Ngai Heng Pte Ltd (hereafter named, “Ngai Heng”) is committed to the highest standards of integrity and ethics when conducting business.

This Code of Conduct (“CODE”) sets out the standards of conduct whereby Ngai Heng expects all its current and potential suppliers providing goods and services to Ngai Heng.

A supplier refers to any individual or business that supplies goods or services to Ngai Heng’s business, and includes all persons employed by the supplier, as well as sub-contractors and service providers engaged by the supplier (collectively, “Third Parties”).

In addition, it is the responsibility of the supplier to ensure that all Third Parties understand and comply with this Code. The supplier’s compliance with this Code will be assessed by Ngai Heng and considered in the selection criteria for the purchase of any goods and services. Failure to adhere to the Code may be grounds for Ngai Heng to terminate the supplier relationship, depending on the circumstances and the seriousness of the violation.

For the avoidance of doubt, this Code does not create any binding obligations on Ngai Heng. We reserve the right to modify this Code in line with our company compliance program and we expect our suppliers to accept all such changes. In addition, this Code does not represent a complete set of the suppliers’ obligations and requirements in relation to Ngai Heng. All suppliers are requested to review their specific agreements (for example, purchase orders, terms and conditions, etc.) with Ngai Heng for any additional obligation and requirement.

1          Compliance with Laws and Regulations

Suppliers undertake that they will comply with all laws and regulations that apply to them in the countries that their operations are based, and where they provide goods and services to Ngai Heng. These include, but are not limited to labour and employment laws, financial and business records are correctly maintained and that fair competition is practised.

2          Ethical Standards

Suppliers commit that all their business dealings are handled with integrity, transparency and honesty. No form of fraud, corruption, bribery, extortion or other behaviour involving improper benefits will be tolerated. Any situation that has actual, perceived or potential conflicts of interest must be disclosed to the Ngai Heng.

Ngai Heng does not tolerate any form of and no supplier shall engage in any form of corruption or bribery, including any payment or other form of benefits conferred on any government official for the purpose of improperly influencing decision making.

Suppliers will not offer to any employee of Ngai Heng any gifts, inducement or reward that may influence business decision or create the appearance of influencing any business decision other than that specifically documented in a signed contract or terms and conditions of the business arrangement.

Suppliers and those acting on their behalf will remain free from conflicts of interest that may adversely influence their business relationship with Ngai Heng. Suppliers commit to disclose any potential conflicts of interest promptly to the Ngai Heng.

3          Confidentiality

Suppliers must respect Ngai Heng’s intellectual property, trade secrets and all other confidential, proprietary or sensitive information, and may not use or disclose any such information except in accordance with the terms of their contract with Ngai Heng, and for the benefit of Ngai Heng.

4          Health and Safety

Suppliers are required to provide a safe and healthy working environment for all its employees and are encouraged to have in place policies that are designed to promote the general health of employees and prevent work-related injuries and illness. The workplace should, among other things, be free of pollution, toxic material and waste and have adequate safety and accident preventive measures.

Suppliers are also required to ensure that its workers and employees are physically fit for work and not under the influence of alcohol, prohibited drugs, or other incapacitating substances when providing goods or services to Ngai Heng.

5          Environment

Suppliers shall comply strictly with local environmental laws and practices, such as those pertaining to waste disposal, air emissions and pollution. Suppliers must endeavour to minimize the impact of their operations on the environment. For example, suppliers may undertake recycling efforts and carry out research and development to assess how the impact of their operations on the environment may be minimised.  Suppliers must also avoid the use of hazardous materials or engage in practices that would or might cause pollution.

6          Human Rights, Discrimination and Labour Standards

Suppliers shall apply fair standards in its treatment of all its employees, and this entails not subjecting any employee to discrimination based on race, national origin, ethnicity, religion, gender, age, marital status, sexual orientation, disability, or any other reason. Suppliers shall respect the personal dignity, privacy and rights of each individual. No supplier shall employ or make anyone work against his or her will. Suppliers are also required to comply with principles of non-discrimination with respect to their own selection of suppliers and treatment of their own employees.

Suppliers will comply with all national laws on wages and working hours.

Suppliers shall ensure that no child or forced labour forms part of their respective businesses and operations.

7          Personal Data Protection Act

Suppliers shall comply with the Personal Data Protection Act in Singapore and/or applicable data protection laws in the relevant jurisdiction when collecting, using, disclosing, transferring, storing and/or processing any personal data information that are controlled or owned by Ngai Heng and to ensure they have equivalent data protection policies and controls in place. In the event of any data breach, Suppliers shall inform Ngai Heng within 24 hours of discovering the breach.

8          Business Continuity Planning

Suppliers shall have implemented robust plans to mitigate the effects of any business disruptions (e.g., natural disasters, terrorism, strikes, computer viruses, infectious diseases, etc.), in particular plans to ensure that their employees’ well-being and the environment are protected from the negative effects relating to or arising from such business disruptions.

9          Monitoring

Suppliers are expected to actively monitor their day-to-day management processes with respect to this Code, as may be amended from time to time.


Updated as of 01 March 2023