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  • Writer's pictureWT Jen Siow

Make Compliance Culture Circular


Growing up or living together in any household likely has one common thread - each member is conditioned to observe the household order. A desired behaviour is introduced for the unit to embrace, that if upheld, a reward emanates, just as a defiant behaviour would be accorded with punishment. Across many cultures, this conduct correction is the building block for integrity, and we see this universally reflected in common courtesies so as to assimilate into any society.


In any organisation, institution and office, this is `compliance’ – characterising an obligation to conform to sets of rules. Rules can be in the forms of laws, regulations, policies, instructions and processes. When validating the exigency for compliance, the values of the organisation are emphasised, as well as asserting the consequences of breaking the rules. Our actions must err on the side of laws.


In Singapore, there was much public interest in the leasing of heritage colonial bungalows to two prominent figures, the Law & Home Affairs Minister and Foreign Affairs Minister. Questions were explicitly raised as to whether the Ministers “were paying rent below fair market value” for the properties and whether the Ministers had received preferential treatment by the Singapore Land Authority (SLA) which manages the conservation of such properties. The SLA falls under the purview of the Law & Home Affairs Ministry.


Prime Minister Lee Hsien Loong instructed the Corrupt Practices Investigation Bureau (CPIB) to investigate for corruption and criminal wrongdoings in the leasing transactions. CPIB has not identified elements of corruption or abuse of position. Nonetheless, matters pertaining to due processes & transparency in government, and the integrity of ministers were of contention in a lengthy Parliamentary debate. In response to questions and to echo the findings in CPIB’s investigation, the Law & Home Affairs Minister reiterated his recusal from SLA’s decision-making process to avoid any perceived conflict of interest. The Foreign Affairs Minister reaffirmed that he acted with the utmost care and exercised due diligence throughout the leasing negotiation period. Both cited the Ministerial Code of Conduct as guidance for decision-making in their capacity as public officials as they are expected to uphold the highest standards.


Why does the general public overarchingly scrutinise the facts and evidence presented in the investigation report?

The reasonable person has the view that intention compels action. Some have sentiments that resonate with constant noises that drive biases. It is anyone’s liberty to form their perception.


That is why so many organisational Codes of Conduct invoke employees to deliberate these proverbial questions so as not to service any conduct of impropriety and also to avoid the appearance of it:

“Does my decision align with the company’s core values and Code of Conduct?”
“Am I confident to defend my action when it is reported negatively in the news?”
“Will my course of action hamper the rights of others?”

Being in overlapping economies, whether we are someone who holds office, a consumer or a capitalist, our personal and professional ethics define us. Continue to look away from a malfeasance or to think that we can distract the authorities from our malpractice, and we further erode any ambitions to developing a circular compliance culture.


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