Elite UK REIT (“Elite REIT”) is a real estate investment trust constituted by the trust deed dated 7 June 2018 (and as may be amended, varied or supplemented from time to time) (the “Trust Deed”), and entered into between Elite UK REIT Management Pte. Ltd. (in its capacity as the manager of Elite REIT) (the “Manager”) and Perpetual (Asia) Limited (in its capacity as the trustee of Elite REIT) (the “Trustee”). The Manager was issued a capital markets services licence by the Monetary Authority of Singapore (“MAS”) for REIT management (“CMS Licence”) pursuant to the Securities and Futures Act 2001 of Singapore (the “SFA”) on 22 January 2020.
Elite REIT and Corporate Governance
The framework of relevant legislation and guidelines governing Elite REIT include:
- the Securities and Futures Act 2001 of Singapore (the “SFA”);
- the Code on Collective Investment Schemes (including Appendix 6 thereon on property funds) (the “CIS Code”, and Appendix 6 of the CIS Code, the “Property Funds Appendix”);
- the listing manual (the “Listing Manual”) issued by Singapore Exchange Securities Trading Limited (“SGX-ST” or the “Exchange”);
- the Code of Corporate Governance 2018 (the “Code”);
- the Trust Deed; and
- written directions, notices, codes and other guidelines that may be issued, modified or updated by the MAS from time to time.
The Manager is fully dedicated to upholding the highest standards of corporate governance, business integrity and professionalism in all its activities. The Manager believes that its sound corporate governance policies and practices reflect its focus on strong leadership, effective internal controls and risk management, a robust corporate culture, accountability to the Unitholders, and engagement with stakeholders.
Click here to download full Corporate Governance Report.
Code of Conduct and Ethics
Our Code of Conduct and Ethics Policy (“Policy”) sets out the principles and standards of conduct expected of all Board of Directors, employees and representatives (“Covered Persons”) of Elite Partners Holdings Pte. Ltd. (“EPH”), Elite Partners Capital Pte. Ltd. (“EPC”), Elite UK REIT Management Pte. Ltd. (“EURM”) (each an “Elite Company”) including each Elite Company’s parent institution, subsidiaries, affiliates and any entity that the Elite Company exerts control over or that exerts control over the Elite Company (collectively, EPG” or the “Group”).
The policy emphasises the importance of ethical behaviour, accountability, and compliance. Covered persons must act with honesty, integrity, and respect. Accountability for actions and decisions is expected from all. Compliance with laws, regulations, and internal policies is mandatory, and conflicts of interest must be disclosed and mitigated.
The policy states that maintaining confidentiality is crucial for trust and legal compliance. Covered Persons are to protect sensitive information from unauthorized access and disclosure, use confidential information only for legitimate business purposes, and report any breaches of confidentiality immediately. Confidential information includes client data, internal policies, and employee information.
The policy also covers areas such as fair dealing and due diligence practices, commitment to anti-discrimination and anti-harassment, personal data protection compliance, prohibition of insider trading, compliance with anti-money laundering and counter-terrorism financing laws, guidelines on gifts and entertainment, whistleblowing, as well as disciplinary actions for policy breaches. The policy will be periodically reviewed and updated to align with regulations.
Whistleblowing
Whistleblowing refers to the making of certain disclosures (via a dedicated and clearly communicated reporting mechanism) of actual, suspected, or potential (or “reasonably anticipated”) conduct that an individual reasonably believes to be unlawful.
Disclosures can be made by any third party engaged in a business relationship with EURM about serious breaches observed in their dealings with EURM. This includes the reporting of information alleging serious breach of laws, regulations, or ethics by another EURM employee(s).
You may raise genuine concerns about possible improprieties in the conduct of EURM’s business, whether in matters of financial reporting or other malpractices, at the earliest opportunity in an appropriate way.
Click here to read Elite UK REIT’s Whistleblowing Statement.
