COOKIE NOTICE

This Cookie Notice applies to SCV Research and Development Pte. Ltd. (trading as “TASConnect”), which you may have a contract with, or which may provide services to you. This Cookie Notice explains how we use cookies and similar technologies to recognise you when you visit our Website and/or use our applications. It explains what these are and why we use them, as well as your rights to control our use of them.

Our Website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customise your browsing experience and for the collection of analytics and metrics about our visitors both on this website and other media.

What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Where required by applicable law, we will obtain your consent before we place any cookies on your device that are not strictly necessary for the functioning of our Website.

Cookies set by the website owner (in this case, TASConnect) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?
We use first party and third party cookies for several reasons. Our first party cookies are required for technical reasons in order for our Website to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other first and third party cookies also enable us to track and target the interests of our users to enhance the experience on our Website. Third parties may also serve cookies through our Website for advertising, analytics and other purposes.

The types of first and third party cookies served through our Website and the purposes they perform are described below. Please note that the specific cookies served may vary depending on the specific Website you visit. You can find details of the particular cookies that are served on each Website, and/or of any parties serving third party cookies, as well as adjust your preferences, by clicking on the Cookie Settings on the applicable Website. Alternatively, visitors can also use their browser settings to control how cookies are set on their devices. However, blocking some types of cookies may impact your experience of the Website and may impair the services we are able to offer.

 

We use cookies on this site in four main ways:

“Strictly necessary” cookies, which are first party cookies that must be set to allow us to deliver the Website to you and to provide specific services that you request from us. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

“Performance” cookies, which are first party cookies that help us to collect information about how visitors use our Website and helps us with site analysis and improvements. Performance cookies will remain on your computer after you close your browser. If you opt out of, or do not allow, these cookies (as applicable), we will not know when you have visited our Website and will not be able to monitor its performance.

“Functionality” cookies, which allow our Website to remember our choices or preferences, such as information on online forms or previous orders (if applicable). These cookies enable you to move around our Website and use its features such as accessing secure areas. These cookies allow us to offer you a personalised experience while using the Website. They are not used to track your browsing activity on other websites. They may beset by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

“Targeting” cookies, which are third party cookies set through our Website by our advertising partners. They are used by those companies to build a profile of your interests and show you relevant adverts on other websites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will still experience advertising but it will be less targeted to you.

Do you serve targeted advertising?
Third parties may serve cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you.

How can I control cookies?

You have the right to decide whether to accept or reject certain cookies. You can use the Cookie Settings or set or amend your web browser controls to accept or refuse certain cookies.

You can amend your cookies choices at any time, including by withdrawing your consent to certain cookies, through our Cookie Settings or by changing your web browser controls. If you choose to reject cookies, you may still use our Website though your access to some functionality and areas of our Website may be restricted. You may need to refresh your page for your settings to take effect.

Browser controls
Most browsers will allow you to see what cookies you have and delete them on an individual basis or block cookies from particular or all sites. Be aware that any preference set will be lost if you delete all cookies, including your preference to opt-out from cookies as this itself requires an opt-out cookie to have been set.

If you are visiting this site using a mobile device such as a smartphone or tablet, please refer to the manufacturer’s instructions on how to manage cookies.

How often will you update this Cookie Notice?
We may update this Cookie Notice from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Notice regularly to stay informed about our use of cookies and related technologies.

Where can I get further information?
If you have any questions about our use of cookies or other technologies, please contact our team at privacy@tasconnect.com

Privacy Policy

Your personal information is important to us and it is our policy to respect and protect your personal information.  

This Privacy Policy outlines how we collect, use, manage and share personal information, including special or sensitive personal data, that we collect through our internet-based platform, accessed via our website at www.tasconnect.com (the “Platform”), as well as personal information collected from time to time from other lawful sources.  It also tells you how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy. 

1.What personal information do we collect about you?

Personal information is any information that can be used to identify you or that we can link to you and which we have in our possession or control.  

The types of personal information that we collect about you, directly or indirectly,  typically include: your name, contact details, your employer or organisation that you represent and certain details related to your employment, e.g. your job designation and work related contact details. 

We collect or receive personal information in a few different ways:

Information you provide to us: We collect personal information from your interactions with us via the Platform (for example, when you register as a user, when you communicate with us or other parties on our Platform or where you have consented to our Customer providing such information to us) or personal information that you otherwise give to us (for example, when you email us or contact us via other channels).  Often, you choose what personal information to provide to us, but sometimes we require certain information in order for you to use, and for us to provide you and/or the organisation you represent with, the Platform and our services. 

Information we obtain from other sources: From time to time, we may also collect or receive information about you from third party sources such as publicly available databases, credit reference agencies and other lawful sources. We may collect this information to assist us in providing, evaluating and improving our Platform, products and services, or to help us comply with legal and compliance requirements including but not limited to compliance with anti-money laundering and sanctions regulations. We will only collect information from third party sources where these third parties have represented that you gave your consent to disclose your personal information with us or that they are otherwise legally permitted or required to disclose your personal information to us.  

Information collected automatically through your use of our Platform: We will also collect information on an automated basis when you use our Platform or our services. We log usage data when you visit or otherwise use our Platform. Specifically, the information we collect automatically may include information like internet protocol (“IP”) address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Platform, including the pages accessed and links clicked. 

We may also collect precise geolocation data pertaining to your device, if you have consented to providing this to us through your device settings. We may use this information to provide, promote, and improve our services (for example, understanding the country you reside in) and for related reasons, such as sanctions, fraud prevention and security purposes. Please note that if you do not consent to providing your geolocation data, certain features of the Platform may not work. 

The information we collect automatically enables us to better understand the visitors who come to our Platform, where they come from, and what content on our Platform is of interest to them. This enables us to improve the quality and relevance of our Platform to our visitors. 

We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across the Platform, including when you use different devices. To learn more, including how to change your cookie settings, please see below.

The links listed below provide more information about what cookies are installed, how to allow, block or remove installation from your computer. Depending on which browser you use, the user may follow these links:

In addition to collecting and processing personal information, the following types of data about your use of the Platform and/or your use of our services, may also be collected for the following purposes: 

    • metadata (ancillary usage data, e.g. IP address) may be used for providing services and related internal or regulatory compliance uses, such as the provision of service performance statistics);
    • anonymised data and anonymised aggregated data (anonymised data aggregated with anonymised data from other service provider users) may be used for providing, maintaining and supporting the service provider services, compiling statistical reports, performance tracking, transaction categorisation and merchant identification services.

2.How do we use your personal information?

We rely on one or more of the following lawful grounds to collect, use, process and disclose your personal information:

    • Purposes of collection: We may use your personal information for the purposes described in this Policy or of which you have otherwise been notified of.
    • Consent: We may use your personal information for the purposes you have consented to.
    • Performance of a contract: We may need to collect and use your personal information to fulfil the contract between us and our Customer for the services requested and/or to perform our obligations under such contract.
    • Compliance with law or regulation: We may use your personal information as necessary to comply with applicable law/regulation.

We may collect, use, process and disclose your personal information for the following purposes (and subject to your further consent if required by applicable law):

    • providing you and/or the organisation you represent with products and services as subscribed to or requested by you, including products and services provided by our affiliates, joint venture partners, business alliance partners, Customers, and other relevant third party providers
    • processing applications for products and services and completing instructions or requests;
    • providing customer service, customer support and technical support, including in relation to product updates;
    • market research and surveys with the aim of improving our products and services;
    • marketing, business development and promotional purposes;
    • for our legitimate business interests, such as undertaking business research and analysis, managing our operation of the Platform and our business;
    • investigating any complaints or queries you may have;
    • to comply with and monitor compliance with applicable laws and regulations, including without limitation laws and regulations relating to anti-money laundering, anti-bribery and trade sanctions), voluntary codes, internal policies (including that of our affiliates’), contractual obligations (including between us and our affiliates) and other requirements;
    • preventing and responding to actual or potential fraud or illegal activities;
    • maintaining the security of the Platform, including to verify your identify, to investigate or prevent possible or actual fraud or other violations of any agreement between us and the employer or organisation you represent, our User Terms or this Privacy Policy and/or in connection with possible attempts to harm our users, visitors, or other third parties;
    • To seek professional advice, including in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending our legal rights;
    • where you have applied for a position with us, to review and process your job  application.

We may also record or monitor your use of our Platform and services for our business purposes which may include analysis of usage, measurement of site performance and generation of reports.

We may also collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law. 

3.How do we share your information with third parties?

Depending on the purpose of processing your personal information, personal information may be disclosed to:

    • our affiliates anywhere in the world, including any officer, employee, agent or director of any affiliate;
    • our joint venture partners, business alliance partners, third party providers of related services (including financing services) or other investors or potential investors (in connection with the actual or potential merger, sale, acquisition or investment), provided we inform the relevant third party it must use your personal information only for the purposes disclosed in this Privacy Policy;
    • our professional advisers and other service providers in order to provide administrative, financial, legal, accounting, information technology, authentication, research or other services;
    • anyone authorised by you or the employer or organisation you represent, as specified by you or the employer or organisation you represent or in any contract with you or the employer or organisation you represent;
    • any person to whom disclosure is required or permitted under applicable laws or regulations;
    • anyone we consider necessary to facilitate requests for services or applications for products in relation to the Workspace you access; and
    • anyone we consider necessary in order to provide services in connection with a product or service, including our Customer and their nominated Users.

The persons identified in this paragraph 3 may contact you directly to obtain additional information necessary for the purposes set out in this Privacy Policy. We may be kept in copy or may otherwise be kept informed of such communications on the Platform and may assist you in ensuring that the requisite additional information is provided.

4.Keeping your data secure

The security of your personal information is important to us. We use appropriate technical and organisational measures to protect the personal information that we collect and process about you, designed to provide a level of security appropriate to the risk of processing your personal information.  While we monitor our systems for possible vulnerabilities and attacks, we cannot guarantee 100% security of any information that you send us. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your personal information arising from such risks.

When using external service providers, we require that they adhere to security standards mandated by us. We may do this through contractual provisions, including any required by relevant privacy regulators, and oversight of the service provider.

Personal information may be transferred to, or stored at, locations outside of Singapore or the place of original data collection. In all cases, however, any transfer of your personal information to another location will be compliant with applicable data protection law. Regardless of where personal information is transferred, we will take steps to ensure that appropriate technical and organisational measures are put in place to protect your personal information.

5.Data Retention

We retain your personal information in line with our legal and regulatory obligations and for business and operational purposes. The period of retention will vary in accordance with the data type, the purpose for which are processing your personal information and our legal obligations. Subject to applicable law, we will cease to retain your personal information when we no longer require such personal information for the purposes we originally notified you of or for any business or legal needs.

6.Your rights

You may have a variety of data protection rights, depending on your geographical location and applicable law. These rights may include:

    • the right to request access to the  personal information we hold about you (please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information);
    • the right to request that we correct or update your personal information if it is inaccurate or incomplete; 
    • the right to request withdrawal of consent to process your personal information (please note that in certain circumstances it may be lawful for us to continue processing without your consent).

You can exercise your rights by contacting the Data Protection Officer using the contact details set out below.

7.Updates to this Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

8.Third party websites and services

The Platform may contain links to third-party websites or mobile apps, including social sharing features and other related tools. The Platform may also permit you to set settings to allow your data to be disclosed to third parties for the purpose of such third parties providing products and services to you (such as our joint venture partners, business alliance partners and other third party providers of related services (including finance services)). We will always endeavour to require our joint venture partners, business alliance partners and other third party providers of related services on the Platform to comply with applicable data protection laws, such as through contractual provisions. However, please be aware that we do not control these third parties, third party websites or apps or their collection or processing of your personal data. This Privacy Policy does not apply to any information you give to the owner of these third party websites or apps or that are otherwise collected by these third parties. We encourage you to read the privacy policy of any third party before you provide them with any information or request or accept services from such third parties.

9.Contacting us

You may contact us by writing to our Data Protection Officer at privacy@tasconnect.com.

 

©TASConnect

Bank Participant Terms

These terms and conditions (“Bank Participant Terms”) shall govern the use of the TASConnect Platform, TASConnect APIs and TASConnect API Materials by the bank entity that you represent (the “Bank Participant”) and shall form a binding contract between SCV Research and Development Pte. Ltd (a company incorporated and registered in Singapore with company number 202120852K with its registered office at 80 Robinson Road, #02-00, Singapore 068898) (“TASConnect”“we” or “us”) and the Bank Participant. These Bank Participant Terms shall apply in addition to any User Terms that are applicable to Bank Participant’s representatives and any other rules, guidelines, policies and other terms and conditions applicable to the Bank Participant’s access and use of the TASConnect Platform, in each case as published on the TASConnect Platform from time to time.

These Bank Participant Terms take effect on the earlier of (i) when you click an “I Accept” button presented with these Bank Participant Terms; (ii) when you acknowledge agreement in some other way (for example, but providing us with a signed acknowledgment as part of the process of obtaining access to certain Workspaces; or (iii) when you first use the TASConnect Platform, TASConnect APIs or any TASConnect API Materials. By clicking “I Accept” or acknowledging agreement in some other way or by accessing and using the TASConnect APIs or any TASConnect API Materials, you agree on behalf of the Bank Participant to be bound by these Bank Participant Terms. 

You represent and warrant that you are a duly authorised individual of the Bank Participant for the purposes of entering into these Bank Participant Terms and that you have all requisite right, power and authority to enter into these Bank Participant Terms on behalf of the Bank Participant and to legally bind the Bank Participant to these Bank Participant Terms.

You further represent and warrant (i) you and the Bank Participant comply (and shall ensure that the personnel, associated persons, subcontractors and agents of Bank Participant and Bank Participant’s Affiliates comply) in all respects with applicable Sanctions; (ii) you, the Bank Participant (and the personnel, associated persons, subcontractors and agents of Bank Participant and Bank Participant’s Affiliates) are not subject to Sanctions or located, organised or resident in a Sanctioned Country or on a Sanctions List; (iii) you are not accessing the TASConnect Platform, the TASConnect APIs or TASConnect API Materials from a Sanctioned Country; (iv) your use of the TASConnect Platform, the TASConnect APIs and TASConnect API Materials complies with all applicable laws and regulations at all times; and (v) the Bank Participant is properly licensed in its operating jurisdictions. In event you or the Bank Participant become aware of any breach or potential breach of any of the foregoing representations and/or warranties, you and the Bank Participant agree to immediately inform us of such breach.  You acknowledge that we reserve the right to suspend or terminate your access to the TASConnect Platform, the TASConnect APIs and TASConnect API Materials at any time if we believe that your access to the TASConnect Platform, the TASConnect APIs and TASConnect API Materials may cause us to be in breach of Sanctions, laws, regulations or our policies relating to our compliance obligations.

The definitions of capitalised terms used in these Bank Participant Terms are set out at the end of this webpage.

  1. Your relationship with us
    1. The TASConnect Platform is a data management solution which is provided by us to an organisation or other third party that we refer to in these Bank Participant Terms as “Customer” pursuant to an agreement between us and Customer to automate Customer’s designated workflow(s), wholly or partially, including but not limited to Customer’s management of its Invoices and to streamline data transfer between Customer and Customer’s Users (including Bank Participant) as specified or directed by Customer. Amongst others, we will enable Customer Data to be shared though the TASConnect Platform as directed by the Customer and will provide tools to Users for workflow information in accordance with Customer’s specifications.
    2. The Customer has invited Bank Participant to participate, and Bank Participant has accepted Customer’s invitation to participate, in the provision of financial accommodation and/or financial or payment services in relation to Customer’s Invoices. Depending on Customer’s configuration of its Workspace and workflow, Bank Participant may be required to register on the TASConnect Platform to access Customer’s Workspace and/or connect Bank Participant’s system(s) via TASConnect APIs in order to receive certain Customer Data and/or submit and transfer any relevant data through the TASConnect Platform and/or use certain aspects of the TASConnect Platform, TASConnect APIs and TASConnect Materials as part of Customer’s workflow.
    3. Bank Participant acknowledges and agrees that its use of the TASConnect Platform, TASConnect APIs and TASConnect API Materials is strictly and solely related to its receipt and transfer of data as agreed between Bank Participant and Customer (“Permitted Purpose”). Bank Participant further acknowledges and agrees that: (i) the TASConnect Platform is only a data management solution provided to the Customer by TASConnect, (ii) TASConnect and the TASConnect Platform do not permit or allow the purchase or sale of any financial instruments or services on the TASConnect Platform, and (iii) TASConnect is not a party to any financing or payment services transactions between Bank Participant and Customer or Customer’s Users,
  2. Where registration is required
    1. Further to Section 1.2, if Bank Participant and/or its representatives are required to register on the TASConnect Platform, Bank Participant acknowledges that Customer is responsible for configuring and controlling their Workspace and for provision of Bank Participant’s representative access to the Customer’s Workspace, and that Bank Participant’s representative access to that Customer’s Workspace may be subject to additional terms and conditions set by the relevant Customer.
    2. Bank Participant agrees, represents and warrants that it has and will:
      1. provide true, accurate, current and complete information about itself;
      2. maintain and promptly update any information it provides to ensure that it remains true, accurate, current and complete.
    3. Subject to applicable law, we may (but are not obliged to) verify any information provided by Bank Participant, whether that information is provided to us directly by Bank Participant or obtained by us through other sources.
    4. Without limiting anything set out in these Bank Participant Terms, Bank Participant represents and warrants that all the content and information that Bank Participant submits to the TASConnect Platform is genuine, accurate, lawful, valid, current and belongs to the Bank Participant or that Bank Participant has all rights, permissions or consents to submit it to the TASConnect Platform for the purposes it is intended to be used. We will not be responsible for any loss or damages Bank Participant suffers in connection with it being unable to use the TASConnect Platform or any product or service due to the content or information being incorrect, incomplete, or false.
    5. Bank Participant is solely responsible of all its activities in connection with its use of the TASConnect Platform and Bank Participant acknowledges and agrees that, although individual representatives of Bank Participant may be required to register as Users and agree to additional User terms and conditions, Bank Participant remains at all times responsible for the acts and omissions of its representatives and all activities that occur using the login credentials and accounts of Bank Participants or its representatives. Without limiting the foregoing, Bank Participant and its representatives are responsible for keeping confidential and secure all login credentials, passwords and accounts of Bank Participant and its representatives. We shall not be liable for any loss or liability suffered by Bank Participant, its representatives or any other person if such information is not kept confidential and secure by Bank Participant and its representatives (including any unauthorised access by any party logging into and accessing the TASConnect Platform using such information).
  3. Use of the TASConnect APIs and TASConnect API Materials
    1. Under these Bank Participant Terms, we may make available to Bank Participant the TASConnect APIs and TASConnect API Materials that permit Bank Participant’s systems to interface with the TASConnect Platform and which provide certain features and functionalities that enable Bank Participant to transfer certain data to and from the TASConnect Platform.
    2. We grant to Bank Participant a limited, revocable, non-exclusive, non-transferable, non-sublicensable, royalty-free licence to access, download, install copy and use the TASConnect APIs and TASConnect API Materials solely for the purposes of using the TASConnect Platform to obtain and provide necessary data relating to the Permitted Purpose (as defined below).
    3. The licences and rights granted in these Bank Participant Terms are conditional on and subject always to (i) the Bank Participant’s satisfactory completion of TASConnect’s registration and/or TASConnect’ compliance and due diligence procedures(if any); (ii) the Bank Participant’s continuing compliance with these Bank Participant Terms; (iii) the continued compliance by representative of the Bank Participant with applicable User Terms; (iv) the continued compliance by Bank Participant and its representatives with any other applicable policies, terms and conditions; and (v) the Bank Participant being in good standing as determined in our sole discretion, acting reasonably.
    4. The following licence restrictions apply:
      1. Bank Participant may only use and access the TASConnect APIs and TASConnect API Materials though the APIs documented and provided by us to Bank Participant.
      2. Bank Participant must not, and must not authorise any other party to do any of the following with the TASConnect APIs and TASConnect API Materials:
        1. reverse engineer, decompile, or disassemble them;
        2. modify or create derivative works based on them in whole or in part;
        3. distribute copies of them;
        4. remove any proprietary notices or labels on them;
        5. use any open source software in any manner that requires, pursuant to the licence applicable to such open source software, that the TASConnect APIs or TASConnect API Materials be disclosed, licensed, distributed or otherwise made available to anyone;
        6. resell, lease, rent, transfer, sublicense or otherwise deal with the TASConnect APIs or TASConnect API Materials in any manner not expressly permitted by these Bank Participant Terms;
        7. access or use the TASConnect APIs or TASConnect API Materials for fraudulent or unlawful activities or any activities that otherwise violate any rules, guidelines, policies and other terms and conditions applicable from time to time to the Bank Participant ’s access and use of the TASConnect Platform or in a way that is otherwise harmful to us;
        8. access or use the TASConnect APIs or TASConnect API Materials for any reason other than the Permitted Purposes, or in breach of, or contrary to these Bank Participant’s Terms.
  4. Use of the TASConnect Platform
    1. In addition to the licences granted in clause 3.2, and conditional on and subject always to clause 3.3, we grant to Bank Participant a limited, non-exclusive, non-transferable, revocable right to use the TASConnect Platform in accordance with these Bank Participant Terms and solely for the Permitted Purpose. Any rights not explicitly granted in these Bank Participant Terms are reserved by us.
    2. In addition and without limiting anything else in these Bank Participant Terms, Bank Participant must not, and must ensure that its representatives do not, and must not authorise, permit, enable, induce or encourage any person to do, or attempt to do, any of the following:
      1. impersonate or misrepresent itself as another entity or person;
      2. falsely hold itself out as a representative of any organisation;
      3. reveal or share any login credentials to any other person;
      4. post any speculative, false, fictitious or fraudulent information on the TASConnect Platform;
      5. do anything that is illegal or potentially illegal, or that violates or potentially violates the rights (including intellectual property rights) of any person while using or in connection with its use of the TASConnect Platform;
      6. post anything on the TASConnect Platform that may be threatening, harassing, defamatory, obscene, or otherwise objectionable;
      7. upload, post, transmit or otherwise make available on the TASConnect Platform any unsolicited or unauthorised advertising, promotional materials, spam, or any other form of solicitation;
      8. upload, post, transmit or otherwise make available on the TASConnect Platform, any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment;
      9. use any tool, robot, spider, scraper, or other automated means or any manual process for interfering with the any of the functionalities of the TASConnect Platform, extracting, interfering or monitoring any data on the TASConnect Platform and/or causing any disruptions and/or activities on the TASConnect Platform;
      10. reverse engineer, decompile, hack, disable, interfere with, disassemble, modify, copy, translate, or disrupt the features, functionality, integrity, or performance of the TASConnect Platform;
      11. otherwise copy or build a similar or competitive product or service or any ideas, features, functions or graphics of the TASConnect Platform;
      12. gain unauthorised access to the TASConnect Platform or related systems or networks or to defeat, avoid, bypass, remove, deactivate, or otherwise circumvent any software protection or monitoring mechanisms of the TASConnect Platform;
      13. send unsolicited messages, spam, advertisements, marketing or any other inappropriate messages to other Users via the TASConnect Platform;
      14. send phishing, spoofing or other deceptive messages via the TASConnect Platform;
      15. sublicense, resell, time-share or make any other similar inappropriate use of the TASConnect Platform;
      16. scrape or harvest any data from the TASConnect Platform for use outside of the TASConnect Platform (such as collecting contact details or other User data obtained via the TASConnect Platform to contact Users outside the TASConnect Platform), unless otherwise permitted for the Permitted Purpose; or
      17. use the TASConnect Platform to conduct any business or regulated activities (including to offer, solicit, invite, advise (including any corporate, financial, legal, tax, accounting, or investment advice) or recommend any financial services or products, or to execute or enter into any agreement or arrangement (including to provide the financial and/or payment services in relation to the Invoices) other than as a data management solution as agreed by Customer and Bank Participant.
  5. Bank Participant’s use of data obtained from the TASConnect Platform
    1. Bank Participant acknowledges and agrees that it is the Customer that controls its own Workspace, meaning that the Customer is the party that makes the decisions in relation to the use of Customer Data and controls who else has access to the Customer Data and the other settings (including rights and permissions) on the Workspace. For example, the Customer is the party that has decided to grant Bank Participant permission to access their Workspace and/or for Customer Data to be transmitted to Bank Participant’s system and/or may enable or disable representatives or other Users to access any Customer Data that has been submitted to the Customer’s Workspace. The choices that Customer makes in configuring its Workspace in relation to Customer Data will affect how the Customer Data is accessed, used, disclosed, modified, deleted or otherwise processed.
    2. To the extent that Bank Participant provides any information to the TASConnect Platform (via the TASConnect APIs, other automatic transfer or specific uploads), Bank Participant acknowledges and agrees that, as between Bank Participant, the Customer and TASConnect, it is the Customer who is solely responsible for:
      1. informing Bank Participant and its representatives of their policies as to how they intend to process and share the information or content that Bank Participant submits to the TASConnect Platform (for the most part, we will merely follow the Customer’s instructions to process that information or content);
      2. obtaining any rights, permissions or consents from Bank Participant and its representatives that are necessary for the lawful use of any content or information that Bank Participant submits to the Customer’s Workspace (including any transfer of such content or information to another party or another jurisdiction); and
      3. ensuring that the Bank Participant and its representatives understand any settings, rights and permissions that may be available on the Customer’s Workspace;
      4. resolving and responding to any disputes or grievances Bank Participant or its representative may have in relation to how content or information it submits to the Customer’s Workspace is processed.
    3. Bank Participant acknowledges and agrees that:
      1. it will not process Customer Data on our behalf or jointly with us;
      2. it accesses and processes Customer Data as an independent Controller;
      3. it shall comply with, and process all Customer Data in accordance with, all Data Protection Legislation applicable to Bank Participant; and
      4. it shall provide due notices to, and obtain any required consents from, any individuals of Bank Participant’s relevant privacy policies and it shall comply with, and process all Customer Data in accordance with, such privacy policies.
    4. We expect that Bank Participant will process Customer Data with the highest international standards. Without limiting Bank Participant’s obligations under clause 5.3, Bank Participant warrants and represents to us on a continuing basis that:
      1. Bank Participant does and will continue to comply at all times with all applicable obligations in the context of Bank Participant’s relationships with other parties (including Customer and Users), and with all Data Protection Legislation applicable to it;
      2. Bank Participant will not access, use, share or otherwise disclose any Customer Data for any purpose other than the Permitted Purpose;
      3. it has (and will have) all right necessary for data that it submits or transmits on or via the TASConnect Platform and that the collection, use or retention of Customer Data and other data will not violate any law or rights of others;
      4. Bank Participant will take all appropriate technical and organisational measures in accordance with Good Industry Practice to protect against unauthorised or accidental or unlawful processing or use of the Customer Data and to protect Customer Data against accidental or unauthorised loss or destruction or damage to Customer Data;
      5. Bank Participant will at all times ensure it is aware of and have documentation of the location of all copies of Customer Data in its possession or control;
      6. Bank Participant will ensure that its representatives and any party to whom Bank Participant provides access to the Customer Data is subject to written terms at least as stringent as those applying to the Bank Participant in respect of the Customer Data.
  6. Bank Participant data
    1. Bank Participant remains responsible for its own data and materials and for taking steps to maintain appropriate security, protection and backup of Bank Participant’s own data and materials in connection with its use of the TASConnect Platform, TASConnect APIs and TASConnect API Materials. We are not responsible for any unauthorised access to, alteration of, or deletion, destruction, damage, loss or failure to store any of Bank Participant’s data and materials in connection with the TASConnect Platform, TASConnect APIs or TASConnect API Materials (including as a result of Bank Participant’s or any other party’s errors, acts or omissions).
    2. As between Bank Participant and us, Bank Participant retains ownership of all of its own data. Bank Participant grants us a worldwide, non-exclusive, royalty-free, transferable licence to access, use, process, copy, distribute, perform, export and display Bank Participant’s data for the purposes of these Bank Participant Terms, to provide services to Customer and others, to protect the TASConnect Platform, to improve the TASConnect Platform or TASConnect products and services, or as required by applicable law or as otherwise agreed by Bank Participant. Bank Participant represents and warrants that it has obtained and will maintain all rights in and to Bank Participant’s data as is necessary to grant this licence.
    3. We may disclose Bank Participant data to any person:
      1. to (or through) whom it assigns or transfers (or may potentially assign or transfer) all or any of its rights and/or obligations under these Bank Participant Terms and, in each case, to any of that person’s Affiliates, representatives and professional advisers;
      2. to whom information is required or requested to be disclosed by any court of competent jurisdiction or any governmental, banking, taxation or other regulatory authority or similar body, the rules of any relevant stock exchange or pursuant to any applicable law or regulation;
      3. to whom information is required to be disclosed in connection with, and for the purposes of, any litigation, arbitration, administrative or other investigations, proceedings or disputes; and
      4. in accordance with the confidentiality provisions in the Bank Participant Terms.
  7. Intellectual Property Rights
    1. As between Bank Participant and us, we own all right, title and interest in and to the TASConnect Platform, the TASConnect APIs or the TASConnect API Materials. Except as expressly stated in these Bank Participant Terms, nothing in these Bank Participant Terms transfers any intellectual property rights, title or interest in or to the TASConnect Platform, the TASConnect APIs or the TASConnect API Materials to Bank Participant.
  8. TASConnect responsibilities relating to data
    1. To the extent that we process any of Personal Data as a Controller, we will comply with the TASConnect Privacy Policy and Data Protection Legislation applicable to TASConnect. TASConnect shall take appropriate measures in accordance with Data Protection Legislation applicable to TASConnect to help prevent unauthorised or unlawful processing, accidental loss or destruction of Personal Data and to maintain the integrity of the Personal Data.
  9. Indemnity and Limitation of Liability
    1. The TASConnect Platform is provided on an “as is” and “as available” basis. We make no representations, warranties or guarantees, whether express or implied, regarding the TASConnect Platform and expressly disclaims any and all representations, warranties or guarantees of accuracy, merchantability, non-infringement, fitness for a particular purpose, or that the TASConnect Platform will be uninterrupted, timely, secure, or error-free. In addition, we expressly disclaim any and all representations, warranties or guarantees regarding the accuracy, completeness or currency of the information on the TASConnect Platform or any Customer Data, and any reliance on the information on the TASConnect Platform or any Customer Data is at User’s own risk.
    2. While we will make all reasonable efforts to ensure the security of the TASConnect Platform, there are inherent risks in internet-based services and we therefore cannot guarantee the security or confidentiality of any information that Bank Participant submits to the TASConnect Platform.
    3. To the maximum extent permitted by applicable law, we shall have no liability to Bank Participant for any direct, indirect, consequential, special or loss or damage that Bank Participant may suffer in connection with Bank Participant’s use of the TASConnect Platform, including Bank Participant’s reliance on the information on the TASConnect Platform or any Customer Data.
    4. To the maximum extent permitted by applicable law, to the extent that clause 9.3 is not effective, TASConnect’s aggregate liability to Bank Participant will be limited to USD 100.
    5. Bank Participant indemnifies us from and against any direct, indirect, consequential, special or loss or damage that we may suffer in connection with Bank Participant’s breach of these Bank Participant Terms (including the acts or omissions of Bank Participant’s representatives) in using the TASConnect Platform, TASConnect APIs, TASConnect API Materials, including Bank Participant’s reliance on the information on the TASConnect Platform or any Customer Data.
  10. Links to Third Party Sites
    1. To the extent that there are links to other websites or apps owned and operated by third parties on the TASConnect Platform (each a “Linked Site”), Bank Participant acknowledges and agrees that such Linked Sites are not under the control of TASConnect and we shall not be responsible for Bank Participant’s access of, and any content of, any such Linked Sites. We do not endorse any Linked Site (or its services or products) and makes no representations or warranties with respect to the Linked Sites or their contents, terms and conditions, privacy policies or activities. We shall not, in any event, be deemed as a party to any transaction between Bank Participant and the Linked Site. Bank Participant’s access or use of such Linked Site is entirely at Bank Participant’s own risk.
  11. Warranties and representations
    1. Each party (being each of ourselves and the Bank Participant and each being referred to as an “it” below) makes the representations and warranties set out in these Bank Participant Terms on each day for the duration that these Bank Participant Terms are in effect:
      1. it is a corporation, duly incorporated and validly existing under the law of its jurisdiction of incorporation;
      2. it has the power to own its assets and carry on its business as it is being conducted;
      3. the entry into and performance by it of these Bank Participant Terms do not and will not conflict with (i) any law or regulation applicable to it; (ii) its constitutional documents; (iii) any agreement or instrument binding upon it or any of its assets;
      4. it has the power to enter into, perform and deliver, and has taken all necessary action to authorise its entry into, performance and delivery of, Bank Participant Terms;
      5. it has (and in the case of the Bank Participant only, that it has also procured that each of its representatives has) obtained all applicable authorisation, consent, approval, resolution, licence, exemption, filing, notarisation, lodgement or registration authorisations (“Authorisations”) required for it to lawfully enter into, exercise its rights and comply with its obligations under the Bank Participant Terms (and in the case of the Bank Participant only, to provide the financial or payment services in relation to the Invoices), and all such Authorisations, licenses and regulatory approvals are in full force and effect;
      6. it shall comply in all respects with all laws to which it may be subject;
      7. its officers, directors and employees are subject to policies and procedures designed to prevent the occurrence of bribery and corrupt conduct and it shall procure compliance with such policies and procedures by them;
      8. it has not (and undertake that they shall not) engage in making any payments or transfers of value, offers or promises, giving any financial or other advantage, making any requests, agreements to receive or accepting any financial or other advantage, in each case either directly or indirectly which has the purpose or effect of, or would mean acceptance of or acquiescence in, either directly or indirectly, public or commercial bribery, other unlawful or improper means of obtaining or retaining business or commercial advantage, or the improper performance of any function or activity; and
      9. it shall procure compliance with the obligations in clauses 11.1(G) and (H) from each of its officers, directors, employees, other associated persons, agents or subcontractors.
  12. General
    1. We may take any action which in our sole discretion we consider appropriate so as to comply with any applicable law, regulation or any policy which relates to the prevention of fraud, money laundering, terrorism or other criminal activities or the provision of financial and other services to sanctioned persons or entities. In certain circumstances, such action may delay or prevent the processing of instructions or our performance of our obligations under these Bank Participant Terms. We shall not be liable for any loss (whether direct, indirect or consequential and including, without limitation, loss of profit or interest) caused in whole or in part by any actions which are taken by us pursuant to this clause.
  13. Confidentiality
    1. Each party agrees to keep all Confidential Information confidential and not to disclose it to anyone without the other party’s prior written consent and to ensure that all Confidential Information is protected with security measures and a degree of care that you or we, as the case may be, would apply to your or our, as the case may be, own Confidential Information.
    2. Each party may disclose:
      1. to any of your/our Affiliates and any of your/our or their officers, directors, employees, professional advisers, auditors, partners and representatives who need to know such Confidential Information if (i) any person to whom the Confidential Information is to be given pursuant to this paragraph (A) is informed in writing of its confidential nature and that some or all of such Confidential Information may be price-sensitive information, (ii) that the Confidential Information disclosed is only limited to the extent needed; except that there shall be no such requirement to so inform if the recipient is subject to professional obligations to maintain the confidentiality of the information or is otherwise bound by requirements of confidentiality in relation to the Confidential Information; and
      2. to any person:
        1. to (or through) whom you/we assign(s) or transfer(s) (or may potentially assign or transfer) all or any of your/our rights and/or obligations under these Bank Participant Terms and, in each case, to any of that person’s Affiliates and any of yours/our or their officers, directors, employees, professional advisers, auditors, partners and representatives;
        2. appointed by you/us or by a person to whom paragraph (A) above applies to receive communications, notices, information or documents delivered pursuant to these Bank Participant Terms on your/our behalf;
        3. who invests in or otherwise finances (or may potentially invest in or otherwise finance), directly or indirectly, any Invoice;
        4. to whom information is required or requested to be disclosed by any court of competent jurisdiction or any governmental, banking, taxation or other regulatory authority or similar body, the rules of any relevant stock exchange or pursuant to any applicable law or regulation;
        5. to whom information is required to be disclosed in connection with, and for the purposes of, any litigation, arbitration, administrative or other investigations, proceedings or disputes;
        6. who is a party; or
        7. with the consent of the other party,

        in each case, such Confidential Information shall be disclosed only to the extent necessary;

      3. to any auditor;
      4. to any person appointed by you/us or by a person to whom paragraph (B)(1) or (B)(2) above applies to provide administration or settlement services in respect of the services and transactions contemplated under these Bank Participant Terms, such Confidential Information as may be required to be disclosed to enable such service provider to provide any of the services referred to in this paragraph (D); and
      5. to any rating agency (including its professional advisers) such Confidential Information as may be required to be disclosed to enable such rating agency to carry out your/our normal rating activities in relation to services and transactions contemplated under these Bank Participant Terms.
  14. Termination
    1. Bank Participant agrees that we have the right, in our sole discretion, to terminate Bank Participant’s use of the TASConnect Platform, TASConnect APIs and TASConnect API Materials temporarily or permanently at any time without prior notice, including in the case of (i) any suspected or actual non-compliance by Bank Participant with the representations and warranties set out at the beginning of these Bank Participant Terms; (ii) any suspected or actual breach of these Bank Participant Terms, User Terms, TASConnect Privacy Policy and/or any other terms and conditions and policies published on the TASConnect Platform by Bank Participant or its representative; (iii) Bank Participant or its representative act or behave in a manner which results in, or is likely to result in, any harm to TASConnect or its Affiliates, including its employees, directors and officers; (iv) termination of any agreement between TASConnect and Customer with regard to use of the TASConnect Platform; or (v) Customer requests TASConnect terminate such use by Bank Participant.
    2. Termination of these Bank Participant Terms shall not affect any rights or obligations which may have accrued prior to termination. The provisions relating to indemnities, limitation of liability, confidentiality, disclosure of information, governing law and jurisdiction survive termination of these Bank Participant Terms.
  15. Assignment
    Bank Participant may not assign or transfer any of its rights or obligations under these Bank Participant Terms without our prior written consent.
  16. Dispute Resolution
    1. These Bank Participant Terms are governed by the laws of Singapore. The courts of Singapore have exclusive jurisdiction to settle any dispute arising out of or in connection with these Bank Participant Terms (including any dispute regarding their existence, validity or termination) (a “Dispute”). Bank Participant agrees that the courts of Singapore are the most appropriate and convenient courts to settle any Dispute and accordingly will not argue to the contrary. Notwithstanding the foregoing, neither party shall be prevented from taking proceedings relating to a Dispute in any other courts with jurisdiction. To the extent allowed by applicable law, we may take concurrent proceedings in any number of jurisdictions.
  17. Updates and Amendments
    1. We reserve the right to revise these Bank Participant Terms or any of the terms incorporated by reference from time to time as and when necessary without prior notice (subject to the terms set out applicable law). Any such amendments shall take effect from the date they are published on the TASConnect Platform. For the avoidance of doubt, the version that is published on the TASConnect Platform is the relevant version of these Bank Participant Terms that apply at the time Bank Participant uses the TASConnect Platform, TASConnect APIs or TASConnect API Materials and the version published on the TASConnect Platform supersedes any earlier version that Bank Participant may have received by other means.
  18. Interpretation
    1. These Bank Participant Terms along with the User Terms, TASConnect Privacy Policy and any other terms and conditions and policies published on the TASConnect Platform constitute the entire understanding between Bank Participant and us in connection with the TASConnect Platform.
    2. Headings used in these Bank Participant Terms are for convenience and shall not be used as any basis on which the meaning of the Bank Participant Terms shall be interpreted. If any provision of these Bank Participant Terms is found by a court of competent jurisdiction to be invalid, then Bank Participant and us nevertheless agree that the court should endeavour to give effect to our intentions as reflected in the provision and all other provisions of these Participant Terms shall remain in full force and effect.
  19. Definitions
    “Affiliate” means, in relation to any person, a Subsidiary of that person or a Holding Company of that person or any other Subsidiary of that Holding Company.
    “Confidential Information” means, in relation to a party (the “Recipient”), all information relating to the other party (the “Disclosing Party”) or its Affiliates or these Bank Participant Terms, of which the Recipient becomes aware in whatever form, and includes information given orally and any document, electronic file or any other way of representing or recording information which contains or is derived or copied from such information but excludes information that:

    1. is or becomes public information;
    2. is identified in writing at the time of delivery as non-confidential by the Disclosing Party or its Affiliates or any of its advisers;
    3. is known by the Recipient before the date the information is disclosed to it or is lawfully obtained by the Recipient after that date, from a source which is, as far as the Recipient is aware, unconnected with the Disclosing Party and its Affiliates and which, in either case, as far as the Recipient is aware, has not been obtained in breach of, and is not otherwise subject to, any obligation of confidentiality.

    “Controller” means the entity which determines the purposes and means of processing of Personal Data.

    “Customer” means the organisation which has signed an agreement with TASConnect to have a Workspace and receive certain TASConnect services.

    “Customer Data” means all information of whatever nature which may from time to time be submitted to the Customer’s Workspace.

    “Customer Terms” means the terms and conditions between the Customer and TASConnect in relation to the Customer’s use of the TASConnect Platform to have a Workspace and receive certain services from TASConnect.

    “Data Protection Legislation” means the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore and any other legislation wherever in the world that relates to the processing of personal data and/or privacy and applies in connection with the existence or operation of these Bank Participant Terms and all applicable guidance and codes of practice.

    “Good Industry Practice” means that degree of skill, diligence, care, prudence, foresight and operating systems and practice which would reasonably and ordinarily be expected of a skilled and experienced financial institution engaged in the same or a similar type of business as that of the Bank Participant under similar circumstances.

    “Holding Company” means, in relation to a person, any other person in respect of which it is a Subsidiary.

    “Invoice” means an invoice of (i) either the Customer (or any of its Affiliates as may be agreed between the Customer and us pursuant to the Customer Terms) to its customer; or (ii) an invoice of a supplier to either the Customer (or any of its Affiliates as may be agreed between the Customer and us pursuant to the Customer Terms).

    “TASConnect APIs” means the application programming interfaces provided by TASConnect.

    “TASConnect API Materials” means the materials that TASConnect makes available to Bank Participant in connection with the TASConnect APIs, including documentation, specifications, software libraries, software development kits and other supporting materials.

    “TASConnect Platform” means the internet-based platform, accessed via www.tasconnect.com or such other website as TASConnect may determine, provided by TASConnect under these Bank Participant Terms, all as customised, modified or amended from time to time.

    “TASConnect Privacy Policy” means the privacy policy located at www.tasconnect.com.

    “Permitted Purpose” has the meaning given to it in clause 1.3.

    “Personal Data” has the meaning given to the term “personal data” or “personal information” in any applicable Data Protection Legislation.

    “Sanctioned Country” means a country or territory which is subject to Sanctions.

    “Sanctions” means country-wide or territory-wide economic or financial sanctions or trade embargoes imposed or administered by the US Department of Treasury through its Office of Foreign Assets Control (“OFAC”), the United Nations Security Council, the European Union, a member state of the European Union, the Government of the United Kingdom, or the relevant governmental authorities of the country where Bank Participant is incorporated, each such authority as amended, supplemented or substituted from time to time.

    “Sanctions List” means any of the lists of specifically designated nationals or designated persons or entities (or equivalent) who are the subject of Sanctions (including as a result of being owned or controlled directly by such a person or entity) published by:

    1. the US Department of Treasury as administered by OFAC;
    2. the United Nations Security Council;
    3. the European Union;
    4. a member state of the European Union;
    5. the Government of the United Kingdom, or

    each such list and authority as amended, supplemented or substituted from time to time. “Subsidiary” means, in relation to any company or corporation, a company or corporation:

    1. which is controlled, directly or indirectly, by the first mentioned company or corporation;
    2. more than half the issued equity share capital of which is beneficially owned, directly or indirectly, by the first mentioned company or corporation; or
    3. which is a Subsidiary of another Subsidiary of the first mentioned company or corporation,

    and, for this purpose, a company or corporation shall be treated as being controlled by another if that other company or corporation is able to direct its affairs and/or to control the composition of its board of directors or equivalent body.
    “User” means an individual authorised by a Customer to access the Customer’s Workspace and/or receive or submit any data (including via the TASConnect APIs, other automatic transfer or specific uploads) and may include any personnel of the Customer, and representatives of a Customer’s customer or supplier or the Bank Participant, in each case as designated by the relevant Customer and notified to TASConnect via the functionalities of the TASConnect Platform.
    “User Terms” means the terms available at www.tasconnect.com that each individual User must agree to in order to access the TASConnect Platform.
    “Workspace” means a unique domain or instance of the TASConnect Platform dedicated for use by a Customer and its Users.

TERM OF USE

These terms and conditions (“User Terms”) shall govern your use of the TASConnect Platform (defined below) and shall form

TASConnect User Terms

a binding contract between you and SCV Research and Development Pte. Ltd (a company incorporated and registered in Singapore with company number [202120852K] with its registered office at 80 Robinson Road, #02-00, Singapore 068898) (“TASConnect”, “we” or “us”), and shall be deemed to include the rules, guidelines, policies and other terms and conditions published on the TASConnect Platform from time to time that are applicable to any specific product or service that you use on the TASConnect Platform.

By accessing and using the TASConnect Platform (including after a change to these User Terms), you confirm that you have carefully read and agree to these User Terms. If you do not agree to these User Terms, please do not use the TASConnect Platform. 

You represent and warrant that (i) you comply in all respects with Sanctions that are applicable to you; (ii) you are not subject to Sanctions or located or resident in a Sanctioned Country or on a Sanctions List; (iii) you are not accessing the TASConnect Platform from a Sanctioned Country; (iv) your use of the TASConnect Platform complies with Sanctions and all applicable laws and regulations at all times. You acknowledge that we reserve the right to suspend or terminate your access to the TASConnect Platform at any time if we believe, in our sole discretion, that your access to the TASConnect Platform may cause us to be in breach of Sanctions, laws, regulations or our policies relating to our compliance obligations.

 

The definitions of capitalised terms used in these User Terms are set out at the end of this webpage.

  1. Your Relationship with Us
      1. An organisation or other third party that we refer to in these User Terms as “Customer” has invited you to be a User of their Workspace.  The Customer has separately agreed to a set of Customer Terms that permits them to create, configure and control the Workspace to which you have been invited as a User.
      2. Once you have been given access to the Customer’s Workspace, you become a User of the Customer that controls that Workspace. Being a User means you have been authorised by one of our Customers to access their Workspace, access certain information in their Workspace and certain other features available on their Workspace.
      3. When you submit, or approve for submission, any content or information to the TASConnect Platform, whether directly or through automated data transfer, that content or information becomes Customer Data. You acknowledge and agree that the Customer Data on the TASConnect Platform will be owned by Customer. 
      4. The Customer controls its own Workspace, meaning that the Customer is the party that makes the decisions in relation to the use of Customer Data and controls who else has access to the Customer Data and the other settings (including rights and permissions) on the Workspace. For example, the Customer is the party that has decided to grant you permission to access their Workspace and may enable or disable other Users to access any Customer Data that has been submitted to the Customer’s Workspace. The choices that Customer makes in configuring its Workspace in relation to Customer Data will affect how the Customer Data is accessed, used, disclosed, modified, deleted or otherwise processed. 
      5. When you are accessing a Workspace as a User, you acknowledge and agree that, as between you, the Customer and TASConnect, it is the Customer who is solely responsible for:
        1. informing you of their policies as to how they intend to process and share the information or content that you submit to the TASConnect Platform (for the most part, we will merely follow the Customer’s instructions to process that information or content);
        2. obtaining any rights, permissions or consents from you (or the entity that you represent) necessary for the lawful use of any content or information that you submit to the Customer’s Workspace (including any transfer of such content or information to another party or another jurisdiction); 
        3. ensuring that you understand any settings, rights and permissions that may be available on the Workspace; and
        4. resolving and responding to any disputes or grievances you (or the entity you represent) may have in relation to how content or information you submit, or approve for submission, to the Customer’s Workspace is processed.  
      6. If you are a User, you acknowledge and agree that you are able to use the TASConnect Platform as a User subject always to the Customer’s continued permission to designate you as a User and your compliance with these User Terms. 

    Bank Participant User 

      1. If you are a representative of a Bank Participant, you acknowledge and agree that your access and use of certain Customer Data is also subject to the Bank Participant Terms, that the Bank Participant is an independent Controller of the data that it collects or uses from the TASConnect Platform, and therefore as a representative of the Bank Participant, you must also comply at all times with the Bank Participant’s additional obligations (as required by applicable law and by the Bank Participant Terms).    
      2. If you are using the TASConnect Platform as a representative of the Bank Participant, without prejudice to Clause 1.7 above, you also acknowledge and agree that you are able to use the TASConnect Platform subject always to (i) the Bank Participant’s continued nomination by the Customer, (ii)  the Bank Participant’s continued permission to designate you as its representative, (iii) the Bank Participant’s acceptance of the Bank Participant Terms, and (iv) these User Terms. 
      3. If you are using the TASConnect Platform as a representative of the Bank Participant, you represent and undertake that you have obtained all applicable authorisation, consent, approval, resolution, licence, exemption, filing, notarisation, lodgement or registration authorisations (“Authorisations”) required for you to lawfully enter into, exercise its rights and comply with its obligations under these User Terms (including to act as a representative of the Bank Participant in relation to your usage of the TASConnect Platform, including access to the specific Customer Workspace), and all such Authorisations are in full force and effect. 
  2. Services on the TASConnect Platform
    1. The TASConnect Platform is a data management solution which is provided by us to the Customer to automate Customer’s designated workflow(s), including Customer’s management of its Invoices  and to streamline data transfer as specified by Customer between Customer and Customer’s Users (including Bank Participants).  Amongst others, we will enable Customer Data to be shared based on the configuration and control of the Workspace by the Customer and will provide tools for the management of information  as may be agreed between us and the Customer pursuant to the Customer Terms.   
    2. You acknowledge and agree to the functionalities of the TASConnect Platform as described in Clause 2.1 above.  In addition, you acknowledge and agree that the TASConnect Platform is only a workflow management tool and therefore that: 
      1. none of the information or services available on the TASConnect Platform shall be (or shall be construed as) an offer, solicitation, invitation, advice (including any corporate, financial, legal, tax, accounting, or investment, advice) or recommendation for financial services or products whether by TASConnect or any other Users, and you should not take, or omit to take, any action, in reliance on the content of the TASConnect Platform without seeking independent verification or advice; and
      2. the TASConnect Platform does not permit nor allow you to buy or receive any financial products or services from any of the Users (including a Bank Participant).  
  3. Your Activities
    1. Without limiting anything set out in these User Terms, you represent and warrant that all the content and information you submit to the TASConnect Platform (including any documents submitted to verify your identity), or that is submitted on your behalf by Customer, is genuine, accurate, lawful, valid, current and belongs to you or that you have all rights, permissions or consents to submit it to the TASConnect Platform for the purposes it is intended to be used. We will not be responsible for any loss or damages you suffer in connection with you being unable to use the TASConnect Platform or any product or service due to the content or information that you submit being incorrect, incomplete, or false. 
    2. We reserve all rights to reject, block, suspend, deactivate or remove any User from the TASConnect Platform. 
    3. You must not do any of the following: 
      1. impersonate or misrepresent yourself as another person;
      2. falsely hold yourself out as a representative of any organisation;
      3. reveal or share your login credentials to any other person;
      4. post any speculative, false, fictitious or fraudulent information on the TASConnect Platform;
      5. do anything that is illegal or potentially illegal, or that violates or potentially violates any applicable laws, regulations, rules and/or the rights (including intellectual property rights) of any person while using or in connection with your use of the TASConnect Platform;
      6. post anything on the TASConnect Platform that may be threatening, harassing, defamatory, obscene, or otherwise objectionable;
      7. upload, post, transmit or otherwise make available on the TASConnect Platform any unsolicited or unauthorised advertising, promotional materials, spam, or any other form of solicitation; 
      8. upload, post, transmit or otherwise make available on the TASConnect Platform, any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; 
      9. use any tool, robot, spider, scraper, or other automated means or any manual process for interfering with the any of the functionalities of the TASConnect Platform, extracting, interfering or monitoring any data on the TASConnect Platform and/or causing any disruptions and/or activities on the TASConnect Platform; or
      10. in the case of Users who are representatives of a Bank Participant, use the TASConnect Platform to conduct any business or regulated activities (including to offer, solicit, invite, advise (including any corporate, financial, legal, tax, accounting or investment advice) or recommend any financial services or products) or to execute or enter into any agreement or arrangement, or use the TASConnect Platform in any manner other than as a data management tool to streamline the exchange of data between Bank Participant and Users in relation the provision of financial or payment services by the Bank Participant which you represent. 
  4. Rights of Access and Intellectual Property Rights
    1. Nothing in these User Terms transfers any intellectual property rights, title or interest in or to the TASConnect Platform to you. 
    2. Subject to your compliance with these User Terms and the rights of the Customer for the time being to a Workspace and to grant you access as a User, TASConnect grants you a limited, non-exclusive, non-transferable, revocable right to use the TASConnect Platform in accordance with these User Terms. Any rights not explicitly granted in these User Terms are reserved by TASConnect. 
  5. Indemnity and Limitation of Liability
    1. The TASConnect Platform is provided to you on an “as is” and “as available” basis. TASConnect makes no representations, warranties or guarantees, whether express or implied, regarding the TASConnect Platform and expressly disclaims any and all representations, warranties or guarantees of accuracy, merchantability, non-infringement, fitness for a particular purpose, or that the TASConnect Platform will be uninterrupted, timely, secure, or error-free. In addition, TASConnect expressly disclaims any and all representations, warranties or guarantees regarding the accuracy, completeness or currency of the information on the TASConnect Platform or any Customer Data, and any reliance on the information on the TASConnect Platform or any Customer Data is at User’s own risk.   
    2. While we will make all reasonable efforts to ensure the security of the TASConnect Platform, there are inherent risks in internet-based services and we therefore cannot guarantee the security or confidentiality of any information that you submit to the TASConnect Platform. 
    3. To the maximum extent permitted by applicable law, TASConnect shall have no liability to you for any direct, indirect, consequential, special or loss or damage that you may suffer in connection with your use of the TASConnect Platform, including your reliance on the information on the TASConnect Platform or any Customer Data.
    4. To the maximum extent permitted by applicable law, to the extent that clause 5.3 is not effective, TASConnect’s aggregate liability to you will be limited to USD 100.
    5. All limitations and exclusions of liability in these User Terms are only effective to the extent not prohibited by applicable law. 
    6. You indemnify us from and against any direct, indirect, consequential, special or loss or damage that we may suffer in connection with your breach of these User Terms or your acts or omissions in using the TASConnect Platform, including your reliance on the information on the TASConnect Platform or any Customer Data. 
  6. Links to Third Party Sites
    1. To the extent that there are links to other websites or apps owned and operated by third parties on the TASConnect Platform (each a “Linked Site”), you acknowledge and agree that such Linked Sites are not under the control of TASConnect and TASConnect shall not be responsible for your access of, and any content  of, any such Linked Sites. TASConnect does not endorse any Linked Site (or its services or products) and makes no representations or warranties with respect to the Linked Sites or their contents, terms and conditions, privacy policies or activities. TASConnect shall not, in any event, be deemed as a party to any transaction between you and the Linked Site. Your access or use of such Linked Site is entirely at your own risk.
  7. Termination
    1. You understand and agree that we have the right to terminate your use of the TASConnect Platform temporarily or permanently at any time without prior notice, including in the case of any suspected or actual non-compliance with the representations and warranties set out at the beginning of these User Terms.  
    2. Termination of your use of the TASConnect Platform shall not affect any rights, obligations and liabilities that have accrued before the date of such termination.
  8. Privacy
    1. We respect your privacy. To the extent that we process any of your Personal Data as a Controller, we will comply with the TASConnect Privacy Policy. Please note that Customers and Bank Participants may also be independent Controllers in relation to your Personal Data. To the extent that your Personal Data is processed by Customers or Bank Participants, please refer to the privacy policies of those parties.    
  9. Dispute Resolution
    1. These User Terms are governed by the laws of Singapore. The courts of Singapore have exclusive jurisdiction to settle any dispute arising out of or in connection with these User Terms (including any dispute regarding their existence, validity or termination) (a “Dispute”). You agree that the courts of Singapore are the most appropriate and convenient courts to settle any Dispute and accordingly will not argue to the contrary. Notwithstanding the foregoing, you shall not be prevented from taking proceedings relating to a Dispute in any other courts with jurisdiction.  To the extent allowed by applicable law, we may take concurrent proceedings in any number of jurisdictions.
  10. Updates and Amendments
    1. We reserve the right to revise these User Terms or any of the terms incorporated by reference from time to time as and when necessary without prior notice (subject to the terms set out applicable law). Any such amendments shall take effect from the date they are published on the TASConnect Platform.    
  11. Interpretation
    1. These User Terms along with the TASConnect Privacy Policy and any other policies published on the TASConnect Platform constitute the entire understanding between you and us in connection with the TASConnect Platform. 
    2. Headings used in these User Terms are for convenience and shall not be used as any basis on which the meaning of the User Terms shall be interpreted. If any provision of these User Terms is found by a court of competent jurisdiction to be invalid, then you and us nevertheless agree that the court should endeavour to give effect to our intentions as reflected in the provision and all other provisions of these User Terms shall remain in full force and effect.
  12. Definitions

“Bank Participant” means any financial institution nominated by a Customer (and as may be agreed by us pursuant to the Customer Terms) as a financier or service provider to provide Customer or other Users with financial or payment services and to whom Customer grants access to certain of the Customer Data.

“Bank Participant Terms” means the standard online terms between each Bank Participant and us and which governs how each Bank Participant may use certain application programming interfaces provided by us and how each Bank Participant is required to handle the data collected or obtained from the TASConnect Platform.

“Controller” means the entity which determines the purposes and means of processing of Personal Data.

“Customer” means the organisation which has signed an agreement with TASConnect to have a Workspace and receive certain TASConnect services. 

“Customer Data” means all information of whatever nature which may from time to time be submitted to the Customer’s Workspace (including the Invoices).

“Customer Terms” means the terms and conditions between the Customer and TASConnect in relation to the Customer’s use of the TASConnect Platform to have a Workspace and receive certain services from TASConnect.

“Data Protection Legislation” means the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore and any other legislation wherever in the world that relates to the processing of personal data and/or privacy and applies in connection with the existence or operation of these User Terms and all applicable guidance and codes of practice. 

“Invoice” means: 

  1.  (i) an invoice of either the Customer (or any of its affiliates as may be agreed between the Customer and us pursuant to the Customer Terms) to a customer; or 
  2. (ii) invoice of a supplier (to either the Customer (or any of its affiliates as may be agreed between the Customer and us pursuant to the Customer Terms) .

“TASConnect Platform” means the internet-based platform, accessed via www.tasconnect.com or such other website as TASConnect may determine, provided by TASConnect under these User Terms, all as customised, modified or amended from time to time.

“TASConnect Privacy Policy” means the privacy policy located at www.tasconnect.

“Personal Data” has the meaning given to the term “personal data” or “personal information” in any applicable Data Protection Legislation.

“Sanctioned Country” means a country or territory which is subject to Sanctions.

“Sanctions” means country-wide or territory-wide economic or financial sanctions or trade embargoes imposed or, administered by the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”), the United Nations Security Council, the European Union, a member state of the European Union, the Government of the United Kingdom, or the relevant governmental authorities of the country where you or the entity you represent are incorporated, each such authority as amended, supplemented or substituted from time to time. 

“Sanctions List” means any of the lists of specifically designated nationals or designated persons or entities (or equivalent) who are the subject of Sanctions (including as a result of being owned or controlled directly by such a person or entity) published by:

  1. the United States Department of Treasury, as administered by OFAC;
  2. the United Nations Security Council;
  3. the European Union; 
  4. a member state of the European Union,
  5. the Government of the United Kingdom; or
  6. any relevant governmental authorities of the country where you or the entity you represent are incorporated;

each such list and authority as amended, supplemented or substituted from time to time.

“User” means an individual authorised by a Customer to access the Customer’s Workspace and/or receive or submit any data (including via the TASConnect APIs, other automatic transfer or specific uploads) and may include any personnel of the Customer, and representatives of a Customer’s customer, Customer’s supplier or the Bank Participant, in each case as designated by the relevant Customer and notified to TASConnect via the functionalities of the TASConnect Platform.  

“Workspace” means a unique domain or instance of the TASConnect Platform dedicated for use by a Customer and its Users.

FINANCIAL CRIME COMPLIANCE

OUR COMMITMENT

TASConnect’s ambition is to tackle some of today’s most damaging crimes by making the financial system a hostile environment for criminals and terrorists.

Principles

The following principles reflect the minimum expectations of TASConnect.

  • Zero tolerance approach to Bribery and Corruption and will not tolerate the giving, offering, promise or receipt of bribes in any form, including kickbacks, by any person on its behalf, or for whom it is responsible, whether directly or via another party. TASConnect also takes its responsibility to counter the risk that it might be used to further financial crime (including crimes involving fraud or the laundering of the proceeds of such crimes) extremely seriously.
  • TASConnect ensure the business is backed by robust financial crime compliance efforts that address the inherent risk of the people, companies and markets that we serve.
  • Risk-based approach to an effective financial crime compliance (“FCC”). TASConnect allocates responsibilities for Financial Crime risk in a manner consistent with the three Lines of Defence model described in our Enterprise Risk Management Framework

ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM PROGRAMME

Money Laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds of their criminal activities and thereby have these funds enter the normal economy to make it seem as if they have been obtained legitimately.

SANCTIONS COMPLIANCE PROGRAMME

TASConnect complies with all applicable sanctions through the FCC initiative. TASConnect has also established internal prohibitions and restrictions on certain types of business which are not prohibited by applicable sanctions but are imposed through TASConnect’s Policy based on certain risk decisions designed to minimise the potential of sanctions breaches and related risk.

TASConnect will not enter business of any kind, directly or indirectly, involving or for the benefit of Sanctioned Parties unless permitted. The prohibition applies even where such dealings would be permitted by applicable law.

Where parties are listed as the target of Sanctions by countries or organisations other than the UN, EU, UK or US, TASConnect and staff must comply with these sanctions if they apply to them and their business. Any potential conflicts of law must be escalated.

TASConnect will not enter business of any kind, directly or indirectly, involving or for the benefit of any person or entity located in a Sanctioned Country or Territory or with the government of that country or leadership of the territory, including all its agents, agencies, departments, and instrumentalities wherever they are in the world, unless otherwise permissible.

TASConnect has established Client Due Diligence standards to identify sanctions risk and ensure that TASConnect reasonably knows its client at the time of onboarding, and through the life cycle of the client relationship.

ANTI-BRIBERY AND CORRUPTION (“ABC”) PROGRAMME

Bribery and Corruption have a significant adverse effect on the social and economic development of the communities in which TASConnect operates. TASConnect adopts a zero-tolerance approach to Bribery and Corruption and will not tolerate the giving, offering, promise or receipt of bribes in any form, including kickbacks, by any person on its behalf, or for whom it is responsible, whether directly or via another party. TASConnect also takes its responsibility to counter the risk that it might be used to further financial crime extremely seriously.

TASConnect will not engage in Bribery or Corruption activities or create the appearance of Bribery and Corruption and are prohibited from:

  1. Giving and Receiving of Bribes
  2. Giving or accepting Anything of Value of a person promising or asserting the ability to improperly influence a Public Official
  3. The use of employment opportunities when vetting or hiring staff to obtain or retain business or a business advantage, or to influence a Public Official
  4. Gifts and Entertainment (unless permitted)
  5. Sponsorship and Donations (unless permitted)

FINANCIAL CRIME COMPLIANCE RELATED INITIATIVE

TASConnect is working hard to ensure the business is backed by robust financial crime compliance efforts that address the people, companies and markets.

Financial Crime Risk related principles:

  • Establish policies, operating standards, and control processes reasonably designed to create compliance with applicable legal and regulatory requirements and in line with risk assessment.
  • Comply with all applicable legal and regulatory requirements.
  • Support governments, law enforcement agencies and international bodies in combating financial crime.
  • Apply a high-level risk assessment.

 

©TASConnect

ENTERPRISE RISK MANAGEMENT

The Enterprise Risk Management (“ERM”) function is responsible for providing TASConnect’s Board and Management with a comprehensive and independent assessment of the risk exposure of the Company, effectiveness of the risk mitigation and management activities, and summary of the risk limits and utilisation. These activities effectively create an oversight function that provides a second line of defense to all other risk and control functions of the Company.

STRATEGY AND STRATEGIC RISK MANAGEMENT

TASConnect adopts the following principles to direct its risk management. The principles are reinforced by the Company’s risk culture, to identify and assess current and future risks, discuss these risks, and take prompt actions.

TASConnect will strive to balance the relationship between growth, risk and return. While there is often a tendency to focus on additional mechanisms for reducing risk, there may be opportunities to accept greater risks so long as the additional risk levels are understood and managed.

TASConnect’s ERM process begins with the statement of risk appetite (“RA”) and the setting of strategic, financial, and other business objectives during the planning and budgeting process. These objectives cascade through to lines of business, as appropriate. Management will assess if there is an effective alignment of the proposed long-term strategic objectives with the risk appetite approved by the Board. The strategic plan also includes a risk dimension through evaluation of forecasts and scenarios and outlines appropriate risk mitigation strategies. These objectives cascade through to lines of business, as appropriate.

  1. Balancing risk and return – TASConnect is required to manage risks within its approved Risk Appetite and maintain a low probability of an unexpected loss event that would materially undermine the confidence of its clients, external stakeholders, and investors;
  2. Conduct of business – TASConnect is required to demonstrate strong conduct, to be mindful of the reputational consequences of inappropriate conduct; and to achieve fair outcomes for clients, investors, and the markets in which TASConnect operates, while abiding by the spirit and letter of applicable laws and regulations;
  3. Responsibility and accountability – risk taking activities are disciplined, transparent, controlled and focused, particularly within its authorities;
  4. Anticipation – TASConnect seeks to consider future material risks to learn lessons from events that have produced adverse outcomes, and to increase awareness of known risks; and
  5. Competitive advantage – TASConnect seeks to achieve competitive advantage through efficient and effective risk management.

1.RISK APPETITE

As a key to maintaining an acceptable level of risk in light of the financial and strategic objectives of the Company, TASConnect will function within the approved risk appetite and limits of the Board. To support this framework, the ERM functions sets and enforces limit triggers and escalation policies that are consistent with the Board-approved risk appetite.

TASConnect’s risk appetite is the approved boundary for the risk that TASConnect is willing to undertake. It is set within the risk capacity which is defined as the maximum level of risk that TASConnect can assume, given its current capabilities and resources, before breaching constraints determined by capital and liquidity requirements, internal operating environment, or otherwise failing to meet the expectations of regulatory authorities and law enforcement agencies.

2.CONDUCT RISK MANAGEMENT

It is important for TASConnect to manage Conduct Risk in order to deliver positive outcomes to investors, shareholders, counterparties, employees, markets, and competition, and provide all employees with a fair and safe working environment that is free from discrimination, exploitation, bullying, harassment, or inappropriate language.

TASConnect will be responsible for ensuring that the employees identify, mitigate, and monitor Conduct Risk.

TASConnect must demonstrate that Conduct Risk is considered when making material strategic decisions that may impact clients, investors, shareholders, counterparties, employees, markets, and competition.

3.THREE (3) LINES OF DEFENCE

The primary responsibility for the ERM function is to ensure it is conducting its monitoring and oversight role adequately across all risk types.

TASConnect’s processes must implement a maker-checker model with roles and responsibilities outlined below:

Table 1: Risk Management Activities

Role Definition Key Responsibilities
First Line The business or function engaged in or supporting revenue generating activities who own and manage the risks in these activities.
  1. Identify and propose the risks required to undertake the revenue generating activities.
  2. Identify, assess, monitor and escalate risks and events to Second Line and the management team.
  3. Set and execute risk remediation plans.
  4. Own and design processes, controls and standards for adhering to Frameworks and Policies set by the Second Line.
  5. Validate and self-assess compliance to Policies and Standards, confirm the quality of validation, and provide evidence-based affirmation to Second Line (where relevant).
  6. Ensure that applicable laws and regulations are being complied with and escalate significant regulatory non-compliance matters and developments to the Second Line and Senior Management.
  7. Promote a healthy risk culture and good conduct.
Second Line The control functions independent of the First Line that provide oversight and challenge of risk management.
  1. Review First Line proposals and make decisions to approve or reject as appropriate.
  2. Oversee and challenge First Line risk taking activities.
  3. Own processes for setting Policies and Standards and monitoring compliance to the same.
  4. Own and manage processes for oversight and challenge.
  5. Intervene to curtail business if activities are not in line with RA, there is material non-compliance with policy requirements, or when operational controls do not effectively manage risk.
  6. Identify, assess, monitor and escalate risks and events to the ERC and to the Board.
  7. Review and challenge risk remediation plans set by the First Line to mitigate RA breaches or events.
  8. Ensure there are appropriate controls to comply with applicable laws and regulations. Escalate significant regulatory non-compliance matters and developments to ERC, Board and Management Team.
  9. Promote a healthy risk culture and good conduct.
Third Line The internal audit function provides independent assurance on the effectiveness of controls that support First Line’s risk management of business activities, and the processes maintained by the Second Line.
  1. Independently assess whether management has identified the key risks in the business and whether these are reported and governed in line with the established risk management processes.
  2. Independently assess the adequacy of the design of controls and their operating effectiveness.

4.REPORTING AND BREACH HANDLING PROCESS

4.1 For escalation-level breaches, the business (First Line) is to inform the ERM function and the respective Risk Framework Owner (“RFO”) to agree on treatment plans. The escalation-level breach together with the treatment plans must be tabled at the ERC for tracking until completion of the treatment plans and the RA Metric is no longer in breach.

4.2 For RA breaches, the business (First Line) is to inform the ERM function and respective RFO as soon as possible. This will be considered as a Material Event and requires further escalations in accordance.

4.3 Treatment plans for a RA breach are to be formulated within 72 hours of breach discovery. The treatment plans must be endorsed by the RFO and SCV RFO and approved by the Board. Treatment plans must be presented to the next ERC and the Board and must be tracked by these governance bodies until closure.

5.RISK PROFILE

TASConnect’s risk profile provides a complete and forward-looking profile of the elevated inherent risks that TASConnect is exposed to. It contains the following elements:

  1. A Process Universe that outlines the key operational elements and processes to deliver the client experience for the service/product offered by TASConnect.
  2. Inherent risk assessment conducted by the First Line (Process Owners) to identify and assess the inherent risks at each stage of the Process Universe. The Second Line (RFO/SME) approves the said risk assessment performed by the First Line.
  3. Controls are designed and installed to mitigate the inherent risks. First Line monitors the effectiveness of the controls through Key Control Indicators (“KCIs”) and/or Control Sample Tests (“CSTs”) to provide early warning of potential problems. This approach is an ongoing exercise to reflect on the latest risk exposure of TASConnect.
  4. Residual risks are assessed by the First Line (Process Owner) taking into account the design and operating effectiveness of controls implemented. The Second Line (RFO/SME) approves the residual risk assessment performed by the First Line (Process Owners).

6.RISK GOVERNANCE AND OVERSIGHT

This ERM framework is a unifying framework that is consistent with, and supported by, the Company’s values of integrity, team, service excellence, and winning. This ERM philosophy directs all of the TASConnect’s ERM activities and enables management to clearly understand the tradeoffs between risk and return in decision making.

Risk will be measured, either qualitatively or quantitatively, relative to specific performance measures associated with the objectives, whether financial, operational or otherwise, to be actionable. By using the same, or a congruent, unit of measure established for their objectives, the results are more meaningful to management and reduce the need for the development of separate measures. In doing so, ERM becomes embedded into management processes.

Effective ERM requires appropriate and timely information that supports management decisions.

6.1 First and Second Line staff to undertake regular horizon scanning to identify and monitor the impact of emerging risks to learn lessons from events that have produced adverse outcomes, and to raise awareness of known risks.

6.2 Risk management reports will contain risk information that allows TASConnect to appropriately identify, monitor and report on material risks.

6.3 Management must promptly escalate the following Material Events:

      1. any breaches,
      2. any events or issues,
      3. any residual risks, and
      4. any other issue.

 

©TASConnect

CODE OF CONDUCT

1.THE COMMITMENT TO HONEST AND ETHICAL CONDUCT

Why the Code matters

The Code is important because it outlines how TASConnect makes sure that the decisions TASConnect makes are the right ones.

Act responsibly and within the authority

TASConnect must be disciplined, responsible and take accountability for the risks the Company takes. When taking risks, they must be within the delegated authority and must be appropriate to the business area or activity. TASConnect’s policies are in place to help understand what limits and safeguards are in place.

Use good judgment

TASConnect recognise that employees may face complex situations which don’t have simple, clear-cut solutions. Use the Code’s decision-making framework to help make decisions well, appropriately and with care.

2.WORKPLACE CONDUCT

As an organisation, managing risk is a central part of TASConnect’s daily activities. TASConnect creates value for clients and produce long-term returns for shareholders by taking and managing risks in line with TASConnect’s strategy and within TASConnect’s risk appetite. Risk management is the set of end-to-end activities through which the Company makes risk-taking decisions and control and optimise the risk-return profile of TASConnect. It is a vital part of all activities across the Company, starting from the front line. Because of this, all TASConnect employees must make sure they manage risks effectively as part of their organisational responsibilities.

So, it is important that every aspect of TASConnect’s business is carried out within a framework of the delegated authority. Delegated authority is designed to protect employees as well as the Company. Understanding which limits and policies apply to the employees and to not take more risks than appropriate individuals’ role or seniority.

Employees must:

  • Understand the limits and policies that applies, and keep to them
  • Make sure they have appropriate authority before committing TASConnect to any transaction or contractual commitment
  • Be disciplined and take responsibility and accountability for the risks taken, making sure they are appropriate to the business or activity
  • Make sure that decisions made do not create reputational risk
  • Exercise strong financial control by acting within one’s financial authority and ensuring accurate record keeping
  • Use care, skill and diligence when carrying out any responsibilities or delegating to others

Use good judgement

Good judgment is used when facing situations which are challenging and unfamiliar, while staying within the delegated authority.

One should feel comfortable that they can support the decisions or action they take in light of the difficult situations faced. Being methodical and informed when considering solutions will help to deliver a positive outcome. Acting hastily, without involving manager in line and any other relevant colleagues, exposes one to poor decision-making and negative consequences.

Comply with laws, regulations and standards

It is vital that TASConnect complies with relevant laws, regulations and the Company standards in everything the Company does. Making sure that the Company operates within these laws, regulations and standards is the personal responsibility of every employee.

Always:

  • Act ethically, honestly, professionally and with integrity at all times
  • Comply with all relevant legal and regulatory requirements. Make sure all TASConnect employees know and understand them, and act in a way which follows their instructions and the spirit in which these rules are intended. Failing to do so, the consequences can be severe, including damage to the TASConnect brand, loss of clients, loss of confidence from the regulators and the public, suspension or withdrawal of the licences (if applicable) TASConnect holds and fines or other penalties
  • Comply with TASConnect’s standards unless local laws or regulations are either stricter than, or do not allow TASConnect’s standards – in which case local laws or regulations apply
  • Some countries have requirements for people, organisations or particular activities to be licensed, registered, or certified. These are regulatory requirements, and TASConnect must comply with them. It is TASConnect’s responsibility to make sure that the Company have the relevant licences, registrations and certificates that the employees need
  • Understand the legal and regulatory requirements involved in cross-border activities and keep to these requirements

Treat colleagues fairly and with respect

At TASConnect, the Company believes it is important that everyone can work in a fair, safe, inclusive and enjoyable place that encourages creativity, collaboration and continuous

improvement. These things are essential to TASConnect’s core valued behaviours.

Trust and fairness are also a central part of TASConnect’s approach to managing and developing people. By building on the strengths and abilities, the Company can help the employees to achieve their full potential. And if TASConnect is better as a team, the Company will be able to better serve all clients.

TASConnect expect all employees to treat colleagues fairly and with respect as all employees are entitled to a safe working environment that is free from discrimination, exploitation, bullying, harassment or inappropriate language.

Particular areas to take account of are shown below:

  • TASConnect values diversity and work together as a team. The Company is committed to providing equal opportunities and fair treatment in employment. TASConnect do not accept unlawful discrimination in the Company’s recruitment and employment on the grounds of race; colour; nationality; national or ethnic origins; gender; parental status; marital or civil partner status; sexual orientation; gender identity, expression or reassignment; HIV or AIDS status; employment status; flexibility of working arrangements; disability; age; religion; or belief.
  • TASConnect appoints, trains, develops, rewards and promotes based on merit and ability
  • TASConnect may take action to deal with disadvantage or under-representation among specific groups, with the aim of making sure the employment decisions are free from bias
  • TASConnect do not tolerate any exploitation or any bullying, harassment, discrimination against, or victimisation of any colleagues, clients, or visitors – whether spoken, written, physical or psychological.
  • TASConnect all have a duty to treat the people the Company come into contact with through work with dignity and respect
  • When using the Company’s tools and systems such as Outlook, Sharepoint or etc, TASConnect must make sure that the communications are appropriate. Employees should never use these in a way that breaches any of TASConnect’s policies, including those relating to communications and equal opportunities. All employees should not post or pass on any content that would affect any person’s rights or break the law and all communications are factual and do not contain offensive or abusive language

TASConnect is committed to dealing with any issues that are brought to the Company’s attention. TASConnect will thoroughly investigate complaints of harassment, exploitation, discrimination or victimisation and may take formal disciplinary action where misconduct has taken place.

Be open and honest with regulators – give them your full co-operation

To serve TASConnect’s clients and continue to operate, the Company must maintain strong and effective relationships with regulators and governments to keep the business licences and gain new ones. If TASConnect fails to meet any commitments, regulators may lose confidence in the Company and take action against the Company. This action could include substantial financial penalties and removing the business licences, which will damage TASConnect’s brand, reputation and ability to serve the clients.

3.SECURITY OVER INFORMATION AND ASSETS

As part of delivering or supporting the financial services, TASConnect may receive confidential information which may be about organisations, markets and the Company, as well as personal data of clients, colleagues, and other individuals. It is critical that how TASConnect use confidential information, including personal data, instils trust and confidence, not only in those directly affected, but in the broader community in which the Company operates. TASConnect is committed to handling confidential information, including personal data, respectfully and appropriately in line with TASConnect’s responsibilities in terms of bank secrecy and confidentiality, as well as privacy law.

All information and personal data gathered and dealings with TASConnect is confidential unless clearly said to be otherwise. TASConnect will only share confidential information on the Company’s internal platforms with those allowed to receive it. Confidential information, including personal data, must only be used to carry out work, in line with all laws, regulations, contracts and policies and procedures which apply, including relating to information security and information walls.

All employees must use skill, care and diligence in securing and handling confidential information, including personal data. This includes:

  • Not accessing any confidential information, including personal data, unless authorised to do so in line with their role
  • Accessing, storing and getting rid of confidential information
  • Protecting and handling confidential information including personal data to meet privacy requirements
  • Transferring it securely to others or within the Company
  • Not viewing it in public
  • Respecting information walls that may apply to it
  • Not using or disclosing confidential information, including personal data, on any social networking sites
  • Being vigilant for any signs of threats, including social engineering practices

TASConnect may also collect personal data for specified and legitimate work purposes only, and the Company respects individuals’ rights and regulatory requirements when handling it.

More generally, communications made about TASConnect must be accurate and reflect the Company’s views. Employees must not release confidential information or personal data or make representations about TASConnect to the media or on any public forum, including social media, without express authorisation. Only authorised staff may make comments to the media subject to clearance from Branding & Marketing, Legal, Risk and Compliance.

4.BUSINESS CONDUCT

Ensure fair outcomes for clients

TASConnect must always do the very best to deliver fair outcomes for clients. Clients are at the heart of everything that TASConnect does, and TASConnect is committed to providing clear and honest advice to them, and to making sure that the products offered are right for them. As well as being the right thing to do, providing fair outcomes for clients helps TASConnect to build and foster long-term relationships with them. This helps to improve the Company’s reputation and attract new business.

When dealing with all clients, the following minimum standards must be kept:

  • Make sure that products and services are designed with the clients’ needs in mind, including fair and reasonable pricing which has been clearly disclosed
  • Make sure all communications with clients are fair and not misleading
  • Make sure approval for new products and services (including features, strategic-partnership or significant variation to the existing products) have been obtained from internal key stakeholders (such as Legal, Risk and Compliance, Finance, Tax, etc, prior to launching
  • Give clients clear and concise information before they enter into products and services, so they understand the risks. This must be done for all clients, regardless of how experienced they might be or their usual risk tolerances
  • Follow applicable sales processes. Only market and sell the products and services which have been approved for sale
  • Make sure that products and services are appropriate and suitable, meet clients’ needs, and take into account their financial situation, objectives, risk tolerance and risk profile. Even if TASConnect may know the client well, but must never guess likely decisions on their behalf
  • Handle complaints in a friendly, fast, fair and effective way. Keep to all procedures for handling complaints and use client feedback to identify the root causes of issues. If TASConnect has all the facts and can identify a root cause, the Company will be able to improve the products and services and create better outcomes for clients

Compete fairly in the market place

TASConnect is committed to competing fairly. The risk relating to competition law is increasing including where the Company operates, as well as changing regulations. Most states and countries worldwide have developed competition-law regimes and all employees must comply with competition law at all times and in all countries where TASConnect operates. TASConnect is also responsible for complying with the Competition / Anti-Trust Policy.

Breaching competition law is extremely serious. Most competition authorities across the world can impose substantial fines for competition law (or antitrust) breaches, which can be up to 10% of TASConnect’s yearly turnover. And, competition investigations are extensive, disruptive to the business and ability to focus on the clients, and may result in criminal sanctions and imprisonment for the people involved.

Manage conflicts of interest

Managing conflicts of interest effectively allows TASConnect to act fairly, avoid legal and regulatory risks, and protect the Company’s brand, reputation, and own personal integrity.

Conflicts of interest fall into two broad categories – business and personal. When any actual or potential conflicts of interest is identified, TASConnect must act immediately to deal with them openly, honestly and effectively.

Business conflicts of interest can arise in the following situations:

  • Between TASConnect and the clients, suppliers or other third parties including general users of the markets in which TASConnect operates
  • Between clients and other third parties
  • Between different businesses within TASConnect

Personal conflicts of interest may arise when employees put personal interests ahead of those of a client, supplier, other third party or TASConnect. This would include instances where one have an interest or association (eg. an outside business interest) that may interfere with the Company’s interests or the interests of the clients. They may also arise where one have close personal relationships or close financial relationships with other colleagues.

  • Always act with independence and with integrity in all of the dealings
  • Think carefully and anticipate and properly identify all possible conflicts of interest
  • When changing the structure or make-up of any business activities, consider how these changes may create new conflict situations or change conflicts that have already been identified
  • Report any actual or possible conflict identified, immediately to the relevant Senior Management and Risk and Compliance
  • Conflicts of interest should be escalated, recorded and managed in a clear and effective manner in accordance with relevant policies and procedures
  • Make sure any conflict is dealt with in a clear, open and effective way
  • Get approval before one take part in outside business interests and close personal or financial relationships
  • Be familiar with the Conflicts of Interest Policy and comply with the conditions in them

Reject bribery and corruption

There is no room in this organisation for acts of bribery or corruption. Bribery and corruption are illegal, dishonest, and extremely damaging to the countries and communities where they take place. TASConnect must actively reject bribery and corruption in all its forms. When someone gives a benefit to someone else in order to influence that person’s behaviour, that is a bribe. When someone takes improper advantage of their position to make a gain for themselves, they are acting corruptly.

TASConnect must not give or accept bribes or take part in, or enable, any forms of corruption. It’s vital for employees to stay vigilant because the risk of bribery can arise in any of the operations, at any time where the Company is dealing with a third party. Bribery and corruption can take many forms – through procurement decisions, expenses, gifts and entertainment, hiring decisions, sponsorships, donations, the actions of the customers and so on.

TASConnect must take the time to consider how the day-to-day business activities might encounter or create the risk of bribery and corruption. This will help TASConnect to be better positioned to identify possible bribery and corruption. TASConnect must make sure that the transactions and activities the Company takes part in are not, and cannot be perceived as, an improper inducement for business.

Some important points to highlight:

  • Take particular care if the work involves interactions with Public Officials – including anyone working for government departments, regulators and state-owned enterprises. The rules in this area are more complicated, and the risk can be higher. If this applies to employee’s role, contact Risk and Compliance for more guidance
  • TASConnect can be held legally responsible for the actions of intermediaries and third parties who act on behalf the Company anywhere in the world. When dealing with third parties, TASConnect must make sure that the bribery and corruption risk has been assessed and controlled. This is why TASConnect has robust procurement policies in place
  • Some practices that may be considered normal where the work may actually be illegal under the UK Bribery Act or US Foreign Corrupt Practices Act, or create the perception of bribery or corruption somewhere else. As a result, this can have a negative effect on TASConnect. Employees must take this into account when deciding on the right thing to do, and get advice if necessary
  • If it genuinely feels that personal safety might be at risk when not taking part in bribery or a corrupt arrangement, report it to Risk and Compliance. This should also report the incident to the relevant authorities, where appropriate
  • Get to know the clients. If there is a meaningful and deep relationship with the clients, employees will be better placed to identify and detect potentially inappropriate behaviour
  • TASConnect’s policies explains the rules around giving and receiving gifts and entertainment to make sure they are allowed, properly approved, and recorded. These rules will help to protect the employees and employees are to be familiar with them

The guidance set out in TASConnect’s Anti-Bribery Policy and Procedures must be followed, and other policies which may govern bribery and corruption risk for specific activities. When making decisions to deal with any bribery and corruption risk, TASConnect must make sure these are properly and honestly documented.

Fight financial crime

Financial crime has an enormous global impact. When it is allowed to take place, it negatively affects society at all levels – from ruining the lives of people to threatening the global economy. Financial crime allows drug and human trafficking to take place, supports the smuggling and counterfeiting of goods, underpins illegal gambling and financing terrorist activity and tax evasion, among other criminal acts. TASConnect has a duty to protect the communities that the Company serves from the damaging effects of financial crime.

TASConnect is committed to preventing the laundered proceeds of crime (including those from tax evasion) and financing terrorism from being a part of the overall economy and financial system. TASConnect is committed to preventing the Company, the staff (and other associated people) from the criminal facilitation of tax evasion by the clients. Bribery and corruption cannot be tolerated. TASConnect is also committed to keeping to all legally binding sanctions, including measures against people and organisations and measures against specific countries (or nationals or residents of those countries).

TASConnect must play a strong and effective role in the fight against financial crime. The Company owes this to the customers as well as to the global financial system in which TASConnect operates.

TASConnect must cooperate fully with governments, regulators and other financial services providers to protect client accounts from fraud and to help tackle organised financial crime. TASConnect also must act with skill, care and diligence in the ongoing development of financial crime compliance programmes. All of the employees must apply TASConnect’s standards on financial crime compliance as well as any local anti-money laundering laws and regulations.

Some measures taken:

  • Thoroughly check the identity of the clients from reliable evidence as part of the Customer / Client Due Diligence (“CDD”) procedures, and get to know clients so as to recognise transactions which are inconsistent with their business or do not match the normal pattern of activity for which the account was set up
  • Report suspicious activity immediately (if it is about or suspected to be money laundering, Risk and Compliance must be contacted)
  • Understand and follow the sanctions restrictions
  • Report any suspicion of fraud immediately to line manager and contact Risk and Compliance
  • Employees to not get in the way of any reporting or investigation of any suspected financial crime
  • Complete financial crime compliance training
  • At all times, all employees to follow TASConnect’s anti-money laundering / counter terrorist financing, sanctions, anti-bribery and corruption policies and procedures

Do not engage in or support insider dealing

Insider dealing1 is a criminal offence in most states and countries and may lead to fines or prison if convicted. Insider dealing creates an unfair advantage and undermines the financial system. The nature of TASConnect’s work at times and/or potentially means that the Company is trusted to handle inside information in an appropriate way (if applicable). And TASConnect is all responsible for living the valued behaviours and demonstrating the Company’s commitment to being trustworthy.

Insider dealing includes dealing on own account or encouraging someone else to deal, based on the inside information held. Insider dealing may also take place if one reveals the information to anyone else, other than in the proper performance of work.

The Conflict of Interest standards and any other specific business procedures governing related personal account dealing activities (if any) must be abided by. This applies to transactions carried out by one’s own account or if one has influence over the investment decisions on the accounts of others (if applicable). TASConnect may treat this as a serious disciplinary matter when in breach of the Conflict of Interest rules.

Do not deal or cause someone else to deal:

  • When in possession of any inside information

If employees have, or have access to, inside information or possible inside information:

  • Escalate this in line with Conflicts and Information Walls standards and/ or the management of Inside Information standards (if applicable); and
  • Make sure that inside information is not shared with or revealed to any other people, other than in the proper performance of work

As a designated employee (if applicable), any potential dealing account intention must be informed or disclosed to Risk and Compliance.

5.SOCIAL RESPONSIBILITY

Respect the communities and the environment

TASConnect has the ability and responsibility to make positive change in the communities. TASConnect wants to make sure that the product and services that are provided supports sustainable economic and social development in the communities in which the Company operates.

The upcoming position statements and internal Environmental, Social and Governance risk management (ESG) framework will guide the business activities. They set out the environmental and social standards TASConnect expects of the clients, and the positive behaviours the Company encourages.

TASConnect has a duty to respect the human rights of others who may be affected by they Company’s actions and decisions, whether in the sourcing decisions, through providing products and services, or in how the employees work with each other including supporting the communities.

TASConnect is also establishing targets to manage the Company’s energy, paper and water usage. The Company’s commitment to meeting these targets means TASConnect is managing the resources responsibly.

TASConnect is also strictly non-political and do not get involved in political activities, support political parties or have any political links.

What TASConnect can do:

  • Identify opportunities to make a positive contribution to the communities and the environment
  • Making sure that providing products and services matches the ESG risk management framework
  • Being aware of how the day-to-day decisions made might affect the human rights of others, and acting within the policies to avoid negative outcomes (Reputational Risk)
  • Keeping to the policies on political activities, including the Sponsorship and Donations Policy

6.REPORTING CONCERNS

Speaking Up

TASConnect must maintain a culture of strong ethics, integrity, transparency, and openness. By Speaking Up employees help the Company to identify issues and deal with them.

Misconduct is damaging for everyone. It exposes TASConnect to significant risks and can damage the Company’s financial performance, reputation, and the trust of everyone who has an interest in the business.

The Company and employees all have an important role to play in protecting TASConnect ‘s reputation and the industry at large.

There may be a time when something at work that does not feel right. Speaking Up is a safe, confidential way to let the Company know of it. Some examples of when one should speak up:

  • Failing to comply with laws or legal obligations, including committing fraud or other criminal acts
  • Putting the health and safety of a person in danger
  • Damaging the environment
  • Breaching rules or regulatory requirements
  • Failing to comply with codes of conduct, business or country policies and procedures
  • Doing anything which has or is likely to have a negative effect on TASConnect’s reputation or financial well-being
  • Confidential information, including personal data, is lost or stolen
  • Deliberately concealing any of the above

It is enough to have a reasonable belief that any of the above situations has taken place, is taking place, or could take place. However, when Speaking Up, one must do so honestly and in good faith. Knowingly reporting untrue information is not acceptable.

There are a number of ways to raise a concern:

  • Speak to someone in one’s management chain or outside of one’s management chain, for example (a member of the Senior Management or Risk and Compliance)
  • Use the designated Speaking Up channel: email to Speakup [speakup@tasconnect.com]

 


1 Inside information is information of a precise nature, which has not been made public, relating directly or indirectly to issuers or financial instruments, which, if it were made public, would likely have a significant effect (either positive or negative) on the price of those financial instruments or the price of related derivative financial instruments to which it relates. Inside information can be information about the Company or information given about others.

 

©TASConnect