 Table of Contents
A. Introduction This Employee Handbook (“Handbook”) applies to all employees of Citadel and to employees of any other member of the Citadel Group while working in Singapore. The references in this Handbook to "Citadel” are to your employer being Citadel Enterprise (Singapore) Services Pte. Limited or Citadel Securities (Singapore) Services Pte. Limited, and/or any Citadel Group entity in Singapore which you are seconded to.
This Handbook is divided into three sections: Sections A, B and C. Section A is the introduction to the Handbook, Section B contains details of your employment with Citadel which are contractually binding on you, whilst Section C contains policies which do not form part of your contract of employment.
The contractual terms and conditions of employment described in Section B are in addition to those included in your offer letter or secondment letter (if you have been seconded to any Citadel Group entity in Singapore) and your Employment Terms. This Handbook shall be governed by and construed in all respects in accordance with the laws of Singapore and, subject to contract between the parties, the parties irrevocably submit to the jurisdiction of the Singapore Courts.
If you are seconded to any Citadel Group entity in Singapore from any member of the Citadel Group (see definition below), your contractual terms of employment will continue to be governed by your offer letter and/or contract of employment together with any applicable international assignment letter or secondment agreement. Sections B and C of this Handbook, with the exception of Sections B.12, C.2, C.3, C.4, C.5 and C.6, will apply to you.
In this Handbook, “Citadel Group” means Citadel, its subsidiaries, its holding company and each of their respective subsidiaries (all as defined in the Singapore Companies Act (Cap.50)) and any affiliate of one or more of the foregoing entities (“affiliate” means any other corporation, trust, association, unincorporated organisation, limited liability company, joint venture, partnership or other entity that either directly or indirectly (including through one or more intermediaries) controls, is controlled by or is under common control with such company). For the purpose of this definition, “control” (including, with correlative meanings, the terms “controlling”, “controlled by” and “under common control with”), as applied to any person, means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of that person, whether through the ownership of voting securities or by contract or otherwise.
In this Handbook, "Chief Operating Officer" shall mean the Chief Operating Officer of Citadel Asia Limited, Citadel Enterprise Asia Limited, Citadel Securities Hong Kong Services Limited, Citadel Securities Asia Holdings Limited or Citadel Securities Japan Limited.
A.1 Welcome to Citadel
The key to Citadel and its affiliates’ success is the people who make up our organization. We take pride in our cohesive and cooperative work environment; an environment that produces superior results because of the efforts of the people involved. We hope you will find your experience here to be exciting and rewarding.
A.2 General
Citadel is concerned that all employees should fully understand the terms on which they are employed. If you have any queries on this Handbook or any other documentation issued to you, you should raise them immediately with a member of the Human Resources Department or Legal and Compliance.
Citadel reserves the right to amend, vary, update, supplement and replace your terms and conditions of employment with Citadel, its policies, and this Handbook without obtaining consent from you.
This Handbook sets out the guiding principles of what is expected of each of you in your dealings with one another and with others who are stakeholders in our success, including our investors, regulators and the communities in which we exist. Each of us must commit to these principles and accept responsibility for our actions on a daily basis. We must know that we are empowered to do what is right, within the framework of these guidelines and in reliance of our sound judgement and common sense. If we do this, our work and our organisation—CITADEL—will continue to be something of which we can all be proud.
NOTE: This Handbook supersedes all previous employee handbooks, policies, practices and procedures of Citadel Group. In addition, this Handbook supplements Citadel’s compliance policies, manuals, procedures and bulletins, which are available on Citadel’s Legal and Compliance webpage.
B. Contract of Employment
This section of the Handbook, together with the following documents, comprises your contractual terms and conditions of employment (i.e. your contract of employment):
(i) Offer letter and/or secondment letter (as appropriate);
(ii) Employment Terms;
(iii) Non-Disclosure, Non-Compete, Supplemental Non-Compete (if any) and Non- Solicitation
Agreements; (iv) Dispute Resolution Procedures in place from time to time;
(v) Employee Incentive Plans in respect of which you have been invited to participate; and
(vi) Affirmations.
If there is any discrepancy between this section of the Handbook and your offer letter or secondment letter (as appropriate), your Employment Terms or the Non-Disclosure, Non- Compete (if any) or Non-Solicitation Agreements, the terms of your offer letter or secondment letter (as appropriate) and/or your Employment Terms and the Non- Disclosure, Non-Compete (if any) and Non-Solicitation Agreements will take precedence. Unless otherwise expressly stated in this section all consents and authorisations which you are required to obtain from Citadel shall be given by your Supervisor, the Chief Operating Officer, or such other person as they may specify or may nominate from time to time. As noted above, Citadel may, in its discretion, amend, vary, update, supplement or replace without your consent the terms and conditions contained in this Section B.
Your Appointment and Working Hours
B.1 Right to Work
Your employment with Citadel is conditional on you being legally entitled to work in Singapore at all times during your employment. If you require a work visa to work in Singapore, your employment with Citadel is and will continue to be conditional upon such a valid work visa being granted to you and remaining in force.
Your employment with Citadel will terminate automatically and without notice if you cease to be lawfully entitled to work in Singapore.
B.2 Restrictions
Your employment is conditional upon you not being subject to any limitation, obligation or agreement, whether imposed by contract, statute or otherwise, that would preclude your employment by Citadel or in any way restrict your ability to perform your duties as an employee of Citadel. Notwithstanding anything contained in your Employment Terms or secondment letter (as appropriate) your employment with Citadel may be terminated by Citadel giving you not less than 7 days’ notice if it considers that you are unable to comply with this requirement.
B.3 Duration
The commencement date of your employment will be agreed upon with Citadel. Your offer letter will indicate your proposed start date. Your employment with Citadel is expected to continue indefinitely subject to termination in accordance with the sections B.1, B.2, B.15, B.16 and B.17 unless those provisions are dealt with and are different from those in your Employment Terms or secondment letter (as appropriate) in which case the provisions contained in your Employment Terms or secondment letter (as appropriate) will prevail.
Where applicable, your period of continuous employment for statutory purposes shall be deemed to begin on the commencement date unless otherwise stated.
B.4 Probationary Period
While Citadel hopes your employment will be long term, the first three months of your employment will be a probationary period. This is an opportunity for Citadel to review your suitability for the job.
Unsatisfactory performance or conduct or other business reasons could result in a decision to terminate your employment at any time during your probationary period. If you do not pass your period of probation, you will receive a letter terminating your employment. If, however, you complete the probationary period successfully, your employment will simply continue – you will not receive a notification letter.
The terms and conditions of employment set out in this Handbook apply to you during your probationary period except that during the first 60 days of your probationary period you will not be eligible to participate in any pension arrangements Citadel has in place or any pension arrangements that any other entity of the Citadel Group may have in place.
Citadel reserves the right to extend your probationary period at its sole discretion and the situation will be reviewed at the end of this further period. The notice provisions that apply during your probationary period are set out in Section B.15.
B.5 Job Titles and Responsibilities
Your functional job title is as set out in your offer letter. You shall undertake such duties and responsibilities as Citadel specifies and which are consistent with your skills and competences. Your duties at any particular time may be summarised in a written job description. Citadel reserves the right to make certain changes to your job content, the nature of your duties and responsibilities, or reporting line (and any written job description) from time to time. In addition, you may be seconded to or have your employment transferred to other members of the Citadel Group as Citadel may decide from time to time (either within Singapore or elsewhere).
B.6 Confidentiality, Compliance and Non-Competition
Due to the sensitive and confidential nature of the Citadel Group’s activities, you may be required to enter into and indicate (by signing) your acceptance of the contents of the following documents:
• the Non-Disclosure, Non-Compete and Non-Solicitation Agreements; and
• any other documents required by the Monetary Authority of Singapore (“MAS”).
B.7 Normal Place of Work
Your normal place of work is Citadel’s premises in Singapore. Citadel reserves the right, following discussion with you, to change your normal place of work to any other office of the Citadel Group.
Your duties may involve training at the US offices of Citadel in Chicago, Illinois for a period of several months (the exact period of time to be agreed by both parties). While training in Chicago, Citadel will arrange and pay for your rent and utilities.
In addition, you may be required to travel on a short-term basis to the offices of any member of the Citadel Group, business associates and generally as is necessary for the proper performance of your duties or training.
B.8 Whole Time and Attention/Outside Work
During your employment with Citadel you shall devote your best efforts to promote Citadel’s business. During your normal hours of work you shall devote your whole time and attention to your duties for Citadel. During your employment with Citadel you shall not without the prior written consent of Citadel (and even then subject to any terms and conditions Citadel may reasonably impose) engage or be interested in (in either case, whether directly or indirectly) any other business or employment.
Your Supervisor may request that you terminate or modify the terms of any outside work at any time, in order to allow you to devote your business energies to Citadel’s business. Refusal to comply with such a request may result in disciplinary action, up to and including dismissal.
B.9 Working Time
Your normal hours of work will be agreed with your Supervisor. You are required to work such additional hours without additional pay as are necessary for the proper performance of your duties and responsibilities.
Unless you are required to work on a statutory public holiday, you shall not be entitled to receive any time off or additional remuneration for work performed outside normal business hours.
Salary and Expenses
B.10 Salary
Your basic salary is as set out in your Employment Terms or communicated to you separately from time to time. Your basic salary will be paid monthly after any deductions (such as pension contributions) and any other agreed deductions and/or those not prohibited by law in equal instalments in arrears in accordance with Citadel ’s procedures from time to time in force. Currently payment is made on or around the 25th day of each month and credited to the bank account nominated by you. You will be notified if your salary is to be paid at a different time of the month.
Your salary will be reviewed annually. Any review may not result in any change to your salary and any changes are solely at the discretion of Citadel and will be notified to you in writing, in accordance with Citadel procedure in place from time to time. Currently, Citadel notifies staff of any changes within six months of the start of the calendar year to which the change relates. All such communication will be private and confidential.
Any queries relating to salary payment should be raised with the Human Resources Department without delay.
B.11 Expenses and Deduction
Citadel shall reimburse you for all expenses reasonably and necessarily incurred by you in the proper performance of your duties in accordance with the Global Travel and Expense Policy (as amended from time to time) which can be accessed on the Intranet.
If you do not repay to Citadel immediately on demand any amounts payable by you to Citadel arising out of or in connection with your employment or otherwise, including any overpayment of remuneration or other payments made by mistake or through misrepresentation, Citadel is hereby irrevocably authorised, to the extent not prohibited by law, to deduct the same (or any part thereof) from any payment due to you from Citadel under Sections B.10 and B.11 or any money owed to you by Citadel on or after termination of your employment.
B.12 Central Provident Fund
Where applicable, you and Citadel shall contribute into the Central Provident Fund (“CPF”) in accordance with the requirements of the applicable law. You may also make any amount of additional voluntary contributions in accordance with the CPF provisions but this may have an impact on your personal tax liability. We advise you to seek independent advice in respect of your personal tax obligations..
Holiday and Sick Leave
B.13 Holiday
Entitlement
Citadel’s holiday year is the calendar year.
In addition to the gazetted Singapore public holidays ("public holiday"), you are entitled to 20 working days’ paid annual leave per holiday year (this includes your statutory entitlement) (your “Annual Leave Entitlement”) to be taken at times convenient to Citadel. If Citadel requires you to work on a public holiday, you will be entitled to a day’s holiday in lieu or such other entitlement under the Employment Act of Singapore.
You will accrue your Annual Leave Entitlement at the rate of 1.66 days for each completed calendar month of employment with Citadel in Citadel’s holiday year.
Procedures
You may not take annual leave and holidays (in lieu of those worked) without the prior approval of your Supervisor.
Citadel’s holiday year is the calendar year. The portion of annual leave required under the Employment Act is “statutory annual leave” and any annual leave granted in addition to the statutory minimum is “additional annual leave”. Except in your first year of employment, annual leave taken will be reduced against your statutory annual leave balance first. Once you use all your statutory annual leave, any further annual leave you take will be reduced against your additional annual leave balance.
Statutory annual leave must be taken at the time required under the Employment Ordinance, which is the year after it accrues. Any additional annual leave must be taken within the same year that it accrues. Five days of your accrued but unused additional annual leave will automatically be carried forward from one holiday year to the following holiday year. Additional carryovers of any accrued but unused additional annual leave are prohibited without the prior written approval of your Supervisor (which will only be given in exceptional circumstances) and no payment will be made in lieu of such accrued but unused annual leave.
Termination of Employment
Citadel will compensate you for any accrued but untaken statutory annual leave and additional annual leave on termination of your employment. For your accrued but untaken annual leave entitlement, this will be calculated at the rate of 1/260 of your annual basic salary for each accrued but untaken day of contractual annual leave.
If you have used more than your accrued Annual Leave Entitlement prior to the termination of your employment, you must repay Citadel for the excess days at the rate of 1/260 of your annual basic salary for each excess day. If you do not repay immediately on demand any excess annual leave pay, Citadel is hereby irrevocably authorised to deduct such amount (or any part thereof) from any money owed to you (including salary and/or bonuses) by Citadel on or after the termination of your employment (and such deduction shall be without prejudice to Citadel’s right to seek repayment by you of any part still outstanding thereafter) subject to applicable law.
Citadel reserves the right, to the extent not prohibited by law, to require you to take some, all or none of any outstanding Annual Leave Entitlement during your notice period. Your Annual Leave Entitlement will accrue during your notice period.
B.14 Sickness
Notification
If you are absent from work due to sickness or injury, you must inform your Supervisor or Human Resources at the start of your normal working day on each day of absence.
You must keep Citadel regularly informed of the reasons for and expected duration of your absence.
Any unauthorised absence for whatever reason must be explained and failure to do so may be treated as a disciplinary matter.
Short-Term Disability (STD)
Entitlement
Your sickness leave benefit shall be in accordance with the Employment Act.
After completing three months of continuous service, you will be entitled to sick leave in accordance with the following Short-Term Disability (STD) Policy which is inclusive of any statutory entitlement you may accrue and be entitled to receive.
Under this STD Policy you will be eligible for STD sick pay during an absence from work due to a non-work related personal illness or injury that continues beyond four consecutive working days.
Under this STD Policy, you are entitled to STD sick pay for up to 12 weeks in any 12- month period depending on your completed years of service. This period begins when you take sick leave under this policy. Subject to receipt by the Human Resources Department of the applicable forms and appropriate documentation (including satisfactory medical evidence), the amount of STD sick pay you are entitled to receive is as follows:
Subsequent Disability
If you are subsequently diagnosed with a severe disability that entitles you either to benefits under Citadel’s Total and Permanent Disability Scheme (under Section C.5 of this Handbook) or to any compensation under any other social security-type disability benefit provided by the government, you are still eligible to receive STD sick pay at the rate of 100% of base pay for a maximum of 12 weeks regardless of years of service. After Citadel receives appropriate documentation confirming your disability, Citadel will pay you any difference between this amount and any STD sick pay you have already received. The 5- day waiting period still applies.
Application and Medical Evidence
You must complete a Request for Short-Term Disability Benefits Form and provide any additional documentation (including satisfactory medical evidence) requested by the Human Resources Department to be considered for STD sick pay. Your eligibility for STD sick pay is determined independently from your eligibility for STD sick leave. To be eligible for continued benefits under this STD Policy, you may be required to provide additional documentation (including satisfactory medical evidence) during the time you are away confirming your continued disability and inability to work.
Doctor or Physician
Citadel reserves the right to require you to be examined at any time by an independent doctor or physician of its choice and you consent to the disclosure of any medical report prepared by such doctor or physician to Citadel. Citadel reserves the right to discontinue your STD sick pay at any time if it is advised by that doctor or physician that you are fit to return to work but you fail to return to work. If Citadel considers that you are abusing the STD Policy, you may be subject to disciplinary action which may result in termination of your employment.
No Guarantee of Employment
Your entitlement to or receipt of STD sick leave benefits under this policy does not amount to a guarantee of employment for any specific duration and does not restrict Citadel from considering your ongoing employment where you can no longer fulfil the inherent requirements of your position.
Pay During Sickness
If you do not qualify for STD sick pay in accordance with the STD Policy (as set out above) or if statutory requirements under Singapore law provides for more beneficial statutory entitlements, and if you are absent from work due to sickness or injury, you will be entitled to sick leave and sickness allowance during your period of sickness in accordance with the requirements of Singapore law.
Leaving Citadel
B.15 Notice of Termination of Employment
Your employment may be terminated during the first month of your probationary period, by either you or Citadel on 24 hours’ written notice. For the remainder of your probationary period the notice required from either party is not less than seven days’ written notice. After the probationary period has concluded and subject to B.1 and B.2, your notice period will be as set out in your Employment Terms.
Citadel reserves the right to enforce your full notice period. However in some situations, notice periods may be waived in part or in full at Citadel’s absolute discretion.
Wages in lieu of notice may be given by you or by Citadel (or any part of the notice period) less any deductions required or permitted by law. This right may be exercised by Citadel at any time including without limitation at the time notice is given or thereafter. This shall not prevent Citadel from terminating your employment without giving notice or paying wages in lieu of notice in the appropriate circumstances.
Unless you receive prior written approval from your manager, you may not announce your resignation from Citadel to third parties before or during your notice period. Doing so would be a breach of your Non-Disclosure Agreement and Citadel’s Confidential Information Policy. The ability of Citadel to maintain the confidentiality of employee resignations before and during the notice period is necessary to protect Citadel’s business interests and ensure a smooth transition.
Citadel may require that you refrain from performing any duties and/or not be present on Citadel’s premises while you are under notice of termination of your employment, known as a “garden leave.” You will continue to receive base salary and benefits (or a payment in lieu of the value of such benefits) during your garden leave. The exercise of this option is at Citadel’s sole discretion. You may not work for any employer other than Citadel (including self-employment) during a garden leave. For employees that have an executed Non-Compete Agreement as part of their employment obligations, the Restricted Period shall be reduced by one day for each day during the Notice Period prior to the end of their employment during which, at Citadel’s direction, the employee is not required not to carry out any duties. For the avoidance of doubt, such reduction shall not apply in circumstances where the employee is on “garden leave” but still required to carry out some duties (including from home). Furthermore, you shall not deal with any counterparties, brokers, etc. or employees of either Citadel or its affiliates in relation to business issues during this time. If you breach this requirement, Citadel will no longer be required to continue the payment of your base salary and benefits for the remainder of any such period.
During any period of suspension or notice described immediately above, your terms and conditions of employment, notably relating to your obligations of fidelity, confidentiality and security and including, but not limited to, your obligations under the Non-Disclosure, Non- Compete, Non-Solicitation Agreements and the Dispute Resolution Procedures, will remain in full force.
B.16 Termination of Employment without Notice
Notwithstanding any other provision of this Handbook, Citadel shall (without prejudice to its other rights and remedies) be entitled to terminate your employment without notice and without pay in lieu of notice in accordance with the Employment Act as well as for those situations listed in Section B.28 (Acts of Misconduct) or if you are of unsound mind, bankrupt or if you have had a receiving order made against you or if you make any general composition with your creditors or take advantage of any statute affording relief for insolvent debtors.
You shall have no claim against Citadel for damages or otherwise by reason of termination of your employment by Citadel in accordance with this Section.
B.17 Service of Notice
Any notice required to be given under this Handbook or under your Employment Terms shall be in writing and shall be deemed served if it is personally delivered or sent by registered post to the last known address of the other party. Any notice so posted shall be deemed served upon the second calendar day following that on which it was posted. Any notice served upon Citadel should be addressed for the attention of Human Resources or the Chief Operating Officer.
B.18 Return of Citadel Property
Upon termination of your employment, or at any other time if so required by Citadel, you shall immediately return to Citadel via your Supervisor or Human Resources any property, including without limitation any files, reports, analyses, charts, records, materials, drawings, computer hardware or software, entry passes, keys, mobile telephone and other electrical devices, credit cards, etc., any copies of the same (whether in hard copy or electronic form) and any intellectual property belonging or relating to Citadel (or any member of the Citadel Group) which you made or received during the course of your employment with Citadel and which are in your possession or under your control.
Rules and Codes of Practice
B.19 Workplace Inspections
In the interests of safeguarding employees’ property and that of our investors, Citadel and each member of the Citadel Group, and, in keeping with the spirit of Citadel’s Drug and Alcohol Policy (set out in Section B.30 of this Handbook), Citadel hereby reserves the right to question all persons entering and leaving its premises (including you, whether as an employee or as a visitor), and to inspect any packages, parcels, purses, handbags, briefcases, or any other possessions or articles carried to and from our facilities. In addition, Citadel reserves the right to inspect the contents of your office, desk, files or any other area. It should be noted that all offices, desks, files, lockers and so forth are the property of Citadel. Inspections may be conducted at any time at our discretion and prohibited items found in your possession will be confiscated.
Persons seeking to enter the premises who refuse to cooperate in an inspection conducted pursuant to this policy may not be permitted to enter the premises. If you refuse to cooperate in an inspection, (whether on entering or leaving the premises), or if, after an inspection and any appropriate investigation, you are found to be in possession of stolen property or prohibited items, you will be subject to disciplinary action.
B.20 Ensuring Ethical Responsibility
It is Citadel’s policy that all decisions and actions carried out in our name adhere to the highest standards of integrity. In many circumstances, this imposes a greater requirement than is established by law or regulation. It is your responsibility to follow this policy, guided by fundamental principles of trust, honesty, objectivity, fairness and respect for yourself and others. As an organisation, we all must strive to always “do the right thing”; therefore, reasons such as “everyone does it” or “it’s not illegal” are not excuses and are unacceptable for violating our ethical responsibility.
In addition to these professional standards of responsibility, standards and guidelines for ethical conduct are set forth in the respective Code of Conduct and other policy statements or manuals that you may receive from time to time. Certainly, no document can provide automatic answers to all possible situations, and where the circumstances you face are not addressed specifically by these policies, you should weigh your decision against the fundamental principles described here. In cases of uncertainty, unusual complexity or high sensitivity, you should discuss the matter with your Supervisor, Human Resources, Compliance, or the Chief Operating Officer.
Citadel’s reputation for high regulatory and professional standards is vitally important. Every employee has a direct personal responsibility to:
• comply with not just the letter but also the spirit of regulatory and legal requirements; and
• observe the highest standards of integrity and fair dealing.
If you believe that Citadel or another employee is in breach or at risk of a breach of those standards, you must alert Human Resources, Compliance, or the Chief Operating Officer. The importance of upholding Citadel’s standards overrides all other considerations.
You will not suffer any reprisal for matters raised in good faith. We will keep any investigation of your report(s) as confidential as practicable.
B.21 Protecting Confidential Information
As a Citadel employee, you will have continuous access to proprietary information, confidential business information and trade secrets regarding the affairs of Citadel and members of the Citadel Group, their current and former employees, and their investors. You are responsible for maintaining this information in strict confidence as described in this policy and as set forth in greater detail in the Non-Disclosure, Non-Compete (if any) and Non-Solicitation Agreements. The provisions of the Non-Disclosure, Non-Compete (if any) and Non- Solicitation Agreements shall control your compliance with this policy and you should familiarise yourself with that document to avoid any violation of this policy.
Generally, information obtained and documents produced during your employment with Citadel are Citadel property. You may not remove sensitive documents from our premises without authorisation. If you leave our employment, you may not in any way use or disclose confidential or proprietary information obtained while working here. Further, while you remain employed with us, you may not use or release information about any of Citadel’s or any member of the Citadel Group’s business to others without proper authorisation, whether for business or for personal purposes. In addition, you must carefully safeguard confidential information provided to you by third parties by virtue of your employment with Citadel.
This policy applies to all Confidential Information, as that term is defined in the Non- Disclosure, Non-Compete (if any) and Non-Solicitation Agreements. Information is covered based on its confidential and proprietary nature or content, not the form in which it exists. Therefore, information will be covered whether it exists in written or electronic form or is merely a part of your knowledge base.
Any improper use or transfer of material or disclosure of information in violation of this or any other policy will result in disciplinary action, up to and including summary dismissal, and may also subject you to civil and criminal penalties. Please recognise that such transfer of material may be intentional or inadvertent. Therefore, you are responsible for taking necessary care adequately to secure Citadel’s and Citadel Group’s Confidential Information. This includes, but is not limited to, sealing files, locking cabinets, desk drawers and briefcases, avoiding sensitive conversations on cellular phones and in public areas, particularly enclosed areas such as elevators and airplanes, and ensuring that data stored on computer hardware, such as laptops, cannot be viewed by others in your surroundings.
In the event of a conflict between this Section and your Non-Disclosure Agreement, the terms of your Non- Disclosure Agreement will prevail. You must also comply with the “Information Barrier Policies and Procedures,” “Confidential Information Policies and Procedures,” “Material Non-public Information Policies and Procedures” and all other policies as published by Legal & Compliance.
B.22 Sharing Citadel Information with the Public
As the Citadel Group grows, it attracts increasing levels of attention from the public, including media, industry groups, and online forums. Every employee of the Citadel Group should be conscious of how we represent our organization to the public.
When in doubt, consult with your Supervisor or Public Relations. Below are policies for the most common situations.
Press Inquiries
All media inquiries about Citadel should be referred to Public Relations. Unauthorized disclosure of Citadel-related information to the press is not permitted and will constitute a violation of your Non-Disclosure Agreement. The specific terms and guidelines in dealing with journalists pertaining to your business will be communicated to you and form part of your terms and conditions of employment, any breach of which may result in disciplinary action.
If you believe you’ve said something to a reporter unknowingly, or you need guidance on a press query you’ve received that is not related to Citadel, contact Public Relations.
Social Media
Social media consist of blogs, online social networks and other similar public communication venues. Participation in online forums is permitted when it is personal; however, employees are not authorized to act as a representative or spokesperson for the firm, or to disclose information that pertains to any Citadel Group activities. Unauthorized disclosure will constitute a violation of your Non-Disclosure Agreement with Citadel.
If you choose to participate in forums on the Internet, you are personally responsible and liable for what is communicated. Employees are expected to exercise common sense and caution in such participation.
If you come across online content related to Citadel that is incorrect or potentially damaging to Citadel’s reputation, please forward them to Public Relations for appropriate action.
Public Speaking
From time to time Citadel employees are invited to speak on topics pertaining to our industry. These programs are often valuable to our business and to our reputation as a market leader.
We pursue opportunities that are relevant, reach audiences who are important to Citadel and provide value to the organization.
If you have been asked to speak on behalf of Citadel and feel the opportunity is worthwhile, you must get approval from your Supervisor, and subsequent approval from Corporate Communications and Legal & Compliance prior to agreeing to the speaking engagement. Please submit the “Public Speaking Request Form” which can be found on the Intranet to commence the approval process.
Public Decorum
As a member of the Citadel organization, you are viewed by others as a representative of the firm. Be sensitive to how you and the company may be perceived by others through your words and actions. When in public – including business trips, industry events and company functions – exercise good judgment and common sense.
B.23 Avoiding Conflicts of Interest
Citadel respects the right of employees to invest in private enterprise and to engage in personal activities. However, should you wish to do so, you are responsible for avoiding any conflict between your personal interests or activities and the interests of Citadel and those of the members of the Citadel Group. As a general rule, this means that you must not acquire a personal interest in securities or properties or permit yourself to come under any personal obligation that might tend to cause you to use your position with Citadel for private gain or to obtain benefits or favours either for yourself or anyone you know, or that will influence your conduct on behalf of Citadel. Conflicts can arise with suppliers, investors and other organisations or people seeking to do business with Citadel and any member of the Citadel Group and can involve investments, outside employment or personal relationships.
If you encounter a situation in which you or an immediate family member, including your spouse, minor children and other adults living in your household, might have an actual or potential conflict of interest, you must immediately discuss the situation with your Supervisor, Compliance, or the Chief Operating Officer . This allows appropriate personnel at Citadel to make an informed, independent decision regarding a potential conflict. Citadel, in its sole discretion, will determine whether a conflict exists and what action, if any, should be taken. Violations of this policy can result in disciplinary action.
B.24 Disclosing Potential Conflicts
Citadel has established certain disclosure requirements designed to help you comply with the professional standards of responsibility policies and thereby prevent conflicts of interest. Every employee is required to complete and sign a “Citadel Employee Conflicts Questionnaire”. These policies attempt to cover common situations, but are in no way exclusive. Citadel requires you to exercise sound judgement consistent with these policies at all times in the performance of your duties. If you are unsure as to the conduct required from you or have any questions on these policies either regarding your own activities or those of your co-workers, you must seek guidance from Compliance, or the Chief Operating Officer.
Financial Interests
You must disclose any financial interest that you or any member of your immediate family holds in a present or potential investor, vendor or competitor of Citadel or any member of the Citadel Group. Immediate family includes your spouse, minor children and any adult living in your household. Such financial interests, which include individual brokerage accounts, must be identified on the “Personal Account Information Form”. In the event that you do have such a financial interest, you must not represent Citadel or be involved in any transaction with such present or potential investor, vendor or competitor of Citadel or any member of the Citadel Group. This subsection does not apply to ownership of less than 1% of the equity or debt of a publicly held corporation.
Further, as set forth in greater detail in the respective Code of Conduct, the Confidential Information Policies and Procedures, Information Barriers Policies and Procedures and the Personal Investment Policies, any trading on your personal account, and any trading your immediate family wishes to make on their personal accounts, must be approved in advance. Approval must be sought for personal account trading by using SCT under Legal & Compliance on the intranet. Please refer to the above policies or consult with Legal and Compliance for details. Failure to comply may subject you to disciplinary action, up to and including dismissal, as well as other legal penalties.
B.25 Complying with Securities Laws
Citadel’s policy regarding publicly traded securities and insider dealing rules are set forth in the Confidential Information Policies and Procedures, Information Barriers Policies and Procedures and the Personal Investment Policies (the “Policies”) which were given to you when you joined Citadel and are updated and redistributed from time to time. You should review the Policies, which can be found on the Intranet under Legal and Compliance, thoroughly and ensure that your conduct is consistent with the Policies at all times. It is emphasised that you are subject to the provisions of the Securities and Futures Act (Cap.289) and all related rules, guidelines and circulars issued by the MAS, any other relevant legislation or codes of practice in force from time to time and the requirements of Citadel’s respective Code of Conduct. Please know that Citadel strictly enforces the provisions of the Policies, in light of the severe penalties that may result from a violation of the insider trading laws. Breach of the Policies may lead to disciplinary action, up to and including dismissal. Potential penalties include civil fines and a prison sentence for the violating employee. In addition, Citadel may be liable for financial penalties for each violation by any of its employees. You should contact Compliance or the Chief Operating Officer if you have any questions regarding this compliance requirement.
B.26 Personal Solicitations
To maintain a proper business environment and prevent interference with work, as well as to avoid any undue pressure, you may not distribute literature or printed materials of any kind, sell merchandise, solicit financial contributions or solicit for any other cause during working time and working areas, except as approved by Legal & Compliance pursuant to Citadel’s Political Contribution Compliance Policies. Non-employees and other workplace visitors also are prohibited from distributing material or soliciting employees on Citadel’s or any member of the Citadel Group’s premises at any time. If you are aware of any such disturbance or interference from non-employees or other work place visitors, please report the matter to the Chief Operating Officer or Human Resources.
B.27 Compliance with Citadel Work Rules and Policies
The information in this Handbook and the Policies are all designed to provide you with guidelines for appropriate behaviour in the workplace. These documents do not provide a complete set of guidelines, but are designed merely to illustrate types of expected behaviour. You are required to adhere to these guidelines at all times.
Notwithstanding the above, Citadel believes that certain rules and regulations regarding inappropriate workplace behaviour are necessary for the efficient operation of Citadel and for the benefit and protection of the rights and safety of all. Whilst the policies and procedures contained in Section C do not form part of your contract of employment, you are required to comply with those policies and procedures. Accordingly, if you violate any of the work rules set out in this Section of the Handbook or in Section C, you may be subject to disciplinary action. This list of work rules is not exhaustive and any other action deemed by Citadel, in its sole discretion, to be similar misconduct or conduct that interferes with operations or is generally offensive to guests or fellow employees may also result in disciplinary action.
Citadel reserves the right to modify, expand or rescind any or all of these guidelines at any time, in its sole and absolute discretion.
Cooperation with Investigations
From time to time, and in its sole discretion, Citadel may authorise or conduct an investigation into possible work rule violations. In such a case, you are expected to cooperate fully with a request to participate in such an investigation. Failure to cooperate may result in disciplinary action. However, you will not be subject to retaliation or disciplinary action as a result of your participation in the investigation provided you participate in good faith.
You are required to comply with Citadel’s policies and procedures in force from time to time, including without limitation those set out within this Section B and Section C of this Handbook. Please note that it is a term of your employment that you may be required from time to time to undergo, and you hereby consent to undergo, such examinations and/or inspections as may be specified in such policies and procedures as are currently in force or may be in force from time to time, including in particular the Drug and Alcohol Policy (set out at Section B.30) and Workplace Inspections (set out at Section B.19).
B.28 Disciplinary Rules
Any employee who is found to have committed the following acts of misconduct may be subject to disciplinary action, including termination of employment. The following list of misconduct is not intended to be exhaustive and any other conduct identified by Citadel, in its sole discretion, to be similar misconduct or conduct that interferes with operations or is generally offensive to guests, clients or fellow employees may also result in disciplinary action, including termination of employment.
Citadel may terminate your employment summarily without notice or without pay in lieu of notice if it regards the misconduct as gross misconduct. Citadel may also issue you with a warning and/or take further disciplinary action if the conduct persists.
Acts of Misconduct
B.29 Data Protection
The following information is provided to you in accordance with the requirements of the Personal Data Protection Act 2012 of Singapore.
You may be required to supply (and you consent to supply) your personal data in connection with your employment. All personal data concerning you (whether provided by you or any other person, and whether provided before or after the date of the employment contract) may be disclosed or transferred to or otherwise used by Citadel and/or any member of the Citadel Group and/or any person authorised by Citadel when carrying out the business of Citadel or any Member of the Citadel Group.
All personal data concerning you (whether provided by you or any other person, and whether provided before or after the date of the employment contract) may be collected, used, and maintained for the following purposes:
The personal data that Citadel has collected may be transferred (within or outside Singapore) to our subsidiary and associate companies including any member of the Citadel Group; their insurers and bankers; medical practices providing medical cover for employees; administrators or managers of Citadel’s provident fund scheme; and other companies engaged in contractual activities on Citadel’s behalf; for the above mentioned purposes for which the personal data are to be used.
It is Citadel’s policy to retain certain personal data of employees in accordance with the applicable law when they cease to be employed by us. Such data is required for any residual employment-related activities in relation to a former employee including, but not limited to: the provision of job references, processing applications for re-employment, matters relating to retirement benefits, and allowing us to fulfill contractual or statutory obligations.
Citadel will retain data in respect of its employees after their employee with Citadel terminates for a period that Citadel considers necessary for legal and/or business purposes and/or to serve the purposes for which that personal data was originally collected.
In order to ensure the correct use and to maintain the accuracy of data collected from you, as well as preventing unauthorized or accidental access, processing, erasure or other use of the data, Citadel has implemented various physical, electronic, and managerial measures to safeguard and secure the data Citadel collects.
In general, and subject to certain exemptions, you are entitled to:
Any request for access to and/or correction of personal data should be addressed to the Human Resources Department.
B.30 Drug and Alcohol Policy
Citadel is determined to provide a safe and healthy working environment and is firmly committed to the health and safety of its employees, customers/clients, and visitors. Citadel promotes a culture free of substance abuse and the damage it causes. The use of illegal drugs and alcohol abuse is inconsistent with the behaviour expected of our employees. Such behaviour undermines Citadel’s desire to produce a service of the highest quality for its customers/clients, and subjects all employees, customers/clients, and visitors to unacceptable safety risks. For this reason, the unlawful distribution, possession, sale, or use of an illegal drug is prohibited and may render the individual liable to summary dismissal. This policy does not apply to the lawful use of prescription drugs under the supervision of a doctor and within the limits of a valid prescription.
Employees must also be mindful of alcohol consumption at company sponsored events. We expect every member of our team to act with integrity and exercise sound judgement. Accordingly, no Citadel sponsored events will serve alcohol past 11pm local time.
Citadel may offer you assistance with your alcohol or drug-related problem. However, Citadel must look after the interests of its business and other employees. If you are unwilling to accept its assistance, you may be subject to disciplinary action up to and including dismissal. Citadel reserves the right to call in the police to investigate in any case it deems necessary. The consumption of such levels of alcohol which renders you unfit to perform your duties, or causes you to be a safety hazard to yourself, customers/clients, other employees, or Citadel property, is also strictly prohibited. Any single act of excessive drunkenness may be regarded as gross misconduct, which may render the individual concerned liable to summary dismissal. It should be noted that the provisions of this policy may extend to functions outside of normal working hours.
Please note that employees who violate any aspect of this policy may be subject to disciplinary action up to and including dismissal.
Citadel reserves the right to ask you to undergo a “with-cause” drug screen when your conduct, behaviour, or work performance gives reason to believe that you are under the influence of drugs. If you refuse to comply with this request, Citadel may take disciplinary action. The organisation appreciates that this is a sensitive issue and any decision to request a screen will be agreed upon with Human Resources, or the Chief Operating Officer. A positive test result may result in your employment being terminated.
B.31 Intellectual Property and Moral Right Waiver
By statute and at common law, certain relevant inventions, discoveries, improvements, trademarks, copyrights, management and computer systems and other intellectual property are the property of Citadel if they are made by you during the course of your employment. You are required to communicate these to Citadel and to join with it, if required, in seeking appropriate legal protection without prejudice to the provisions under any other statutory rights and protection available under any applicable law. You also agree to waive any moral rights which you have in connection with any such intellectual property. Please refer to the Non-Disclosure Agreement for further information.
B.32 Gifts and Entertainment
You must not (whether for your own benefit or for that of anyone else) solicit or accept from, or offer to, an existing or prospective investor, counterparty, supplier to, or contractor with, Citadel or any member of the Citadel Group any favour, gift, entertainment, or other benefit the size or frequency of which exceeds normal business practice. Nothing may be given or received which might distort commercial judgement or harm Citadel’s reputation. The following are however permissible:
Employees are subject to reporting thresholds, approval, and notification process for any gifts and entertainment being given and received.
Please refer to the applicable “Business Gifts and Entertainment Compliance Policies” and “Global Travel and Expense Policy” which can be accessed on the Intranet.
If you have any doubt as to whether a gift or entertainment is acceptable and deliverable, please consult Compliance and for any queries on travel and entertainment issues please consult Finance.
B.33 Use of Citadel Services
Citadel contracts with a variety of vendors to provide services, e.g. courier and postal services. Unless expressly authorised, these services are to be used strictly for business purposes and not for employee’s personal use. Misuse of these services may render the individual liable to disciplinary action.
C.Non-Contractual Policies and Issues
As noted above, whilst Part C does not form part of your contract of employment, you are required to comply with Citadel’s policies and procedures in force from time to time and a failure to do so may result in disciplinary action being taken against you up to the termination of your employment. Citadel reserves the right, in its absolute discretion, to vary, amend, replace or discontinue any policy without consultation with you. However, you will be notified of any change as soon as practicable.
C.1 Bonus
You may be eligible to participate in any Citadel discretionary bonus schemes operated currently or in the future. Citadel will provide you with details of any such schemes as appropriate.
C.2 Private Medical and Dental Insurance
You and your dependants are entitled to participate in Citadel’s Private Medical and Dental Insurance in accordance with and subject to the rules of Citadel’s policy in force from time to time.
You understand and agree that if the insurer fails or refuses to provide you with any benefit under the insurance arrangement provided by Citadel, you will have no right of action against Citadel in respect of such failure or refusal. Citadel reserves the right to amend or discontinue these scheme(s) and/or the cover provided from time to time at its sole discretion and will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit. Further details of the current scheme(s) are available from the Human Resources Department and are described in the scheme documents.
C.3 Critical Illness Insurance
You and your dependants are entitled to participate in Citadel’s Private Medical and Dental Insurance in accordance with and subject to the rules of Citadel’s policy in force from time to time.
You understand and agree that if the insurer fails or refuses to provide you with any benefit under the insurance arrangement provided by Citadel, you will have no right of action against Citadel in respect of such failure or refusal. Citadel reserves the right to amend or discontinue these scheme(s) and/or the cover provided from time to time at its sole discretion and will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit. Further details of the current scheme(s) are available from the Human Resources Department and are described in the scheme documents.
C.4 Life Insurance
Citadel has in place a life insurance scheme which will provide a benefit of up to 24 (twenty-four) times your basic monthly salary (subject to any maximum amounts imposed by the scheme rules) should you die whilst in the service of Citadel.
Cover will be subject to the rules of the scheme from time to time in force and acceptance by the scheme provider of any claim under the scheme. You may be requested to provide medical evidence and in certain circumstances your benefits may be restricted or subject to special conditions. You will be notified of any such restrictions and advised of steps necessary for you to obtain full cover, where applicable.
You understand and agree that if the provider of any such scheme fails or refuses to accept a claim under the insurance arrangement provided, your estate will have no right of action against Citadel in respect of such failure or refusal and Citadel will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit. Citadel reserves the right to amend or to discontinue the life insurance scheme and/or the cover provided from time to time at its sole discretion and will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit.
C.5 Accidental Death and Dismemberment
Citadel has in place an Accidental Death and Dismemberment Insurance Scheme which provides a benefit of up to 24 (twenty-four) times your basic monthly salary (subject to any maximum amounts imposed by the scheme rules) for accidental death or certain identified accidental bodily injuries in accordance with the policy schedule. Cover will be subject to the rules of the scheme from time to time in force and acceptance by the scheme provider of any claim under the scheme. You may be requested to provide medical evidence and in certain circumstances your benefits may be restricted or subject to special conditions. You will be notified of any such restrictions and advised of steps necessary for you to obtain full cover, where applicable.
You understand and agree that if the provider of any such scheme fails or refuses to accept a claim under the insurance arrangement provided, you and your estate will have no right of action against Citadel in respect of such failure or refusal and Citadel will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit. Citadel reserves the right to amend or to discontinue the Accidental Death and Dismemberment Scheme and/or the cover provided from time to time at its sole discretion and will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit.
You or your personal representative will be requested to provide proof of loss when making a claim.
C.6 Total and Permanent Disability
If you are rendered unable to work as a result of becoming totally and permanently disabled, Citadel has in place a Total and Permanent Disability Insurance Scheme which provides a benefit of up to 24 (twenty-four) times your monthly basic salary by way of a lump sum of up to S$200,000 as the first payment. The balance of any benefit due will be paid in 3 (three) equal annual installments (subject to any maximum amounts imposed by the scheme rules). If a Total and Permanent Disability benefit payment has been made, no Life Insurance benefit shall be payable in the event of subsequent death. Cover will be subject to the rules of the scheme from time to time in force and acceptance by the scheme provider of any claim under the scheme. You may be requested to provide medical evidence and in certain circumstances your benefits may be restricted or subject to special conditions. You will be notified of any such restrictions and advised of steps necessary for you to obtain full cover, where applicable.
You understand and agree that if the provider of any such scheme fails or refuses to accept a claim under the insurance arrangement provided, you and your estate will have no right of action against Citadel in respect of such failure or refusal and Citadel will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit. Citadel reserves the right to amend or to discontinue the Total and Permanent Disability Scheme and/or the cover provided from time to time at its sole discretion and will not be liable to provide any replacement benefit of the same or similar kind, or compensation in lieu of such benefit.
You will be requested to provide proof of your permanent disability when making a claim.
C.7 Disciplinary Procedures
From time to time, and in its sole discretion, Citadel may authorise or conduct an investigation into possible work rule violations or suspected acts of misconduct. Citadel may require you to attend a disciplinary hearing and will expect you to co-operate fully.
You may be given a warning as a result of any acts of misconduct committed by you or, if sufficiently serious, you may be summarily dismissed.
Citadel may also be obliged to conduct, or participate in, an investigation at the behest of a regulator. In such a case, you are expected to cooperate fully with a request to participate in such an investigation. Failure to cooperate may result in disciplinary action, up to and including termination of employment. You may, however, be disciplined in connection with any wrongdoing that is revealed by the investigation.
C.8 Grievance Procedures
Citadel recognises that misunderstandings or conflicts can arise in any organisation. Your role in resolving such matters is crucial and you are expected to be direct with co-workers in trying to prevent and resolve problems before they become serious.
However, if a situation persists that you believe is detrimental to either you or to Citadel, please talk to your Supervisor. If you are not comfortable discussing the particular situation with your Supervisor, please feel free to speak with Human Resources, the General Counsel or the Chief Operating Officer. All conversations will be treated in a confidential manner to the greatest extent possible. Citadel will make every attempt at being as responsive and prompt as possible in resolving the problem.
Citadel does not tolerate any form of retaliation against employees who use this procedure in good faith. The procedure should not be construed, however, as preventing, limiting, or delaying Citadel from taking disciplinary action against any individual, including termination of employment, in circumstances where Citadel deems disciplinary action appropriate.
C.9 Diversity and Inclusion Policy
A diverse team and an inclusive culture are foundational to Citadel’s mission of being the world’s most successful investment team and market maker. For nearly three decades, Citadel has flourished by attracting extraordinary individuals of all backgrounds, upholding meritocracy and winning with integrity. This policy sets out the elements of Citadel’s core values and strategies as they pertain to promoting a work environment that is diverse and inclusive.
Citadel believes a diverse team of individuals is a powerful source of strength. A broad array of viewpoints and experiences drives faster innovation and superior execution, creating a meaningful source of competitive advantage. We believe diversity of background, experience, beliefs and thought drives unique and greater outcomes. Citadel’s commitment to attracting and developing a diverse talent base reflects its culture of meritocracy.
C.10 Equal Employment Opportunity Policy
Citadel is an equal opportunity employer. All individuals are considered for employment and advancement opportunities without regard to race, creed, colour, religion or belief, political opinion, sex, gender, sexual orientation, marital status, ethnic or national origin, age, disability, or any other protected characteristic.
As an organisation, Citadel is committed to these ideals as they relate to recruitment, selection, employment, promotions and transfers, compensation, benefits, services provided, disciplinary actions and dismissal, training opportunities and all other matters relating to your employment. Employee achievement at Citadel is measured by merit and accomplishment, including decisions regarding hiring, promotion and compensation.
Citadel will not tolerate unlawful discrimination. All employees, but particularly managerial staff, are obliged to ensure that they do not unlawfully discriminate or knowingly aid another to do so and if you are found to be engaging in any type of unlawful discrimination, you will be subject to disciplinary action, up to and including dismissal for serious or persistent offences.
Citadel encourages employees to report in good faith any unlawful discrimination. Any employee who feels discriminated against should report the complaint as soon as possible to their manager, Human Resources, General Counsel or the Chief Operating Officer. Employees are encouraged to direct any questions or concerns about discrimination in the workplace, to their manager, Human Resources, or any other member of management. Complaints and/or concerns remain confidential to the extent possible, in light of Citadel’s need to conduct a proper investigation.
Citadel is against any form of retaliation or victimisation against any employee who, in good faith, raises concerns or makes reports or complaints about discrimination or assists in a complaint investigation. However, if after investigating a complaint of unlawful discrimination, Citadel determines that the complaint was not made in good faith or that an employee has provided false information regarding the complaint, disciplinary action may be taken against the individual who filed the complaint or who gave false information.
Citadel conducts annual workplace training on harassment, discrimination, and respect.
C.11 Employees with Disabilities
If you feel you are an individual with a disability and need an accommodation to perform your job, you should make such an accommodation request to your Supervisor, or the Resources Department. Upon receipt of the accommodation request, we will work with you in investigating a reasonable accommodation that enables you to perform the essential functions of your job, as long as such accommodation does not pose an undue hardship to Citadel. After proper assessment, the Human Resources Department will advise you of our decision on your accommodation request.
Only those persons with a need to know will be apprised of any medical or other information concerning your accommodation request.
C.12 Anti-harassment Policy
Citadel is committed to maintaining a work environment that encourages and fosters appropriate conduct and dignity and respect for individuals. Accordingly, Citadel has adopted this policy in order to create a work environment free from discrimination of any kind, including harassment based upon race, creed, colour, religion or belief, political opinion, sex, gender, sexual orientation, marital status, ethnic or national origin, age, disability, or any other protected characteristic. Citadel wishes to emphasise that all forms of harassment are unacceptable. Accordingly, Citadel will not tolerate harassment by or of any employee, non-employee, vendor or workplace visitor in any form, whether non- verbal, verbal, physical or by innuendo. Any employee who violates this policy shall be subject to disciplinary action up to and including dismissal for serious offences. If legal proceedings are brought, any employee involved in acts of harassment may be held personally liable.
Definitions and Examples of Workplace Harassment
Sexual Harassment
Sexual harassment is an unwelcome sexual advance, or an unwelcome request for sexual favours, or unwelcome conduct of a sexual nature or any other conduct based on sex affecting the dignity of women and men at work. This can include physical, verbal, or nonverbal conduct.
Sexual harassment includes, but is not limited to:
Such conduct is unacceptable if:
Disability Harassment
Disability harassment is unwelcome conduct (which may include an oral or written statement) given to a disabled employee on account of his or her disability (or the disability of an associate of the employee). An associate includes a spouse, relative, carer, someone who is living with the employee and someone who is in a business, sporting or recreational relationship with the employee.
Disability harassment includes, but is not limited to, offensive or derogatory remarks or jokes or abuse referring to the disabled employee’s disability or the disability of an associate of the employee, offensive comments about the disabled employee’s appearance or the appearance of an associate of an employee, making offensive gestures or noises, or displaying offensive objects, pictures or written materials.
Disability harassment may also include behaviour which is not obviously offensive but which discriminates - intentionally or not - against a disabled employee or an associate of a disabled employee. For example, it may include unnecessarily arranging meetings in rooms which are difficult for the employee to get to or otherwise making arrangements which inconvenience the disabled employee more than they would inconvenience an employee who is not disabled.
General Harassment
The essential characteristic of sexual or disability harassment is that it is unwelcome by the recipient. It is for each employee to determine what behaviour is acceptable to them and what they regard as offensive. Attention becomes harassment if it is persisted in once it has been made clear that it is regarded by the recipient as offensive. However, in some cases, one incidence of behaviour may so obviously be offensive that it will constitute harassment.
You should understand that Citadel’s definition of impermissible conduct may be broader than the legal definition; nevertheless, Citadel will hold you responsible for maintaining both internal as well as legal standards. Citadel recognises that sometimes it can be difficult to know what constitutes harassment since people and their perceptions and sensibilities are different and can change. Comments, jokes or personal advances that you may perceive as innocent or funny may be offensive to a co-worker. You should know that even innocent intentions do not excuse actions that are unwanted and that are reasonably perceived as threatening or offensive. Therefore, you are encouraged to avoid misunderstandings by acting professionally, treating others with dignity and respect, and avoiding conduct that others could misinterpret either as welcoming inappropriate conduct or as being inappropriate conduct.
C.13 Complaints of Harassment
If you believe that you are being subjected to harassment in Citadel’s workplace, you should firmly and promptly notify the offender that his or her behaviour is unwanted, inappropriate, and/or unwelcome, and that it offends you or makes you feel uncomfortable and interferes with your work. If it is too difficult or embarrassing for you to do this on your own, you may wish to seek support from a sympathetic colleague who could make the approach for you. However, if such informal, direct communication is ineffective or impractical, you should follow the procedures in this policy. Please be aware that you do not need to first try informal, direct communication before you can utilise these procedures. Similarly, if you witness conduct by others that you believe may be workplace harassment, or if someone you know has been the victim of workplace harassment, you may also use the following procedures:
You should report the offending incident(s) or conduct as promptly as possible. You should also feel free to report the incident or conduct even if, in the past, you did not report it or if you have taken some time to decide to report the incident or conduct.
Citadel has no requirement for the form or content of a complaint. However, to allow us to take steps to prevent harassment in our workplace, please provide as much information as possible regarding the offending incident(s) or conduct, such as what happened or is continuing to happen, the person(s) involved, the time(s) and place(s) the incident(s) occurred and the names of witnesses, if any.
If it is found that a disciplinary offence has occurred, disciplinary action will be taken under Citadel’s Disciplinary Procedure. This may include a requirement that an employee guilty of harassment should attend counselling and thereafter Citadel will monitor the situation to check that the harassment has stopped. Cases of serious harassment may result in the employee’s dismissal.
Prohibition against Retaliation and Victimisation
Citadel prohibits any form of retaliation or victimisation against any employee who, in good faith, files a complaint under this policy or assists in a complaint investigation and shall treat such retaliation or victimisation as a disciplinary offence. However, if, after investigating any complaint of harassment, Citadel determines that the complaint was not made in good faith or that an employee has provided false information regarding the complaint, disciplinary action may be taken against the individual who filed the complaint or who gave false information.
C.14 Personal Relationships
Citadel prohibits relationships between a manager and a member of the manager’s staff (an employee who reports directly or indirectly to that person) and between employees who are in positions involving the review or audit of each other’s work, as permitted by law. Citadel also prohibits relationships where there may be a real or perceived conflict of interest, as determined in Citadel’s sole and absolute discretion. If such relationships exist, the parties need to be aware that Citadel, at its sole discretion, may effect modifications, including, but not limited to, implementation of enhanced controls in respect of one or both roles, one or both employees may be moved to a different department, or other action may be necessary, up to and including separation from employment. If any employee enters into a prohibited romantic relationship as defined above, the parties must notify their Department Head and Human Resources. If there is any ambiguity or doubt as to whether a particular romantic relationship creates a real or perceived conflict of interest, employees are expected to seek clarification with Human Resources. At all times, you are expected to respect the confidentiality obligations that you and other employees owe to Citadel. You may not disclose sensitive information to any employees that do not have a business need to know, and should not ask or probe for sensitive information that other employees are not permitted to disclose to you.
C.15 Health and Safety Policy
Citadel is committed to providing a safe work environment for our employees and other visitors to our facilities. In this regard, Citadel complies with relevant occupational health and safety laws with the goal of minimising exposure to health or safety risks. To help accomplish this, you are expected to work diligently to maintain safe working conditions and to adhere to practices and procedures designed to prevent injuries and illness. This is an important statement and it is for the attention of all employees, whatever their position.
Your responsibilities in this regard include:
Citadel reserves the right to request that you leave the premises if, in our judgement, your injury or illness poses a direct threat to the health and safety of others in the workplace, in accordance with applicable law. It is the desire and policy of Citadel to comply with the statutory requirements laid down in the Workplace Safety and Health Act (Cap. 354A) and associated regulations and to inform you, and to emphasise to you, that your health, safety and welfare at work should be important to you, as well as to the business.
Our policy is to provide and maintain safe and healthy working conditions, equipment and systems of work for all our employees, and to provide such information, training and supervision as they need for this purpose.
C.16 Workplace Violence Policy
Workplace Violence
You are strictly prohibited from any act or threat of violence against any person, including employees, customers, vendors, service providers or other visitors, in or about Citadel’s facilities or while you are engaged in our business. You are further prohibited from such conduct against any of your co-workers at any time, as it inevitably will create tension and conflict inside the workplace.
Further, as a Citadel employee, you should warn appropriate personnel, e.g. your Supervisor, Human Resources, the General Counsel, or the Chief Operating Officer if you observe or are made aware of any inappropriate behaviour relating to violence in the workplace. Your reports in this regard will be held in confidence to the maximum extent possible and you will not suffer any retaliation for making a report in good faith under this policy. Such claims are serious, however, if Citadel determines that your complaint is not made in good faith or that you provided false information regarding the complaint, disciplinary action may be taken.
C.17 Personal Development
Education and Training
Citadel recognises the important role you have in creating and maintaining our learning organisation.
Our Growth & Development Team provides professional development opportunities that enhance the performance of our individuals and teams. For full detail regarding our education and training programs, including eligibility requirements, programme restrictions, and the application / reimbursement process, please visit the Intranet.
Onsite Training
Instructor-led courses, seminars, and presentations are held onsite throughout the year through partnerships with industry experts and top academic institutions, technology firms, and consulting firms.
Online Training and Self-Study Resources
Self-Study Resources are available, containing high-quality educational materials such as online universitylevel courses, technical presentations from industry experts, and various other websites, books, and tools on a variety of topics pertinent to our employees.
Financial Markets eLearning
Employees have access to over 300 online courses focused on various financial markets and investment topics. The courses are created by market experts and take approximately one hour to complete.
Library and Recommended Reading
Over 600 books are available for loan. Each employee may check out up to three titles at once for a maximum of 60 days.
Tech Talk Videos
Tech Talks are presentations featuring leading technology experts that are delivered exclusively to Citadel professionals. Past presentations have focused on programming techniques, product releases, and industry outlooks.
Continuing Education
If you would like to participate in offsite seminars or pursue professional certifications and academic degrees, you may be eligible for sponsorship through Citadel’s Continuing Education Programs.
Individual and Team Coaching
Individual and team coaching engagements are available through partnerships with top consulting firms. Coaching engagements are unique to each individual and team, but typically focus on leadership development, management skills, communication and presentation skills, team building and conflict resolution.
C.18 Working Conditions
Personal Use of Citadel Public Areas, Property and Facilities
Citadel may maintain public areas as a means for communicating to our growing population. These areas are located throughout the facility in places frequently visited to allow constant access to posted information. Information in such areas may be updated by the Human Resources Department and used to post information about your rights as an employee, to highlight important policy and operational information and to announce special events. You may not use these public areas to post printed or written materials, photographs or notices of any kind that are inconsistent with Citadel’s “Personal Solicitations” Policy.
You may not make unauthorised or improper use of Citadel personnel, and should refrain from making any request of any co-worker that is not consistent with Citadel business operations. Further, all offices, desks, computers, computer files and office supplies, whether or not in use or discarded, are the property of Citadel and are not for your personal use, unless such use is approved in advance by your Supervisor. Citadel retains the right to access Citadel property at all times; therefore, to avoid confusion regarding ownership, please keep your personal items separate from Citadel property.
Personal Appearance and Demeanour
Citadel’s dress code is business casual. We believe that an informal style of dress and behaviour contributes to the efficient operation of Citadel. You are, however, required to dress in appropriate attire and to conduct yourself in a professional manner at all times. Should you, in the judgement of your Supervisor or Human Resources, appear for work not properly dressed, you may be asked to leave the workplace and directed to return in proper attire and you will not be paid for the time off.
You are also expected to keep your work environment clean and orderly. To this end, please make an effort to organise and clear all materials from work surfaces, especially materials of a sensitive or confidential nature, prior to leaving at the end of each day.
Smoke-Free Environment
To maintain a safe and comfortable working environment, Citadel is pleased to provide you with a work environment that is smoke-free. As such, Citadel prohibits smoking in office space, including corridors and utility areas.
C.19 Maternity Leave
Citadel’s policy is to treat employees affected by pregnancy, childbirth or related medical conditions in the same manner as other employees unable to work because of their physical condition in all employment aspects, including recruitment, hiring, training, promotion and benefits.
If you become pregnant and have a baby while you are employed by Citadel, you will be entitled to take paid maternity leave in accordance with this policy.
Please note that only permanent employees are eligible for the paid maternity leave under this policy. Individuals considered contractors by Citadel are not eligible for the paid maternity leave under this policy. Interns are also not eligible for the paid maternity leave under this policy. Contractors and interns are entitled to any maternity leave benefits available under Singapore law.
Leave Entitlement and Maternity Pay
Regardless of your length of service, you will be entitled to take maternity leave of 16 weeks in one continuous period on full pay (inclusive of any statutory maternity leave entitlement you may have under Singapore law). If you would like to discuss flexibility around taking your leave, please speak to Human Resources.
If you need to take additional leave as a result of pregnancy-related illness, you may apply for sickness leave in accordance with section B.14 of this Handbook (Sickness).
Throughout your maternity leave period, your entitlements and benefits will remain the same. During your period of maternity leave, you will continue to accrue annual leave at your contractual rate.
Ante-Natal Care
If you are pregnant and have made an appointment to receive ante-natal care on the advice of a registered medical practitioner, you may take time off work to attend the appointment. You will not be required to work additional or different hours to make up the lost time but we ask that you endeavour to arrange ante-natal appointments at the beginning or end of the working day where possible.
Start of Maternity Leave
A medical certificate certifying the pregnancy by a registered medical practitioner is required by Citadel and should be provided to the HR Benefits Team. You may start your maternity leave in accordance with Singapore law.
C.20 Paternity Leave
If you become a father of a newly born child or a parent of an adopted child (where your spouse or partner is taking adoption leave) or child placed in long-term or permanent foster care while you are employed by Citadel, you will be entitled to take paid paternity leave in accordance with this policy.
Please note that only permanent employees are eligible for the paid paternity leave under this policy. Individuals considered contractors by Citadel and interns are not eligible for the paid paternity leave under this policy. Contractors and interns are entitled to any paternity leave benefits available under Singapore law.
Regardless of their length of service, employees who are fathers of a new born child or a parent of an adopted child or a child placed in long-term or permanent foster care, are entitled to take up to 2 weeks’ paternity leave on full pay (inclusive of any statutory paternity leave entitlement under Singapore law). In order to qualify for paternity leave, you must be the biological father of a new born child or the mother’s husband or partner, or the father of an adopted child or a child placed in long-term or permanent foster care.
Eligible employees are generally entitled to take the 2 weeks of paternity leave in one continuous period. Employees may take paternity leave at any time within 16 weeks beginning on the actual date of delivery or adoption or fostering placement of the child. Only one period of leave will be available to you irrespective of whether more than one child is (i) born as a result of the same pregnancy, or (ii) adopted, or (iii) placed on fostering care. If you would like to discuss flexibility around taking your leave, please speak to Human Resources.
You are expected to give advance notification of 3 months (or as close to that as reasonably possible) to your Supervisor and Human Resources of the expected delivery date or adoption date of the child. If you do so, you can take paternity leave by notifying your Supervisor and the Human Resources Director immediately prior to taking leave.
For the avoidance of doubt, an employee who has taken maternity or adoption leave will not be entitled to paternity leave under this section.
C.21 Other Time Off
Marriage Leave
If you have been continuously employed by Citadel for a period of one year or longer, you will be entitled to take up to five days’ marriage leave on full pay in the year in which you marry.
Bereavement Leave
You will be entitled to take up to five days' leave on full pay to attend the funeral or take care of related personal details due to a death in your immediate family. “Immediate family” for purposes of this policy is defined as your spouse, children, parents, grandparents, siblings, siblings-in-law and parents-in-law.
Adoption Leave
If you are to be the parent of an adopted child, you may be eligible for paid adoption leave. Please note that only permanent employees are eligible for the paid adoption leave under this policy. Individuals considered contractors by Citadel and interns are not eligible for the paid adoption leave under this policy. Contractors and interns are entitled to any adoption leave benefits available under Singapore law.
Eligibility, Leave Entitlement and Maternity Pay
You must meet the following criteria to be eligible for adoption leave:
Only one parent can take adoption leave. If your spouse or partner takes adoption leave with their employer, you may be entitled to paternity leave. In some cases, you may also qualify for shared parental leave.
Regardless of your length of service, you will be entitled to take adoption leave of 12 weeks in one continuous period on full pay (inclusive of any statutory adoption leave entitlement you may have under Singapore law). If you would like to discuss flexibility around taking your leave, please speak to Human Resources.
Throughout your adoption leave period, your entitlements and benefits will remain the same. During your period of adoption leave, you will continue to accrue annual leave at your contractual rate.
Start of Adoption Leave
Evidence of the formal intent to adopt is required by Citadel and should be provided to the HR Benefits Team. You may start your adoption leave in accordance with Singapore law. For the avoidance of doubt, an employee who has taken paternity leave will not be entitled to adoption leave under this section.
Childcare Leave
Currently, if you are a full-time employee and have at least 3 months’ continuous employment, you are eligible for 6 days of childcare leave per year until the year your child turns 7 years old, regardless of the number of children you have. Yearly childcare leave must be consumed by the end of that year and cannot be carried forward. Childcare leave is capped at a total of 42 days for each parent. Leave is pro-rated for part-time employees and employees with partial year of service in that calendar year.
Extended Childcare Leave
Eligible employees with a child between the age of 7 and 12 years of age are eligible for two days of extended childcare leave. For parents with children in both age groups (i.e. under 7 years old as well as between 7 and 12 years old), the total maximum number of childcare leave is six days per year (pro-rated for partial years of service).
Unpaid Infant Care Leave
Currently, full-time working parents of children below 2 years of age, and with at least 3 months’ continuous employment, may take leave without pay of up to 6 days a year (regardless of the number of children you have). This is additional to any entitlement to paid childcare leave. Leave is pro-rated for part-time employees. More information can be obtained from Human Resources.
Shared Parental Leave
If you are a working father, you may be eligible for shared parental leave in accordance with the eligibility requirements and entitlements applicable at the time and as set out by the Ministry of Manpower.
C.22 General
Access to Personnel Records
Citadel maintains personnel records for each employee, including your personnel file and your benefits file. These files contain documentation regarding most aspects of your employment, including, but not limited to, performance appraisals, compensation letters, disciplinary warnings and other notices. In compliance with the Personal Data Protection Act 2012, the Company seeks to maintain up-to-date, accurate and complete personnel files at all times. It is your responsibility to manage updated telephone number(s), home address, and emergency contact information, legal or preferred name in the Company’s HR system. It is your responsibility to maintain and update changes in number of dependents, or beneficiary designations on the respective employee benefit system. In addition, you have the right to review your personnel files consistent with applicable law. If, after such review, you believe any records or information in your personnel file are inaccurate, you may submit a written request to the Human Resources Department to have them corrected. The Human Resources Department will either correct the disputed information or explain in writing why your request was not granted. Your request and any response from the Human Resources Department will be kept in your file. If your records are not modified to your satisfaction, you may file a written statement of disagreement with the Human Resources Department, which also will be kept in your personnel file and will accompany any transmittal or disclosure made to a third party.
Citadel respects the privacy of employees and will control access to individual files. Generally, personnel records are maintained as confidential data, and are shared only with those Citadel personnel or business agents with a need to know. Former Citadel employees and unrelated third parties have access to employee personnel files only in accordance with local law. Please also see Section B.29 (Data Protection).
Employee Referral Programme
Citadel strives to create a workplace in which we can all take pride and encourages employees to refer candidates for consideration for appropriate openings within Citadel. If an individual referred by you is hired by Citadel and remains employed for at least six months, you will be eligible to receive an employee referral bonus. Further information is available on the Intranet. If you have any questions regarding this policy, please contact the Recruiting team.
Employment References
All employment verification inquiries must be referred promptly to the Human Resources Department, who will respond to all such inquiries. In general, responses to an inquiry will be limited to confirming dates of employment and positions held.
Citadel will comply with requests for letters of reference from letting agencies if you specifically authorise the reference. The Human Resources Department will handle requests for references from other employers for currently employed staff and for those who have left within the previous five years. Open letters of reference will not be given and no reference should be given by an employee, other than from the Human Resources Department.
Personal Property
You should take care of your property to prevent theft and you are responsible for the safety of your own personal property on Citadel premises. Citadel cannot accept responsibility for any loss or damage caused in this regard. Notification of articles lost or found on the premises should be made to the Office Administrator.
You should refrain from having personal mail sent to you at Citadel premises. Citadel cannot accept liability for the loss of personal mail addressed to the premises.
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