Code of Conduct in Business Relationships


Business ethics is relevant to the conduct of individuals and also to the conduct of the organisation as a whole. As such, York Hotel Singapore is committed to observe its social and ethical standards in all its business activities. This Code of Conduct in Business Relationships (the “Code”) covers a range of business practices and procedures. The Code does not cover every issue that may arise, but sets out basic principles to guide all employees of York Hotel Singapore.

This Code may be amended or modified only by the Management of York Hotel Singapore. Failure to work in accordance with the Code will be treated seriously. This may result in disciplinary action being taken which, in some cases, may include dismissal in accordance with our internal policies and local labour and employment laws.

In addition, this Code is applicable to all employees of York Hotel Singapore, including, without limitation, General Manager, members of the Management or Executive Committee and other persons (collectively, “team members”) who work in or are affiliated with “Goodwood Park Hotel Private Limited” or in association with the “Goodwood Park Hotel Private Limited”, “Goodwood Park Hotel”, “York Hotel”, or “Royal Garden London” owned by Goodwood Park Hotel Private Limited.



1.1 Conducting business with honesty and integrity
a) Employees shall ensure that procurement contracts are awarded and administered free from improper influence.

b) Circumstances might arise that could call the Employee’s impartiality into question. When any such conflict of interest arises, the Employee shall promptly consult and involve the Compliance Manager in evaluating the potential conflict of interest.

c) Partners or family members shall not receive personal benefits as a result of an Employee’s position at the company.

d) Employees shall comply with Company guidelines regarding the acceptance of gifts and hospitality.

1.2 Corporate Citizenship
a) Employees are expected to be aware of and to advance the objectives and core values of the Company at all times.

b) In this regard, Employees are expected to:
  • Be committed to deliver shareholder value and to manage the company for its stakeholders;
  • Maintain high standards of service quality and work efficiency;
  • Properly manage risk for and on behalf of the company; and
  • Always conduct themselves in a manner that is professional and respectable and to avoid promulgating any information that is deceptive, misleading or unfair.
  • Employees should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other practices that may violate the laws designed to prevent unfair competition or anti-competitive practices.

1.3 Compliance with Laws and Policies
a) Employees shall at all times :
  • Be familiar with and comply with the Company’s internal policies and processes; and
  • Abide by the applicable laws, rules and regulations.
  • Be accountable and adhere to the Code of Ethics prescribed by the company.
b) Employees must never lead a supplier or client to believe that they can inappropriately influence any procurement decisions at the Company.

c) Real or perceived conflicts of interest in the procurement process should be avoided at first instance, and where unavoidable and inevitable, proper disclosure must be made.

d) Any concerns regarding compliance with the Company’s Code of Ethics shall be raised and reported immediately to the Compliance Manager.

1.4 Anti-Money Laundering (AML) Compliance
a) The company is committed to operating with integrity. Bribery and any form of financial crime, including improper payments, money laundering and tax evasion or the facilitation of tax evasion, are not permitted under any circumstances. This also applies to any agents, consultants and other service providers who do work on our behalf. Bribes are intended to influence or encourage someone to act improperly. They can include payments or anything of value, such as complimentary rooms.

1.5 Competition and Fair Dealing
a) Employees shall select suppliers and award business on the basis of fair competition.  Arrangements with or among suppliers that could potentially limit or distort competition shall be avoided.
1.6 Delegation of Authority
a)  Employees shall abide by the Company’s delegation of authority policies and procedures.

b) Employees should:
  • Only act within the delegation of authority rules and any authority that may specifically be given to them as delegated authority that may specifically be given to them as a delegated authority leader; and
  • Ask their Supervisors if they are uncertain as to their delegated authority level.

1.7 Protection and Proper Use of Corporate Assets
a) Employees should protect the assets of the Company so as to ensure their efficient use for legitimate business purposes only. No funds, assets, services or facilities of the Company (including, for the purposes hereof, without limitation, complimentary items, discounts and amenities) may be used, directly or indirectly, for any unlawful or unethical purpose. Use the property of the Company only for legitimate purposes, as authorised in connection with your job responsibilities.  Employees should not share or use computer access information of the Company, such as passwords.

b) Any concerns regarding compliance with the Company’s Code of Conduct in Business Relationships shall be raised and reported immediately to the Compliance Manager.

1.8 Handling Personal Data
a) York Hotel Singapore collects personal data such as names, contact details and other information that directly or indirectly identifies an individual – from guests, colleagues, shareholders, owners and business partners. We may also handle more sensitive personal data, such as information revealing racial or ethnic origin or data concerning health. Global data privacy laws (also known as data protection laws) determine how we need to treat this data. Complying with these laws is an essential part of doing business responsibly. In particular, we must safeguard personal data from loss, disclosure or misuse in accordance with data protection laws, procedures and contractual obligations.  We must also consider what information we need to give people about how we handle their personal data to ensure we are acting fairly and transparently.

For more information on our Privacy Policies, please visit .

1.9 Reporting Procedures
a) In the event that members of the public feel uncomfortable about a situation or have any doubts about whether it is consistent with York Hotel Singapore’s Code of Conduct in Business Relationships and wish to report known or suspected violations of the law or this Code can email to

All reports will be handled sensitively and with discretion. Your confidentiality will be protected to the extent possible.

b) Employees have a duty to report any known or suspected violations of this Code, including violation of the laws, rules, regulations or policies that apply to the Company. If you know of or suspect a violation of this Code, immediately report the conduct to the Compliance Manager.

Adopted by the Management on August 1, 2018