating, ranking top 2% out Driving Sustainable Growth