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GXS' Whistleblowing Policy provides a platform for individuals to disclose any improper conduct in good faith that involve GXS staff members and/ or business partners, without fear of any repercussion.

All instances of whistleblowing will be independently reviewed and investigated by an investigative team led by Internal Audit. Results of the investigation will also be reported to the Audit Committee.

The whistleblower’s identity and information disclosed by the whistleblower will be kept confidential and disclosed on a need-to-know basis.

Improprieties for disclosure

The following are examples of improper and reportable conduct:

  • Improper accounting practices;
  • Theft, fraud, embezzlement or dishonesty;
  • Bribes and kickbacks;
  • Breach of GXS's Policies and Code of Conduct;
  • Failure to comply with applicable laws and regulations;
  • Actions that unnecessarily endangers the health and safety of other persons, or the environment;
  • Unlawful conduct such as sexual harassment, violence or threatened violence, illegal drug or alcohol use and money laundering.
Information to disclose

Please provide the following information for disclosure in order to facilitate a thorough investigation:

  • Detailed description of the incident including date, time, nature of the incident and the actions/transactions during such incident;
  • The location of the incident;
  • The identity and particulars of the person(s) involved in the incident;
  • Your relationship with the person involved in the incident;
  • Any witness to the incident;
  • Any evidence or other information that may support or substantiate the incident (e.g. conversation transcripts, documents, photos, etc.);
  • If not a GXS employee, any connections to GXS

Whistleblowers are encouraged to provide their name, contact number and email address for further information and clarification to facilitate the investigation where possible. Alternatively, whistleblowers may remain anonymous.

Report improper activities

Your concern matters to us and we take whistleblowing seriously. You may make a whistleblowing report to any of the following dedicated channels:

1. Email to; or

2. Send mail addressing to any of the following parties:

  • Head of Internal Audit;
  • Audit Committee Chairman*;
  • Board Chairman*.

*directed through the Head of Internal Audit for the attention of the Audit Committee Chairman or Board Chairman.

                  GXS Bank Pte Ltd
                  3 Media Close #09-03
                  Grab HQ
                  Singapore 148498
                  Attention: Head Internal Audit


GXS is committed to the protection of the whistleblower’s identity, anonymity and confidentiality of the matter reported to the fullest extent possible at all times.  Whistleblowing Reports received will be investigated, kept confidential and disclosed only on a need-to-know basis.

Protection Against Retaliation

GXS is committed to the protection of whistleblowers who acted in good faith from any retaliation against whistleblowers for making a whistleblowing report. GXS takes any form of retaliation against a whistleblower seriously and will take appropriate action against any such person who engages in any retaliatory conduct against a whistleblower.