IREIT Global
annual report 2014
Corporate
Governance Report
1
The cost of such engagement of KPMG to carry out compliance activities is borne by the Manager out of its own funds and not out of
Unitholders’ funds.
The Board, with the concurrence of the ARC, is of the
opinion that the Manager’s internal controls were
adequate as at 31 December 2014 to address financial,
operational, compliance and information technology
security risks of IREIT, based on the risk management
and internal controls framework established and
maintained by the Manager, work performed by both
internal and external auditors as well as reviews
performed by management and the ARC.
Anti-Money Laundering and Countering the
Financing of Terrorism Measures
The Manager as holder of a CMS Licence needs
to comply with MAS’ Notice on the Prevention of
Money Laundering and Countering the Financing of
Terrorism (the “Notice”). Under the Notice, the main
obligations of the Manager include:
•
Customer due diligence;
•
Ongoing customer monitoring;
•
Suspicious transaction reporting;
•
Record keeping; and
•
Staff training.
The Manager organised an anti-money laundering
training session for the Board members, its licensed
representatives and employees which covered the
applicable regulations on anti-money laundering
and countering the financing of terrorism under the
Notice.
Compliance Officer
The Manager has engaged KPMG Services Pte. Ltd.
(“KPMG”) to carry out certain compliance activities
on a quarterly basis
1
. KPMG’s scope of engagement
covers assessing the Manager’s compliance with
applicable provisions of the SFA through the conduct
of quarterly checks on:
(i) whether the representatives of the Manager
have fulfilled their regulatory obligations; and
(ii) whether the Manager, in its role as REIT
manager, has prepared returns and other
documents accurately for submission to the
MAS.
KPMG will report the results of its activities to the
CEO and the Board on a quarterly basis.
KPMG will also provide advice and training
on compliance requirements under the SFA to
representatives of the Manager.
KPMG will also provide regulatory compliance advice
from time to time as may be required by the Manager.
Notwithstanding the engagement of KPMG to carry
out certain compliance activities on a quarterly basis,
the Manager is responsible for ensuring compliance
with all applicable laws, regulations and guidelines.
Dealings in Units
Each director and the CEO of the Manager is to give
notice to the Manager of his acquisition of or any
changes in the number of Units which he holds or in
which he has an interest, within two business days
after such acquisition or the occurrence of the event
giving rise to changes in the number of Units which
he holds or in which he has an interest.
All dealings in units in IREIT b
announced via SGXNET, with th
posted on the SGX-ST website at
The directors and employees
prohibited from dealing in the Units:
• in the period commencing one month before the
public announcement of IREIT’s annual results
and property valuations, and two weeks before
the public announcement of IREIT’s quarterly
results and ending on the date of announcement
of the relevant results or, as the case may be,
property valuations; and
