Supplier Code of Conduct
Updated as of 2 November 2026
Raffles Medical Group Ltd and its subsidiaries (collectively, “RMG") is committed to conducting our businesses and operations with the highest standards of ethics and integrity. We aim to collaborate with our suppliers to create and maintain a sustainable supply chain.
Our Supplier Code of Conduct (“Code”) stipulates the minimum standards of conduct which RMG expects from all its suppliers providing goods and/or services to RMG and compliance with the Code is a condition to contract. It also applies to all employees, group entities, subcontractors and others who act on suppliers’ behalf (collectively “Third Parties”).
It is the responsibility of suppliers to ensure all Third Parties comply with this Code.
This Code does not represent a complete set of the suppliers’ obligations and requirements in supplying goods and services to RMG and the contents herein do not prejudice any other contractual terms that may be agreed between RMG and its suppliers. All suppliers are to be aware of the obligations and requirements under their specific contractual documents such as agreements for goods and/or services, purchase orders, letters of acceptance and tender documents for any additional obligation and requirement. In confirming their acceptance of the terms and conditions stated in the contractual documents, suppliers confirm that their operations fulfil the requirements stated in this Code, which shall be deemed incorporated into any relevant contract with RMG. Where there are any perceived discrepancies between the requirements of this Code, contractual terms and prevailing laws and regulations, suppliers are expected to meet the strictest standard that may be applicable.
RMG will review this Code from time to time and reserves the right to amend this Code at its sole and absolute discretion. Changes will be communicated to suppliers for their compliance.
Suppliers will cooperate with RMG by providing any information, documents, certifications, policies, records and evidence pursuant to requests, audits, due diligence reviews, regulatory inquiries or assurance processes that RMG may initiate to confirm their fulfillment of the requirements stated in this Code. In the event of any supplier’s failure to comply with this Code, RMG shall be entitled to exercise its sole and absolute discretion to suspend, require remediation of, or terminate any contract or agreement with the supplier.
- Laws and Regulations
Suppliers undertake to comply with all applicable laws, regulations, codes, licences, guidelines and regulatory directions in the countries where their respective businesses and operations are carried out and where the goods and services are delivered. For goods and services supplied in or to Singapore, this includes, where applicable, the Personal Data Protection Act 2012, Healthcare Services Act 2020 and its subsidiary legislation, Health Products Act and Health Products (Medical Devices) Regulations 2010, Cybersecurity Act 2018, Prevention of Corruption Act 1960, Workplace Safety and Health Act 2006, Environmental Protection and Management Act 1999, Insurance Act 1966 and its subsidiary legislation and related regulations, SGX Listing Rules and applicable sustainability reporting, climate-related disclosure and assurance requirements, together with any applicable requirements, codes, licences, guidelines, directions or notices issued by the Ministry of Health, Health Sciences Authority, Personal Data Protection Commission, Cyber Security Agency of Singapore, National Environment Agency, Monetary Authority of Singapore, Singapore Exchange Regulation and other competent authorities.
- Business Ethics
RMG expects suppliers to uphold the highest ethical standards and abide by the following:
- a. Business integrity
Suppliers shall not engage in any illegal or unethical behaviour. Any form of improper behaviour, including but not limited to bribery, corruption, fraud, extortion, cheating, money laundering and terrorist financing, is prohibited. Suppliers shall comply with all applicable anti-money laundering and counter-terrorist financing laws, regulations, notices, guidelines and sanctions requirements, and shall maintain appropriate policies, controls, due diligence, record-keeping, monitoring and reporting procedures.
- b. Fair competition
Suppliers shall conduct their business fairly and in compliance with all applicable anti-trust/competition laws.
- c. Data protection and intellectual property
Suppliers shall protect personal data, confidential information, patient information, medical records and health information that they obtain, access, host, process or transmit in the course of their business dealings with RMG against unauthorized or unlawful use, disclosure, access, modification, loss, alteration, damage and destruction. Suppliers shall implement reasonable security arrangements and safeguards appropriate to the sensitivity of the information, including access controls, encryption or equivalent protection where appropriate, secure disposal, staff training, audit logs, incident response procedures and controls over subcontractors and cloud or technology service providers, and shall comply with all applicable personal data, health information, cybersecurity and privacy laws.
Suppliers shall conduct business in a manner which respects intellectual property rights of RMG and other parties and shall protect such rights to the extent required by law or contractual obligations.
In the event of any actual or suspected data breach, cybersecurity incident, unauthorized access, loss of personal data, compromise of health information or incident that may affect the confidentiality, integrity, availability, safety or continuity of RMG’s systems, services, patients or operations, suppliers shall notify RMG without undue delay and in any event within 24 hours of becoming aware of the incident, to enable RMG to assess and comply with any applicable statutory or regulatory notification obligations. The notification shall include, to the extent known, the nature and extent of the incident, affected systems and data, affected individuals, containment and remediation actions taken or proposed, regulatory notifications made or contemplated, and any support required from RMG.
Suppliers shall not use, disclose, transfer, store or process RMG’s personal data, patient information, medical records, health information or confidential information for any purpose other than the authorized purpose agreed with RMG. Suppliers shall obtain RMG’s prior written approval before engaging any subcontractor or transferring such information outside Singapore and shall ensure that any approved subcontractor is bound by obligations no less protective than those in this Code and the applicable contract.
- d. Conflict of interest
Suppliers shall immediately disclose any actual, perceived or potential conflict of interest in any of their business dealings with RMG.
- Labour and Human Rights
Suppliers shall respect and uphold the human rights of all employees and treat them with dignity and respect.
Suppliers are required to maintain a fair and equitable work environment that is free from any form of discrimination, intimidation and harassment. Other than abiding by the statutory requirements governing employment, suppliers shall ensure that employment practices do not discriminate upon grounds of age, gender, race, religion or any other characteristic protected by applicable law.
Suppliers shall ensure that their operations do not leverage on any form of illegal child labour, modern slavery, such as human trafficking or forced labour, and shall take reasonable steps to avoid contributing to any adverse human rights impacts.
Suppliers shall take reasonable steps to identify and manage labour, human rights and ethical risks within their own operations and supply chains, including risks relating to forced labour, migrant worker welfare, recruitment fees, excessive working hours, unsafe working conditions and retaliation against workers who raise concerns in good faith.
- Health, Safety and Quality
Suppliers shall comply with all applicable occupational health and safety laws and regulations. They are to implement effective health and safety policies and procedures to provide workers with a healthy and safe work environment. They shall identify, evaluate and control worker exposure to safety and health hazards, including chemical, biological, physical and ergonomic stressors.
Suppliers shall supply products and services that meet the specifications and needs of RMG, and that are in line with recognized and contractually agreed safety and quality requirements and comply with the local laws in the country in which they are provided to RMG. This includes ensuring that quality assurance processes are in place and all required approvals, licenses, certifications and registrations are obtained, properly maintained and kept up to date.
Where suppliers provide, support or affect licensable healthcare services, or provide medical devices, health products, drugs, equipment, software, digital health products, clinical systems or services used in patient care or healthcare operations, suppliers shall ensure that all applicable healthcare service licensing requirements, product registrations, dealer’s licenses, import, manufacture, supply, advertising, post-market surveillance, adverse event reporting, field safety corrective action and recall obligations are obtained, maintained and complied with, unless exempted or otherwise permitted by the relevant authority. Suppliers shall promptly notify RMG of any quality issue, safety concern, adverse event, product defect, recall, field safety corrective action, regulatory restriction or enforcement action that may affect goods or services supplied to RMG.
Where suppliers operate, support or provide services relating to designated critical information infrastructure, regulated cybersecurity services or systems that are material to RMG’s healthcare operations, suppliers shall comply with all applicable cybersecurity laws, licensing requirements, standards, directions and incident reporting obligations, and shall maintain appropriate technical, organizational and operational safeguards proportionate to the risks involved.
- Environment
Suppliers shall operate in a responsible and sustainable manner by minimizing adverse impact on the environment, reducing pollution and waste, conserving energy and water, managing hazardous substances safely and ensuring compliance with all applicable environmental laws and regulations. Suppliers are encouraged to adopt environmentally responsible practices across their operations and supply chains, including reducing waste, reusing products, recycling resources, avoiding hazardous materials where possible, and using packaging and logistics solutions that reduce environmental impact without compromising patient safety, product quality, infection control or regulatory requirements.
Suppliers are required to support RMG’s sustainability requirements and initiatives, including requests for accurate, complete and timely information relating to greenhouse gas emissions, energy and water consumption, waste generation and disposal, packaging, logistics, sustainable procurement, climate-related risks and other environmental, social and governance matters reasonably required for RMG’s SGX sustainability reporting, climate-related disclosures, assurance, regulatory filings, customer commitments or internal governance. Where suppliers are subject to emissions reporting, carbon tax or other environmental reporting obligations, suppliers shall maintain reasonable records to substantiate such information and shall not provide false, misleading or unsubstantiated sustainability claims.
Suppliers shall use reasonable efforts to identify, assess and manage climate-related, environmental and supply chain risks that may affect continuity of supply, patient care, product quality, infection control, regulatory compliance or RMG’s operations. Suppliers shall promptly inform RMG of any material disruption, environmental incident, regulatory non-compliance or sustainability-related matter that may affect their ability to supply goods or services to RMG.
- Supplier Diversity
RMG advocates supplier diversity to provide opportunities to all categories of suppliers. Likewise, RMG’s suppliers are expected to practice inclusive sourcing that promotes diversity and inclusion in the supply chain.
- Reporting and Inquiries
Suppliers shall put in place appropriate governance processes, policies, controls, training and resources to communicate the standards imposed herein to their employees and other Third Parties, to ensure compliance with the requirements of this Code and to effectively manage legal, regulatory, quality, safety, data protection, cybersecurity, sustainability and supply chain risks.
Suppliers and their employees shall, in good faith and in timely manner, report any possible violation or breach of this Code. Such report can be made via the following channels:
Email: secretariat@rafflesmedical.com
Address: Raffles Medical Group, 585 North Bridge Road, #11-00, Singapore 188770
While reports may be made anonymously, parties making the reports are encouraged to state their identity and/or contact particulars to facilitate investigations. All reports will be treated with impartiality, fairness and confidentiality, with importance placed on protecting the party making the report from retaliation or other detriment. Suppliers shall fully cooperate with and not obstruct any review or investigation carried out by RMG in relation to such report. Any report made in good faith, even if subsequently shown to be unsubstantiated following investigations, will not lead to any repercussions. However, appropriate action may be taken against parties who make reports containing malicious allegations (e.g. made for personal gain or with the knowledge that they are false).