Code of Conduct (Singapore)
CODE OF CONDUCT
[Company Name]
UEN: [UEN]
[Company Address]
Effective Date: [Effective Date]
1. INTRODUCTION AND PURPOSE
1.1 This Code of Conduct (“Code”) sets out the standards of professional behaviour, ethical conduct, and workplace obligations expected of [Covered Persons] of [Company Name] (“the Company”).
1.2 This Code is issued in accordance with the Employment Act 1968 (Cap. 91A), the Workplace Safety and Health Act 2006 (Cap. 354A), and the Tripartite Advisory on Managing Workplace Harassment issued by the Ministry of Manpower (MOM), the National Trades Union Congress (NTUC), and the Singapore National Employers Federation (SNEF).
1.3 All persons covered by this Code are required to read, understand, and comply with its provisions as a condition of their engagement with the Company.
2. PROFESSIONAL CONDUCT AND INTEGRITY
2.1 All employees must conduct themselves with integrity, honesty, and professionalism in all business dealings, both internal and external.
2.2 Employees must not engage in any conduct that brings the Company into disrepute, including but not limited to dishonesty, fraud, misrepresentation, or misuse of Company assets or information.
2.3 Employees are required to comply with all applicable Singapore laws and regulations, including the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 and the Prevention of Corruption Act 1960.
2.4 Any conflict of interest — actual, potential, or perceived — must be disclosed promptly to the employee’s direct manager and to [HR Contact].
3. WORKPLACE RESPECT AND HARASSMENT-FREE ENVIRONMENT
3.1 The Company is committed to maintaining a workplace that is safe, respectful, and free from harassment, bullying, and discrimination in accordance with the Tripartite Guidelines on Fair Employment Practices and the Fair Consideration Framework.
3.2 Harassment includes any unwanted conduct — verbal, non-verbal, physical, or digital — that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment. This includes sexual harassment as defined under the Protection from Harassment Act 2014 (POHA).
3.3 Discrimination on the basis of race, language, religion, sex, age, disability, family status, or any other protected characteristic under the Workplace Fairness Legislation is strictly prohibited.
3.4 Employees who experience or witness harassment or bullying are encouraged to report the matter to [HR Contact] without fear of retaliation.
4. CONFIDENTIALITY AND PERSONAL DATA PROTECTION
4.1 Employees must not disclose confidential business information, trade secrets, or proprietary data to unauthorised persons during or after their employment.
4.2 All handling of personal data — whether of customers, employees, or business partners — must comply with the Personal Data Protection Act 2012 (PDPA) and the Company’s data protection policies.
4.3 Employees must use Company IT systems, email, and communications tools responsibly and in accordance with the Company’s acceptable use policies.
5. WORKPLACE SAFETY AND HEALTH
5.1 Every employee has a duty under the Workplace Safety and Health Act 2006 to take reasonable care of their own safety and the safety of others who may be affected by their acts or omissions at work.
5.2 Employees must comply with all safety rules, procedures, and instructions issued by the Company and must promptly report any unsafe conditions, near-misses, or accidents to their supervisor.
5.3 Employees must not report to work or operate machinery while under the influence of alcohol, drugs, or any other substance that impairs judgment.
6. DISCIPLINARY PROCEDURES
6.1 Breaches of this Code may result in disciplinary action up to and including termination of employment in accordance with the Employment Act 1968 and the employee’s contract of service.
6.2 Disciplinary proceedings will be conducted fairly and in accordance with the principles of natural justice, giving the employee a reasonable opportunity to respond to allegations before a decision is made.
6.3 Where a breach may also constitute a criminal offence, the Company reserves the right to report the matter to the relevant Singapore authorities, including the Singapore Police Force or the Corrupt Practices Investigation Bureau (CPIB).
EMPLOYEE ACKNOWLEDGEMENT
I confirm that I have read, understood, and agree to comply with this Code of Conduct issued by [Company Name]. I understand that breach of this Code may result in disciplinary action.
Company: [Company Name]
Authorised Signatory:
Authorised Signatory (Company)
________________
Signature
Employee
________________
Signature
What Is a Code of Conduct (Singapore)?
A Code of Conduct in Singapore sets out the standards and procedures the organisation expects its people to follow.
Singapore does not have a standalone statute mandating that all private companies adopt a Code of Conduct. However, several regulatory frameworks create strong incentives or requirements. The Singapore Exchange (SGX) Listing Rules require listed companies to adopt a code of conduct and ethics as part of their corporate governance obligations under the Code of Corporate Governance 2018 (revised by the Monetary Authority of Singapore (MAS)). The MAS Guidelines on Fair Dealing require financial institutions to adopt codes of conduct addressing fair treatment of customers. The Competition and Consumer Commission of Singapore (CCCS) encourages businesses to adopt compliance programmes — which typically include a Code of Conduct — to prevent anti-competitive behaviour under the Competition Act (Cap. 50B).
A Code of Conduct operates alongside the employment contract, the Employee Handbook, and any applicable collective agreements. Under Singapore employment law, the terms of the Code of Conduct may be incorporated into the employment relationship either expressly (by contractual reference) or impliedly (through consistent enforcement and employee acknowledgement). The Singapore Industrial Arbitration Court and the Employment Claims Tribunals (ECT) have considered the enforceability of workplace policies in unfair dismissal and employment claims, and employees dismissed for breaching a Code of Conduct may challenge the dismissal under Section 14 of the Employment Act if they can show the dismissal was without just cause.
The Workplace Safety and Health Act (Cap. 354A), administered by the Ministry of Manpower (MOM), imposes statutory duties on employers to maintain a safe workplace. A Code of Conduct typically addresses workplace safety expectations — such as reporting hazards, wearing protective equipment, and prohibiting substance abuse — that complement the employer's statutory obligations under the WSH Act and the WSH (General Provisions) Regulations.
Singapore's Tripartite Alliance for Fair and Progressive Employment Practices (TAFEP) — a joint initiative of MOM, the Singapore National Employers Federation (SNEF), and the National Trades Union Congress (NTUC) — publishes the Tripartite Guidelines on Fair Employment Practices. A well-drafted Code of Conduct incorporates these guidelines by prohibiting discrimination on grounds of age, race, gender, religion, marital status, family responsibilities, or disability, and by establishing grievance and reporting mechanisms for employees who experience workplace harassment or discrimination.
The Personal Data Protection Act 2012 (PDPA) adds a data protection dimension to the Code of Conduct. Employees who handle personal data as part of their duties must comply with the PDPA's obligations regarding consent, purpose limitation, and data security. The Personal Data Protection Commission (PDPC) has taken enforcement action against organisations whose employees mishandled personal data — and a Code of Conduct that addresses data protection responsibilities helps demonstrate organisational compliance.
When Do You Need a Code of Conduct (Singapore)?
A Code of Conduct is needed in Singapore whenever an organisation seeks to formalise its behavioural expectations and create a reference framework for disciplinary decisions, regulatory compliance, and workplace culture.
Newly incorporated companies registering with ACRA benefit from adopting a Code of Conduct from inception, establishing clear workplace standards before the organisation scales. EnterpriseSG's Start-Up SG programme and various government grants require recipient companies to demonstrate sound corporate governance practices — including workplace policies — as a condition of funding.
SGX-listed companies must adopt a Code of Conduct and ethics policy as required by the Code of Corporate Governance 2018 issued by MAS. Principle 1 of the Code states that the Board should establish and maintain a framework of prudent and effective controls, and Practice Guidance 1 recommends a formal code of conduct and ethics. Companies preparing for an Initial Public Offering (IPO) on the SGX Mainboard or Catalist board should develop their Code of Conduct during the pre-listing preparation phase.
Financial institutions regulated by MAS — including banks, insurance companies, capital markets intermediaries, and payment service providers licensed under the Payment Services Act 2019 (Cap. 2A) — must adopt codes of conduct addressing fair dealing, conflicts of interest, and market conduct. MAS Notice SFA 04-N12 and various technology risk management guidelines require financial institutions to implement conduct policies covering information security, insider trading, and anti-money laundering.
Organisations expanding their workforce beyond 25 employees should formalise behavioural standards through a Code of Conduct, as the Ministry of Manpower (MOM) and the Employment Claims Tribunals consider documented workplace policies when adjudicating employment disputes. An employer who dismisses an employee for misconduct without reference to a documented Code of Conduct may face difficulty establishing just cause under Section 14 of the Employment Act 1968 (Cap. 91).
Companies handling personal data of customers, employees, or third parties need a Code of Conduct that addresses data protection responsibilities under the PDPA 2012. The PDPC has imposed financial penalties on organisations whose employees accessed, disclosed, or misused personal data in the absence of clear internal policies — making a documented Code of Conduct a critical compliance tool.
Multinational corporations operating in Singapore frequently adopt a local Code of Conduct adapted from their global policy to address Singapore-specific legislation, including the Prevention of Corruption Act (Cap. 241), the Penal Code provisions on criminal breach of trust (Sections 405-409), and the TAFEP Tripartite Guidelines on Fair Employment Practices.
What to Include in Your Code of Conduct (Singapore)
A properly drafted Code of Conduct for a Singapore organisation should contain the following essential elements, aligned with applicable legislation and regulatory guidance.
Scope and Application: A statement identifying who is bound by the Code — directors, officers, full-time and part-time employees, contract staff, interns, and third-party contractors. The Code should specify that all persons within its scope must acknowledge receipt and understanding, typically through a signed acknowledgement form retained by the Human Resources department.
Professional Conduct Standards: Expectations regarding honesty, integrity, diligence, and compliance with applicable laws. The Code should reference the Prevention of Corruption Act (Cap. 241) and state that employees must not solicit, accept, or offer bribes, gratifications, or kickbacks. The Corrupt Practices Investigation Bureau (CPIB) investigates corruption offences in Singapore, and penalties under the Act include imprisonment of up to five years and fines of up to S$100,000.
Workplace Respect and Anti-Harassment: A prohibition on workplace harassment, bullying, discrimination, and inappropriate conduct. The Code should reference the Protection from Harassment Act (Cap. 256A), which provides civil remedies (including protection orders) for victims of harassment, and the TAFEP Tripartite Guidelines on Fair Employment Practices, which prohibit discrimination on grounds of age, race, gender, religion, nationality, marital status, family responsibilities, or disability. The Code should establish a reporting mechanism for harassment complaints and specify the investigation procedure.
Confidentiality and Data Protection: Obligations regarding the handling of confidential business information and personal data. The Code should reference the PDPA 2012 and state that employees must not access, copy, disclose, or use personal data except for authorised business purposes. The PDPC can impose financial penalties of up to S$1 million (or 10% of annual turnover for organisations exceeding S$10 million turnover) under Section 48J of the PDPA for data protection breaches.
Conflicts of Interest: A requirement to disclose any actual or potential conflicts of interest — including outside employment, directorships in other companies (searchable on ACRA BizFile), financial interests in suppliers or competitors, and personal relationships with colleagues that may affect business decisions. The Code should specify the disclosure procedure (typically to the employee's supervisor and the compliance function) and the consequences of non-disclosure.
Workplace Safety and Health: Obligations under the Workplace Safety and Health Act (Cap. 354A), including the duty to report workplace hazards, cooperate with safety procedures, wear prescribed personal protective equipment, and refrain from placing others at risk. The MOM and the WSH Council publish Codes of Practice that employers should cross-reference in the Code of Conduct.
Use of Company Property and IT Resources: Rules governing the use of company equipment, email systems, internet access, and software. The Code should address personal use of company devices, social media policies, and the prohibition of installing unauthorised software. The Computer Misuse Act (Cap. 50A) criminalises unauthorised access to computer material, and employees should be warned that misuse of IT systems may constitute a criminal offence.
Disciplinary Framework: The consequences of breaching the Code, including verbal warnings, written warnings, suspension, demotion, and dismissal. The framework should comply with the Employment Act 1968 (Cap. 91), particularly Section 14 (dismissal for misconduct) and the requirement for due inquiry before dismissal. The Code should state that serious breaches — such as corruption, fraud, theft, or data breaches — may result in immediate dismissal and referral to the relevant authorities (CPIB, Singapore Police Force, or PDPC).
Acknowledgement and Review: A requirement for all persons within the Code's scope to sign an acknowledgement form confirming receipt and understanding. The Code should specify the review cycle (annual review is standard) and the procedure for notifying employees of amendments. On forms-legal.com, the Code of Conduct template generates a customised policy document with conditional sections that adapt based on the organisation's industry, size, and regulatory requirements.
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Reference this free template in an article, syllabus, or research note:
Forms Legal. (2026). Code of Conduct (Singapore) (Singapore) [Legal document template]. Forms Legal. https://forms-legal.com/singapore/business/policies/code-of-conduct-singapore
"Code of Conduct (Singapore) (Singapore)." Forms Legal, 2026, https://forms-legal.com/singapore/business/policies/code-of-conduct-singapore.
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title = {Code of Conduct (Singapore) (Singapore)},
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howpublished = {\url{https://forms-legal.com/singapore/business/policies/code-of-conduct-singapore}},
note = {Free legal document template. Based on Companies Act 1967 (Cap. 50)}
}Also available for these jurisdictions:
Frequently Asked Questions
Singapore law does not impose a blanket statutory requirement for all private companies to adopt a Code of Conduct. However, several regulatory frameworks create sector-specific mandates or strong practical incentives. For SGX-listed companies, the Code of Corporate Governance 2018 (issued by MAS under a "comply or explain" framework) requires the Board to establish and maintain standards of conduct and ethics. Practice Guidance 1 recommends a formal code of conduct that addresses conflicts of interest, confidentiality, fair dealing, compliance with laws, and reporting of illegal or unethical behaviour. Listed companies that do not adopt a Code of Conduct must explain their non-compliance in their annual report. For financial institutions regulated by MAS — including banks licensed under the Banking Act (Cap. 19), insurers under the Insurance Act (Cap. 142), and capital markets intermediaries under the Securities and Futures Act 2001 (Cap. 289) — various MAS Notices and Guidelines require codes of conduct addressing fair dealing, market conduct, information security, and anti-money laundering. For private companies not subject to SGX or MAS requirements, adopting a Code of Conduct is a matter of best practice rather than legal obligation. However, the Employment Act 1968 (Cap. 91) requires employers to have just cause for dismissing employees (Section 14), and documented workplace policies — including a Code of Conduct — provide the evidentiary foundation for disciplinary action.
Yes, an employer may dismiss an employee for violating a Code of Conduct, provided the employer follows the procedural requirements of Singapore employment law and can demonstrate just cause for the dismissal. Under Section 14 of the Employment Act 1968 (Cap. 91), an employer may dismiss an employee without notice for misconduct, but must conduct a due inquiry before doing so. The due inquiry is an internal investigation giving the employee an opportunity to be heard and to respond to the allegations. Failure to conduct a due inquiry may render the dismissal procedurally unfair, and the employee may file a wrongful dismissal claim with the Employment Claims Tribunals (ECT) under Section 14(2) of the Employment Act. The severity of the Code of Conduct violation determines the appropriate disciplinary action. Minor violations (such as dress code breaches or occasional tardiness) typically warrant progressive discipline — verbal warning, written warning, and final written warning — before termination. Serious violations (such as theft, fraud, corruption, sexual harassment, or deliberate data breaches) may justify immediate dismissal without prior warnings. The Tripartite Alliance for Fair and Progressive Employment Practices (TAFEP) and MOM have published guidelines emphasising that dismissal must be proportionate to the misconduct. An employer who dismisses an employee for a trivial Code of Conduct violation without progressive discipline may face a wrongful dismissal claim.
A Singapore Code of Conduct should contain a dedicated anti-corruption section referencing the Prevention of Corruption Act (Cap. 241), which is the primary anti-corruption statute in Singapore. The Corrupt Practices Investigation Bureau (CPIB) — an independent agency reporting directly to the Prime Minister — investigates corruption offences, and Singapore consistently ranks among the least corrupt countries in the world according to Transparency International's Corruption Perceptions Index. The anti-corruption section of the Code should prohibit employees from: (1) corruptly soliciting, receiving, or agreeing to receive any gratification as an inducement or reward for doing or forbearing to do any act in relation to the employer's affairs (Section 6 of the Prevention of Corruption Act); (2) offering, giving, or agreeing to give any gratification to any agent (including government officials) as an inducement or reward (Section 5); and (3) using their position to obtain a personal advantage or to benefit a family member or associate. The Code should define "gratification" broadly, consistent with Section 2 of the Act, which includes money, gifts, discounts, commissions, employment, loans, services, entertainment, and any other form of benefit. Employees should be required to report any attempted bribery or corruption to the compliance function immediately and to cooperate with any CPIB investigation. Penalties under the Prevention of Corruption Act include imprisonment of up to five years and fines of up to S$100,000 per charge.
The Tripartite Alliance for Fair and Progressive Employment Practices (TAFEP) is a joint initiative of the Ministry of Manpower (MOM), the Singapore National Employers Federation (SNEF), and the National Trades Union Congress (NTUC). TAFEP publishes the Tripartite Guidelines on Fair Employment Practices, which set the benchmark for non-discriminatory workplace policies in Singapore and directly influence the content of Codes of Conduct. The Tripartite Guidelines prohibit discrimination in recruitment, promotion, training, and termination on grounds including age, race, gender, religion, nationality, marital status, family responsibilities, and disability. While the Guidelines are not statute law, MOM has stated that employers who breach the Guidelines may face administrative actions — including curtailment of work pass privileges — and the Employment Claims Tribunals consider adherence to TAFEP principles when assessing wrongful dismissal claims. A Code of Conduct that incorporates TAFEP principles should: (1) state the organisation's commitment to merit-based employment decisions; (2) prohibit discriminatory language, conduct, and decision-making; (3) establish a grievance mechanism for employees who experience or witness discrimination; (4) require managers and supervisors to complete fair employment training; and (5) designate a responsible officer (typically the HR Director or a TAFEP liaison officer) to handle discrimination complaints.
Best practice in Singapore corporate governance recommends reviewing the Code of Conduct at least annually, with additional reviews triggered by significant changes in legislation, regulatory guidance, business operations, or workforce composition. The Code of Corporate Governance 2018 (for SGX-listed companies) and MAS regulatory guidelines (for financial institutions) expect boards and management to maintain current and effective governance frameworks, which includes periodic review of the Code of Conduct. The Board or its designated committee (typically the Audit Committee or Nominating Committee) should approve any material amendments. Specific triggers for an unscheduled review include: (1) amendments to the Employment Act 1968 (Cap. 91) or the enactment of new workplace legislation (such as the Workplace Fairness Act expected in the near future); (2) new PDPC enforcement decisions or amendments to the PDPA 2012 that affect data protection obligations; (3) changes to TAFEP Tripartite Guidelines or the issuance of new Tripartite Advisories by MOM; (4) expansion into new business activities or jurisdictions that introduce additional regulatory requirements; and (5) a serious internal incident (such as a fraud, data breach, or harassment complaint) that reveals gaps in the existing Code. When the Code is updated, all employees within its scope should receive written notification of the changes and sign an updated acknowledgement form.
A Code of Conduct alone does not eliminate vicarious liability, but a well-implemented Code supported by training, monitoring, and enforcement can significantly reduce the organisation's legal exposure. Under Singapore law, an employer is vicariously liable for the wrongful acts of employees committed in the course of employment. The Singapore Court of Appeal applied the "close connection" test in Skandinaviska Enskilda Banken AB (Publ), Singapore Branch v Asia Pacific Breweries (Singapore) Pte Ltd [2011] 3 SLR 540, holding that an employer is liable where there is sufficient connection between the employee's wrongful act and their employment. For statutory offences, a Code of Conduct can provide a due diligence defence. Under the PDPA 2012, the PDPC considers whether the organisation had implemented reasonable policies, training, and oversight when determining penalties for data protection breaches by employees. Under the Prevention of Corruption Act (Cap. 241), Section 8 creates a presumption of corruption in certain circumstances, but an employer who can demonstrate strong anti-corruption policies, training programmes, and reporting mechanisms may argue that the employee acted outside the scope of employment. The Workplace Safety and Health Act (Cap. 354A) imposes statutory duties on employers that cannot be delegated to employees through a Code of Conduct.
This template is provided for informational purposes only and does not constitute legal advice. Laws vary by jurisdiction and change over time. Consult a qualified attorney for advice specific to your situation.Full disclaimer
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