As an international real estate operating company with a truly global presence, and as one of Singapore’s largest companies by market capitalization, conducting its business with integrity, honesty and accountability, according to the highest ethical standards and in compliance with all applicable laws and regulations, is a top priority for City Developments Limited (CDL).
This case study is based on the 2016 Integrated Sustainability Report by CDL published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
As one of Singapore’s largest commercial landlords, with a geographically diversified portfolio that includes hotels, shopping malls, residences, serviced apartments, offices, integrated developments – more than 18 million square feet of floor area globally –, City Developments Limited (CDL) tries to operate ethically and responsibly, adopting a zero tolerance approach to bribery and corruption. In order to operate with honesty, integrity and accountability CDL took action to:
- implement a Code of Business Conduct and Ethics
- apply an Anti-Corruption, Fraud and Competition Policy and Guidelines
- implement a Whistle-Blowing Policy
- apply a Personal Data Policy
- use ethical marketing practices
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With this case study you will see:
- Which are the most important impacts (material issues) CDL has identified;
- How CDL proceeded with stakeholder engagement, and
- What actions were taken by CDL to operate with honesty, integrity and accountability
What are the material issues the company has identified?
In its 2016 Integrated Sustainability Report CDL identified a range of material issues, such as legal compliance, employee health and safety, product quality and responsibility, customer/public health and safety, contractor health and safety. Among these, operating with honesty, integrity and accountability stands out as a key material issue for CDL.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups CDL engages with:
|Stakeholder Group||Method of engagement|
|· Regular dialogue sessions with Senior Management
· CDL 360 – Company intranet
· Daily news bulletin
· Staff Connect an inter-department committee that organises company-wide activities to foster work-life balance and reinforce team spirit
· Frequent employee activities
· Employee volunteering platform – City Sunshine Club (CSC)
· Biennial Employee Engagement Survey
· Employee Assistance Programme (counselling service) and grievance platforms
|Customers||· Homebuyers – Temporary Occupation Permit (TOP)1 Welcome Parties, Green Living Kits
· Post-TOP customer satisfaction surveys
· Tenants – Project: Eco-Office kits, recycling programme, 1°C Up campaign, Green Lease Partnership Programme, green fitting out kits
· Annual tenant satisfaction surveys
|Builders and suppliers
|· EHS Policy
· Quarterly EHS audits and seminars
· Annual EHS Awards
· Declaration of EHS commitment through letter and pledge-signing
· EHS risk assessments at concept, design and construction stages
· CDL EHS Cup soccer league
· Construction vision casting
· Bi-annual vendor evaluation
|Investors, analysts and
|· Annual General Meetings
· Biannual financial results briefings
· Quarterly financial results announcements
· Regular analyst and investor meetings
· Media releases and interviews
· Annual reports
· Sustainability reports
· Company website
· Project launches (as required)
· Timely and active response to ESG rating agencies and analysts
|Government agencies and regulators
|· Senior Management representation on boards of various industry bodies and sustainability-related public discussions
· Regulatory readiness to the Singapore Government’s commitment to manage carbon emissions
· Longstanding partner of various national programmes
|Community||· Public communications plan with residents within a 100m radius of CDL’s new developments
· Builders’ contact details publicly displayed at construction sites to facilitate feedback from the neighbourhood
· Sustainability reports
· Participation in external conferences/forums
· Corporate advertisements
· Consultation and sharing with academics, NGOs, and business associations
· “Beauty of Nature” calendar series
How stakeholder engagement was made to identify material issues
To prioritize and validate key material issues CDL conducted, through an independent consultant, an online survey among internal and external stakeholders, who were also able to propose additional issues.
In its 2016 Integrated Sustainability Report CDL reports that it took the following actions for operating with honesty, integrity and accountability:
- Implementing a Code of Business Conduct and Ethics
- CDL’s Code of Business Conduct and Ethics, available to employees on the company’s intranet, offers guidance on the company’s attitude towards corruption and bribery, compliance with laws, regulations and CDL’s policies and procedures, the protection and proper use of confidential information, among others.
- Applying an Anti-Corruption, Fraud and Competition Policy and Guidelines
- CDL’s anti-corruption, fraud and competition policies and guidelines are available on the company’s website and intranet, providing information and guidance on:
- CDL’s ‘zero-tolerance’ stance against corruption and bribery, and on how employees may identify, deal with, resolve, keep away from and prevent instances of corruption, bribery and extortion
- actions that may constitute fraudulent conduct
- anti-competitive practices, conduct and acts, which represent an abuse of a company’s dominant market position
- Implementing a Whistle-Blowing Policy
- CDL employees (and other persons) are able to raise concerns on possible misconduct relating to financial reporting, auditing, internal controls or other issues, through CDL’s whistle-blowing procedure. CDL’s Whistle-Blowing Policy and whistle-blowing communication channels (email and postal address, plus telephone contact numbers) are available on its website and intranet.
- Applying a Personal Data Policy
- [tweetthis]CDL has introduced a Personal Data Policy[/tweetthis] to inform stakeholders on how the company handles personal data, complying with the Singapore Personal Data Protection Act (No. 26 of 2012). In addition, customers may contact CDL’s Data Protection Officer by mail, email or phone, for questions, complaints and feedback regarding their personal data or the company’s Personal Data Policy, among others.
- Using ethical marketing practices
- CDL’s marketing collaterals comply, among others, with the Singapore Code of Advertising Practice, administered by the Advertising Standards Authority of Singapore.
Which GRI indicators/Standards have been addressed?
The GRI indicators/Standards addressed in this case are:
1) G4-49: Report the process for communicating critical concerns to the highest governance body – the updated GRI Standard is: Disclosure 102-33 Communicating critical concerns
2) G4-50: Report the nature and total number of critical concerns that were communicated to the highest governance body and the mechanism(s) used to address and resolve them – the updated GRI Standard is: Disclosure 102-34 Nature and total number of critical concerns
3) G4-56: Describe the organization’s values, principles, standards and norms of behavior such as codes of conduct and codes of ethics – the updated GRI Standard is: Disclosure 102-16 Values, principles, standards, and norms of behavior
4) G4-57: Report the internal and external mechanisms for seeking advice on ethical and lawful behavior, and matters related to organizational integrity, such as helplines or advice lines – the updated GRI Standard is: Disclosure 102-17 Mechanisms for advice and concerns about ethics
5) G4-58: Report the internal and external mechanisms for reporting concerns about unethical or unlawful behavior, and matters related to organizational integrity, such as escalation through line management, whistleblowing mechanisms or hotlines – the updated GRI Standard is: Disclosure 102-17 Mechanisms for advice and concerns about ethics
6) G4-SO3: Total number and percentage of operations assessed for risks related to corruption and the significant risks identified – the updated GRI Standard is: Disclosure 205-1 Operations assessed for risks related to corruption
1) This case study is based on published information by CDL, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
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