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REQUEST FOR PROPOSAL

Project Name Appointment of External Auditor for Audit of Disbursed Claims under FTS, IBF-STS and PCP Schemes

RFP.FUN.2018.0003

The Institute of Banking & Finance

(Reg No: 197402045E) 10 Shenton Way

#13-07/08, MAS Building

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1 ABOUT IBF

1.1 The Institute of Banking and Finance Singapore (“IBF”) was established in 1974 as a

not-for-profit industry association to foster and develop the professional

competencies of the financial industry. The principal activities of IBF are:

(a) To administer licensing examinations on behalf of the Monetary Authority of

Singapore (“MAS”) and industry examinations on behalf of industry bodies;

(b) To develop industry standards, competency roadmaps and professional

development pathways for financial industry practitioners;

(c) To act as the national accreditation and certification agency for financial industry

competency in Singapore;

(d) To administer training grant schemes offered under the Financial Sector

Development Fund (“FSDF”) on behalf of the MAS;

(e) To facilitate and administer Professional Conversion Programmes for the

financial industry on behalf of Workforce Singapore; and

(f) To provide career advisory and job placement services for the financial industry.

2 PROJECT BRIEF

2.1 The purpose of this Request for Proposal (RFP) is to invite proposals for the audit of

disbursed claims under the following schemes/programmes:

(a) Training grants under the Financial Training Scheme (FTS) and The Institute of

Banking and Finance Standards Training Scheme (IBF-STS); and

(b) Course fees and salary support grants under Professional Conversion

Programmes (PCP).

2.2 The Financial Training Scheme (FTS) is a training incentive scheme under the Financial

Sector Development Fund, aimed at supporting financial sector training programmes

that raise the competency of the financial sector. The IBF Standards Training Scheme

(IBF-STS) provides funding for training and assessment programmes accredited under

the IBF standards.

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2.3 The Professional Conversion Programme (PCP) is part of the Adapt and Grow initiative

offered by Workforce Singapore (WSG) to support individuals in re-skilling for

expanded or new jobs. IBF is the appointed Programme Manager to administer the

PCPs for the financial industry. The PCPs provide a course fee grant for structured

training that is not accredited by any agency and funding support for salary to

companies that successfully complete PCPs administered by IBF. Please refer to Annex

1 for information on training grants under the FTS and IBF-STS schemes, and Annex 2

for information on course fees and salary support under PCP.

3 BACKGROUND

FTS and IBF-STS Claims

3.1 Company-sponsored claims under the FTS and IBF-STS training grants are submitted

during two claim cycles every year as follows:

Claim Cycle Qualifying Period Claims Submission Period

1 Programmes completed1 from Jan

to Jun Jul to Sep of the same calendar year

2 Programmes completed1 from Jul

to Dec Jan to Mar of the next calendar year

3.2 Self-sponsored claims under IBF-STS are submitted by the training provider

throughout the year but within three months from the date of their trainees’

completion1 of their programmes.

3.3 Training grant claims are submitted through the IBF Portal by (a) Financial Institutions

(FIs) for company-sponsored trainees and (b) Financial Training Providers (FTPs) for

self-sponsored trainees. With effect from 1 July 2018, IBF has revised the claim

submission requirements in relation to training grants under the FTS and IBF-STS.

1 For programmes with an assessment component, the trainee must have passed the assessment, and for

programmes without an assessment component, the trainee must have received a certificate of attendance

provided by the training provider.

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3.4 All company-sponsored claims submitted by FIs must be accompanied by the following

supporting documents:

Total claim amount per

company-sponsored

claim application

Supporting documents required

S$30,000 and above

(a) Signed Management Declaration Form; and

(b) One of the following:

External audit certification; or

Internal audit certification; or

Compliance certification.

Less than S$30,000





Compliance certification; or

Full supporting documents for each trainee (i.e.

programme completion certificates,

programme invoices and/or any relevant

documents as proof of successful programme

completion and fee payment, as well as any

other documents necessary to support the

claim application).

3.5 All claims submitted by FTPs for self-sponsored trainees must be accompanied by full

supporting documents for each trainee (i.e. programme completion certificates,

programme invoices and/or any relevant documents as proof of successful

programme completion and fee payment, as well as any other documents necessary

to support the claim application).

3.6 After receiving the claims, IBF will perform selected pre-disbursement checks before

disbursing the training grants to the FIs and self-sponsored trainees. IBF will provide

more information on the pre-disbursement checks upon request.

3.7 For an overview of the claims load and claims profile (based on data in 2017), please

refer to Annex 3.1.

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Professional Conversion Programme (PCP) Claims

3.8 Professional Conversion Programme (PCP) claims are submitted during four claim

cycles every year as follows:

Claim Cycle Qualifying Period Claims Submission Period

1 PCP completed2 from Jan to Mar Apr to Sep of the same calendar year

2 PCP completed2 from Apr to Jun Jul to Dec of the same calendar year

3 PCP completed2 from Jul to Sep Oct of the same calendar year to Mar

of the next calendar year

4 PCP completed2 from Oct to Dec Jan to Jun of the next calendar year

2Completion of PCP refers to the date on which the trainee completes his/her on-the-job (OJT) training

or structured training, or starts his/her redeployment, whichever is later.

3.9 All claims submitted by FIs for course fees and/or salary funding support must be

accompanied by the following supporting documents:

Total claim amount Supporting documents required

S$30,000 and above





Compliance certification.

Less than S$30,000





Compliance certification; or

Full supporting documents

3.10 After receiving the claims, IBF will perform selected pre-disbursement checks before

disbursing the grants to the FIs. IBF will provide more information on the pre-

disbursement checks upon request.

3.11 For an overview of the projected claims load and claims profile, please refer to Annex

3.2.

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4 SCOPE OF SERVICES

Requirement Specifications

4.1 The appointed auditor will perform audits on claim applications disbursed in the prior

quarter, and on any specific claim application selected by IBF or the grant authority,

to detect anomalies, erroneous or fraudulent claims.

4.2 The post-disbursement audit performed by the appointed auditor should include but

not be limited to the following:

S/N Purpose Training Grants under FTS

and IBF-STS

Course Fee and Salary

Support Grants under PCPs

(a) Verifying

accuracy of

claim amounts

Programme cost

reflected in the funding

claim worksheet is

correct

GST amount is not

claimed by the FI

Claim is submitted in the

correct claim submission

period/ claim cycle

Only completed

programmes are

included in claim

Salary support reflected

in the PCP funding claim

worksheet is reasonable

Correct funding

quantum for salary

support has been

applied

Trainee has successfully

completed both the

Structured Training and

On-the-Job-Training

(OJT) component of the

PCP, and has been

successfully re-

deployed by the FI

Trainee has completed

training for the PCP and

been redeployed within

the stipulated time

frame.

Claim is submitted in

the correct claim

submission period/

claim cycle

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S/N Purpose Training Grants under FTS

and IBF-STS

Course Fee and Salary

Support Grants under PCPs

(b) Verifying

authenticity of

trainees

Existence of trainee

Trainee is a Singapore

Citizen/ Permanent

Resident

For enhanced funding

quantum of 90%, trainee

is 40 years old and above

Trainee is a staff of the FI

Existence of trainee

Trainee is a Singapore

Citizen/ Permanent

Resident

For enhanced funding

quantum of 90%,

trainee is 40 years old

and above or has been

unemployed for at least

6 months prior to the

PCP

Trainee is a staff of the

FI

4.3 The auditor should propose a risk-based audit approach, taking into consideration the

type of claim submission, i.e. whether the claim is submitted with an internal audit

certification, compliance certification, external audit certification or full supporting

documents, to ascertain with at least 95% confidence that the claims have been

properly disbursed. Please refer to the types of checks performed by the external/

internal auditors and internal compliance departments of FIs under Annex 4.

4.4 The auditor should also recommend indicators as well as additional supporting

documents that FIs/FTPs should be required to provide (if their claim applications are

selected for post-disbursement audit) to facilitate the detection of fraud at the trainee

level, claim application level, and claim applicant (i.e. FI/FTP) level.

4.5 The auditor is expected to assess the risk and assign an associated risk rating to each

claim applicant audited. Based on the risk profile of the claim applicant, the auditor

may vary the sample sizes accordingly in subsequent audits (e.g. apply a higher

sampling for higher-risk claim applicants). The auditor should propose an appropriate

approach to building the risk profile of each claim applicant.

4.6 The auditor may also use data provided by IBF (e.g. claim records, IBF member-FI

employee size, pricing of IBF-accredited programmes) to enhance the quality and

efficiency of its audit.

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4.7 The auditor will undertake all tasks involved in audit field work, from selecting the

claim samples to following up with the FIs and FTPs on their document submission.

4.8 The appointed auditor will be awarded a one-year contract with IBF having the option

to extend the contract by one year.

Audit Deliverables and Timeline

4.9 With reference to the audit timeline and audit deliverables under Annex 5, the auditor

is expected to complete the audit field work and submit the audit report on time. The

audit report should comprise but not be limited to the following:

(a) List of claims audited with no exception noted

(b) List of claims audited with exceptions noted (but having no financial impact)

(c) List of claims audited with exceptions noted (having financial impact) and workings

to arrive at the clawback amount.

5 EVALUATION CRITERIA

5.1 The evaluation criteria for this engagement of services will be based on the following:

(a) Ability to provide a pragmatic and efficient risk-based audit approach to achieve

IBF’s audit objectives within the required timeframe.

(b) Experience / track record in providing similar audit scope to government agencies

or programme managers of government grants.

(c) Experience and qualification of team to be assigned to the project. Please indicate

if there are possible conflicts of interest with other assignment(s) undertaken by

the audit firm.

(d) Competitive fee structure.

(e) Ability to meet IBF’s reporting needs.

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6 SUBMISSION REQUIREMENTS AND DEADLINE

6.1 The proposal should comprise:

(a) Executive Summary of the company’s understanding of IBF’s audit scope

(b) Qualifications and Experience:

Provide a brief on the company’s experience and track record in

conducting similar scope of audits and the experience and qualifications of

the team to be assigned to IBF’s project.

(c) A proposal explaining the audit approach and methodology including details of

audit planning, execution and reporting process.

(d) Timeline and deliverables including the scope of audit and schedule of work that

would be performed

(e) Audit Fees

6.2 The submission deadline for the proposal is 25 October 2018, Thursday.

6.3 All submitted proposals must include the reference: “RFP.FUN.2018.0003”.

Please submit the proposal to IBF Governance by email or mail using the following

address:

Attention: IBF Governance

Email: [email protected]

Mailing Address: 10 Shenton Way, #13-07/08, MAS Building, Singapore 079117

Please do not share your proposal with any other officer at IBF.

6.4 Any clarifications/ queries about the RFP may be addressed to:

Sai Siew Huey, Senior Manager, Funding


Tel: +65 6508 7605

Liew Hui Min, Assistant Manager, Funding


Tel: +65 6508 7606

7 NON-DISCLOSURE AGREEMENT

7.1 Interested companies will be required to sign a non-disclosure agreement (NDA) in

Annex 6 as confidential information may be provided by IBF during the RFP process.

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Annex 3.1: Overview of FTS/IBF-STS Claims Load and Claims Profile

Year 2017 Q1 Q2 Q3 Q4

Jan to Mar Apr to Jun Jul to Sep Oct to Dec

Claims Received (by claim count)

FI 274 6 212 3

Claim application <

$30k

251 6 195 3

Claim application ≥

$30k

23 - 17 -

FTP 21 10 22 24

Claims Received (by claim amount)

FI S$3,813,506.36 S$15,757.18 S$2,552,861.13 S$5,220.23

Claim application <

$30k

S$1,118,847.71 S$15,757.18 S$841,542.48 S$5,220.23


$30k

S$2,694,658.65 - S$1,711,318.65 -

FTP S$602,293.86 S$1,202,178.8

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S$894,671.37 S$1,049,026.2

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Range of claim

amount (per claim

application)

S$192.60 to

S$121,899.92

S$96.30 to

S$644,010.50

S$171.20 to

S$299,904.00

S$264.83 to

S$678,069.70

Trainee Records Profile

FI - total number

of trainees

26,329 399 8,733 143

Claim application <

$30k

12,009 399 4,029 143


$30k

14,320 - 4,704 -

FTP - total number

of trainees

363 403 314 350

Range of no. of

trainees (per claim

application)

7 to 126 1 to 305 5 to 170 2 to 266

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Annex 3.2: Overview of PCP Claims Load and Claims Profile

Year Q4 2018 to Q4 2019

Projected

Number of unique FIs submitting claims 11

Total claim amount S$17,834,000

Total number of unique trainees 1,500

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Annex 4: Checks Performed by Auditors and Internal Compliance Departments of Financial

Institutions (FIs) Before Claim Submission to IBF

1 FTS and IBF-STS Claims

Check that:

(a) Items and amounts claimed by the Company are in accordance with the FTS and IBF-STS

funding guidelines (please refer to these under Annex 1 - Info Note for FTS and IBF-STS

Training Grant Schemes);

(b) Items claimed by the Company are for Eligible Programmes within the programme validity

period;

(c) Items claimed by the Company are accurately recorded in the Funding Claims Worksheet,

and in accordance with the books and records maintained by the Company;

(d) Description and authenticity of items claimed are valid by referring to and cross-checking

against appropriate supporting documents and other records;

(e) Claims correspond to the appropriate supporting documents, e.g. in-house declaration

forms, invoices, certificates of completion, exchange rate documentation etc.;

(f) Claims are made only for expenses incurred by and invoiced to the company; and

(g) All items claimed are incurred within the qualifying period of claim as stated in the Funding

Claims Worksheet.

2 Professional Conversion Programme (PCP) Claims

Check that:

(a) Items and amounts claimed by the Company are in accordance with PCP Terms and

Conditions;

(b) Items claimed by the Company are for approved PCP Pathways;

(c) Items claimed by the Company are accurately recorded in the PCP Funding Claims

Worksheet with reference to and cross-checked against appropriate supporting

documents and other records, e.g. NRIC, payslips, certificates of completion, resignation

letters, redeployment letter, etc.

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Annex 5: Audit Timeline for FTS, IBF-STS and PCP Claims

Month/ Year Audit Deliverable

End-Dec 2018 Audit report for 1st audit on claims disbursed in Jul to Sep 2018

Mar 2019 Audit report for 2nd audit on claims disbursed in Oct to Dec 2018

Jun 2019 Audit report for 3rd audit on claims disbursed in Jan to Mar 2019

Sep 2019 Audit report for 4th audit on claims disbursed in Apr to Jun 2019

~End of document~

Annex 1 - Info Note for FTS and IBF-STS Training Grant Schemes (Updated July 2018)

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IBF Standards Training Scheme (IBF-STS) & Financial Training Scheme (FTS)

1. Overview 1.1 The Financial Training Scheme (“FTS”) and the IBF Standards Training Scheme (“IBF-STS”)

are targeted at promoting financial sector training. The FTS supports recognised training programmes while the IBF-STS supports those accredited under the IBF standards.

1.2 IBF is the Funding Administrator for both the Financial Training Scheme (“FTS”) and the

IBF Standards Training Scheme (“IBF-STS”).

Terms & Conditions IBF Standards Training Scheme (“IBF-STS”)

Financial Training Scheme (“FTS”)

Eligible Programmes Provides funding for training and assessment programmes 1 accredited under the IBF Standards.

Provides funding for financial sector-specific training programmes 2 which are recognised under FTS.

Funding Quantum Provides 70% funding for direct training costs subject to a cap of S$7,000 per participant per programme. Direct training cost would be based on the programme fee charged by the External Training Provider or apportioned basic salaries 3 of internal staff involved in developing and/or delivering IBF-STS accredited in-house programmes.

For IBF-STS programmes commencing on and after 1 July 2016, Singapore Citizens aged 40 years old and above are eligible for 90% co-funding of direct training

Provides 50% funding for direct training costs subject to a cap of S$2,000 per participant per programme. Direct training cost would be based on the programme fee charged by the External Training Provider or apportioned basic salaries3 of internal staff involved in developing and/or delivering in-house programmes.

For FTS programmes commencing on and after 1 July 2016, Singapore Citizens aged 40 years old and above are eligible for 90% co-funding of direct training costs, subject to a cap of

1 Refer to the IBF Programme Finder for eligible external accredited programmes. 2 Refer to the IBF Programme Finder for eligible external programmes. Eligibility of in-house programmes require the approval of IBF. 3 Basic salaries include the employee’s CPF contribution but exclude the employer’s CPF contribution, annual wage supplements, bonuses, allowances (fixed and variable), and overtime pay. All costs should be apportioned accordingly if training and assessment programmes involve a mix of eligible and ineligible staff.


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costs, subject to a cap of S$7,000 per participant per programme.

All ancillary expenses (e.g. freight/delivery costs, material costs, rental costs, food & refreshments, travel expenses including airfare, accommodation, cost of living allowance, etc.) and other charges (e.g. credit card charges, conversion charges, etc.) are non-qualifying expenses.

S$2,000 per participant per programme.

All ancillary expenses (e.g. freight/delivery costs, material costs, rental costs, food & refreshments, travel expenses including airfare, accommodation, cost of living allowance, etc.) and other charges (e.g. credit card charges, conversion charges, etc.) are non-qualifying expenses.

Eligible Participants Non Company-Sponsored Track

Non Company-Sponsored participants are required to be Singapore Citizens or Singapore Permanent Residents physically based in Singapore.

Company-Sponsored Track

Company-Sponsored participants are required to be Singapore Citizens or Permanent Residents, physically based in Singapore 4 . Company sponsors refer to Financial Institutions regulated by MAS (either licensed or exempted from licensing). Entities that are significantly involved in supporting financial sector activities will

Company-Sponsored Track

Company-Sponsored participants are required to be Singapore Citizens or Permanent Residents, physically based in Singapore. Company sponsors refer to Financial Institutions regulated by MAS (either licensed or exempted from licensing). Entities that are significantly involved in supporting financial sector activities will be assessed for eligibility on a case-by-case basis.

To qualify for FTS funding, trainees must successfully complete the training programme (including passing all relevant

4 Qualifying expenses incurred on the training of both executive and non-executive staff, as well as staff employed on a short-term basis of less than one year (inclusive of contract staff and interns) will be eligible for funding under IBF-STS and FTS, subject to meeting the conditions under these schemes. Licensed agents or representatives (i.e. financial advisors, traders, insurance agents, remisiers) representing a legal principal entity may be included in the claims of the principal entity.


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be assessed for eligibility on a case-by-case basis.

To qualify for IBF-STS funding, trainees must successfully complete the training programme (including passing all relevant assessments and examinations). Staff who attend a programme in the capacity of an instructor or facilitator, e.g. presenter / speaker / panelist are not eligible for IBF-STS funding.

assessments and examinations). Staff who attend a programme in the capacity of an instructor or facilitator, e.g. presenter / speaker / panelist are not eligible for FTS funding.

Non Company-Sponsored Track

Non Company-Sponsored individuals are not eligible for FTS funding.

2. Claims Submission 2.1 IBF Portal 2.1.1 All claims should be submitted vide the IBF Portal and claim applicants will be required to

create a IBF Portal Log-in account. Application for IBF Portal Log-in will require Management Representatives to be appointed to manage the IBF Portal as well as verification of the authenticity of the organisation and key persons. Please click here to apply for your Log-In account.

2.2 Non Company-Sponsored Track 2.2.1 Claims for Non Company-Sponsored participants of IBF-STS programmes shall be

submitted by the IBF-STS accredited training provider within 3 months from the date of completion of the programme.

2.2.2 IBF-STS accredited training providers are required to create an IBF Portal Log-in

Account online before submitting non-company sponsored claims via the IBF Portal. 2.2.3 To submit a claim, accredited training providers should populate and upload the FTP –

Doc [A] Funding Claims Worksheet together with all supporting documents5 including proof of successful completion of training programmes (e.g. attendance lists, certificates of completion or result slips) and proof of payment (e.g. invoices or receipts printed on the training provider’s letterhead) for each individual participant.

5 Supporting documents should indicate clearly the Name of Trainee, Name of Programme, Programme Period – Start Date to End Date, Completion Date in order for verification.

https://eservices.ibf.org.sg/CustomerManagement/SignUp


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2.2.4 Claimants are also required to upload the FTP – Doc [B] Management Declaration Form

which has been completed and signed off by the Training Provider’s authorised signatory, who should be a member of the Senior Management.

2.2.5 The processing of claims will only commence upon receipt of the online claim submission. 2.3 Company-Sponsored Track 2.3.1 Claims for IBF-STS or FTS programmes are to be compiled and submitted according to two

half-yearly claim cycles, within three calendar months from the end of each qualifying period:

(i) Claim Cycle 1: 1st July – 30th September – For programmes completed6 from January to June of the same calendar year; and

(ii) Claim Cycle 2: 1st January – 31st March – For programmes completed from July to December of the previous year.

2.3.2 Claimants are required to populate the FI – Doc [A] Funding Claims Worksheet and all

claims should be accompanied by the following supporting documents:

Total Claim Amount For the Relevant Submission Cycle

Required Supporting Document(s)

S$30,000 and above

(i) Internal audit certification; OR (ii) Compliance certification; OR (iii) External audit certification; and (iv) Signed Management Declaration Form

Less than S$30,000

(i) Internal audit certification; OR (ii) Compliance certification; OR (iii) External audit certification; OR (iv) Proof of successful completion of programme, Proof of

payment, Exchange Rate Documentation (for payment in foreign currencies), Declaration Form for In-house Developed Programmes and any other supporting documents necessary to support the claims made. and

(v) Signed Management Declaration Form

6 For programmes with an assessment component, the trainee must have passed the assessment, and for programmes without an assessment component, the trainee must have received a certificate of attendance where provided by the training provider.


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2.3.3 If the total claim amount for the relevant submission cycle is S$30,000 and above, claimants are required to engage an External Auditor or their Internal Audit/Compliance Department to certify the claims. The claims are to be certified using the FI – Doc [D] External Audit Certificate template, or the FI – Doc [C] Internal Audit Certificate template.

2.3.4 If the total claim amount for the relevant submission cycle is less than S$30,000, claimants

can either engage an External Auditor or their Internal Audit/Compliance Department to certify the claims using the FI – Doc [D] External Audit Certificate template or FI – Doc [C] Internal Audit Certificate template. Alternatively, claimants that do not have an Internal Audit/Compliance Department may upload all supporting documents which include proof of successful completion of training programmes (e.g. attendance lists, certificates of completion, result slips) and proof of payment7 (e.g. invoices, receipts printed on the training provider’s letterhead) for individual trainees.

2.3.5 Only individuals with managerial oversight and performing the independent role of

Internal Audit or Compliance can sign off on the Internal Audit/Compliance Certification. Individuals in General Management or the Finance function or individuals performing a concurrent role in Compliance and Finance/ General Management are not authorised to sign off on the Internal Audit/Compliance Certification.

2.3.6 Claimant is required to provide proof of successful completion of training programme and

proof of payment if any of the authorised signatories is/are also the trainee(s) being claimed for.

2.3.7 The terms of reference for auditors and compliance departments is set out in Annex I

below for reference. 2.3.8 Claims for expenses paid in a foreign currency other than SGD should be supported by an

exchange rate documentation, which can be in the form of a credit card statement, company finance statement or exchange rate conversion sheet for which the date (or month) of conversion matches the invoice date (or month).

2.3.9 Claimants are required to upload the FI – Doc [B] In-house Developed Programmes Form

for in-house developed programmes in-lieu of invoices. In cases where a training programme is attended by both eligible and ineligible trainees, programme fees/costs should be apportioned and be claimed for eligible trainees only. Claimants should also ensure that there are strictly no duplication of invoices/receipts submitted within the same claim and/or across different claims.

2.3.10 The computation methodology to derive per unit cost is set out in Annex II below for

reference.

7 Standalone credit card statements, course registration slips, internally generated documents (e.g. SAP documents, internal finance expense sheets) do not suffice as valid proof of payment.


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2.3.11 The FI – Doc [E] Management Declaration Form has to be signed off by a member of

management with a designation of Department Head or above. The authorised signatory for the Internal Audit/Compliance Certification is not allowed to sign off on the Management Declaration Form.

2.3.12 The processing of claims will only commence upon receipt of the duly completed online

claim submission.

3. To avoid unnecessary delays in claims processing, IBF would like to seek FIs’ co-operation to ensure that claim applications are submitted in an accurate and timely manner. Examples of errors encountered in FIs’ previous claim submissions are outlined under Annex III below. As such occurrences unduly prolonged the claim process, we would like to seek FIs’ cooperation to minimise such errors.

Contact For further clarifications on claims, please contact the IBF at [email protected].


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ANNEX I

Terms of Reference for Auditors and Internal Compliance Departments

1) Check that:

a) Items and amounts claimed by the Company are in accordance with Annex A: FTS and IBF-STS funding guidelines;

b) Items claimed by the Company are for Eligible Programmes within the programme validity

period; c) Items claimed by the Company are accurately recorded in the Funding Claims Worksheet,

and in accordance with the books and records maintained by the Company; d) Description and authenticity of items claimed are valid by referring to and cross-checking

against appropriate supporting documents and other records; e) Claims correspond to the appropriate supporting documents, e.g. in-house declaration

forms, invoices, certificates of completion, exchange rate documentation etc.; f) Claims are made only for expenses incurred by and invoiced to the company; and g) All items claimed are incurred within the qualifying period of claim as stated in the

Funding Claims Worksheet. The procedures as listed above from (a) to (g) should cover 100% of the value claimed in the

statement. The auditor shall stamp all relevant documents submitted in support of the auditor’s

statement.

2) In the event that there are errors and deviations found, the auditors shall report these in

the Audit Certification accordingly and provide details.


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ANNEX II

Computation methodology to derive per unit cost

(1) Computation of Per-Unit Cost for E-learning Programmes

The unit cost of each e-learning module per trainee should be computed by:

a. Apportioning the license fee across the total number of e-learning modules in the library that is made available to the subscriber, regardless of whether all the programmes are FTS-recognised; and

b. Apportioning the per-module fee by the total number of client-users who have access to these modules, regardless of whether they are eligible for funding.

As claims submissions are on a half-yearly cycle, training providers should apportion and invoice their license fee into a half-yearly amount.

Apart from the subscription fee and period in the invoice, training providers should also reflect information such as the total number of e-learning programmes available in the library as well as the total number of users covered by that subscription fee.

To illustrate:

Total yearly subscription fee = $20,000

Half-yearly license fee = $10,000

Total no. of e-learning programmes in library at point of purchase = 10

Unit cost of each e-learning module = $10,000 / 10 = $1000 per e-learning module

Number of staff with access to e-learning programmes = 10

Unit cost of e-learning module per trainee = $100


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(2) Computation of Per-Unit Cost for Classroom training

The computation of per unit cost should be based on the number of registered participants or actual attendance, whichever is greater.

Absentees/ No show should not be excluded from the per unit computation.

Illustration 1:

Lump sum fee charged by training provider = $10,000

Total registered participants = 10 pax

Actual attendance = 12 pax

Unit cost = $ (10,000 / 12 pax) = $833.33

Illustration 2:

Lump sum fee charged by training provider = $10,000

Total registered participants = 10 pax

Number of absentee/ no show = 2 pax

Unit cost = $ (10,000 / 10 pax) = $1000


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ANNEX III - Examples of errors encountered in FIs’ previous claim submissions

1) The signatory on the MDF submitted by FI did not meet the requirement of having a seniority level of ‘management with a designation of Department Head or above’. Examples of authorised signatories include but are not limited to ‘Chief Executive Officer’, ‘Chief Operating Officer’, ‘Chief Financial Officer’, ‘Head of Human Resource Department’.

2) The signatory on the internal audit/ compliance certification does not meet the following requirements:

a) Only individuals with managerial oversight and performing the independent role of Internal Audit or Compliance can sign off on the Internal Audit/Compliance Certification. Individuals in General Management or the Finance function or individuals performing a concurrent role in Compliance and Finance/ General Management are not authorised to sign off on the Internal Audit/Compliance Certification.

3) Proof of successful programme completion and proof of payment were not submitted for

the signatories (on the MDF and/or internal audit/ compliance certification) who were also the trainee(s) being claimed for.

4) Wrong set of supporting documents (e.g. programme invoices) were submitted.

5) FI had used the wrong version of Management Declaration Form (MDF).

6) Data entry/administrative errors such as:

a) Wrong grant amount(s) indicated on the internal audit/ compliance/ external audit certification.

b) Name of organisation indicated on the FI’s or FTP’s MDF does not match the organisation’s name indicated in the IBF portal.

Annex 2 - Terms and Conditions for PCP

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INDUSTRY PROFESSIONAL CONVERSION PROGRAMME TERMS AND CONDITIONS

1. Overview

1.1 The Professional Conversion Programme (PCP) is part of the Adapt and Grow initiative offered by

Workforce Singapore Agency (WSG) to support Professionals, Managers, Executives and

Technicians (PMETs) in their re-skilling for jobs in growth sectors.

1.2 The Institute of Banking and Finance Singapore (IBF) is the appointed Programme Manager, to

administer PCPs for the Financial Services industry. IBF will work with financial institutions

(hereinafter referred to as “the company”) to systematically and proactively identify and re-skill (i)

existing PMETS who are currently in jobs that are at risk of redundancy as well as (ii) mid-career

new hires (hereinafter both referred to as “the trainee”), to move them into new or emerging job

functions.

1.3 There are two modes of PCPs:

Industry PCP – industry-standardised training programmes for identified job functions;

and

Company-specific PCP – customised training programmes, specific to individual company

1.4 IBF will develop PCP archetypes for the two modes based on discussion with the industry and

companies. Companies can leverage on industry PCP archetypes to develop their own company-

specific PCPs. IBF will also ensure quality of training programmes through the accreditation of the

programmes.

2 Eligibility of Participants

2.1 To be eligible for PCP, the trainee and company are required to fulfil the following criteria:

Trainee:

Singapore Citizen or Permanent Resident

Minimum 21 years old

Mid-career individuals1

New hires if they are to be deployed in a growth or emerging job role, which they possess no

prior/relevant experience

Existing employees whose current job roles are at risk of redundancy

1 Mid-career individuals refer to individuals who have graduated from school or completed National Service (whichever is later

and where relevant) for at least 2 years


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Company:

Registered or incorporated in Singapore

Able to offer employment2 directly related to the job which the PCP is for, with remuneration

that is aligned to market rate

Committed to the PCP training arrangements for the selected trainees (refer to Section 3)

Trainees are to be redeployed into the new role within 6 months from the end of PCP

3 PCP Structure

3.1 The PCP shall comprise the following components and fulfil the corresponding conditions:

Structured Training

External and in-house training may be included

Unless otherwise agreed, the PCP shall constitute at least 30% structured non-OJT duration

It is strongly encouraged that the structured training comprises IBF accredited programmes or programmes recognised by other agencies (e.g. Singapore Workforce Skills Qualifications under SkillsFuture Singapore and Skills Framework for ICT under Infocomm Media Development Authority)

Training outcome shall be aligned to the skills identified by the industry in the PCP archetypes or otherwise justified

Structured On-the-Job Training (OJT)

The OJT shall be designed to allow the trainee to apply the new skills required in the roles that he/she will be deployed to upon completion of the training

A mentor/supervisor shall be assigned to the trainee to provide guidance and sign-off on the satisfactory completion of the OJT

4 PCP Duration

4.1 The duration of salary support for new hires on industry PCPs may range from a minimum of 3

months (480 hours) to 12 months (1920 hours).

4.2 The duration of salary support for re-deployment of existing staff or new hires on company-specific PCPs may range from a minimum of 3 months (480 hours) to 6 months (960 hours).

4.3 However, trainees have up to 12 months from the commencement of the structured training or OJT (whichever is earlier) till the end of the OJT or structured training (whichever is later) to complete the PCP. They have another 6 months from the completion of PCP to be re-deployed into the new role.

2 Permanent full-time employment or full-time employment with a minimum contract of 1-year.


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5 Funding Support

5.1 The following course fee grant and salary funding support will be provided to the companies through IBF for PCPs: Table 1: Funding Support for PCPs

Funding to Employers Tier 1: Course Fee Grant for Structured Training Programmes Accredited by IBF

Salary Support

Standard Rate 70% of course fee (capped at $7000) for programmes accredited under the IBF-Standards Training Scheme (IBF-STS) 50% of course fee (capped at $2000) for programmes recognised under the Financial Training Scheme (FTS)

Up to 70% of monthly salary3 (capped at $4000 per month)

Enhanced Rate

90% of course fee (capped at $7000) for programmes accredited under IBF-STS 90% of course fee (capped at $2000) for programmes recognised under the FTS [For Singapore Citizens aged 40 and above4] Note: Prevailing funding rate for schemes offered by other agencies may also apply for programmes not accredited by IBF.

Up to 90% of monthly salary2 (capped at $6000 per month) [For Singapore Citizens who are Long-term Unemployed5 or aged 40 and above3]

Funding to Employers Tier 2: Course Fee Grant for Structured Training not Accredited by any Agency

Salary Support

Rate for In-house Programmes

$15 per hour (Capped at $300 / pax) Salary support rates aligned to Tier 1

5.2 To qualify for Tier 1 funding support, the company has to ensure that the programmes attain

accreditation status from IBF or the respective agencies before the commencement of the training.

5.3 The lowest monthly salary paid to the trainee within the PCP duration, commencing from the date of structured training or OJT (whichever is earlier), shall be used to compute the qualifying salary support.

3 Monthly salary refers to “Basic Pay’’ based on lowest monthly salary paid to the trainee during the PCP duration, commencing from the date of structured training or OJT (whichever is earlier) 4 Refers to age forty (40) years and above at the point of PCP commencement 5 Defined as being unemployed and actively seeking employment for six months or more


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5.4 The company is to inform IBF in the event that a trainee resigns or withdraws from the PCP. The qualifying salary support for trainees who resign is set out in the following table: Table 2: Pro-ration of Salary Support

PCP Type for: Time of Resignation Eligible Salary Support

New hires Before commencement of training/OJT

Not eligible

After commencement of training/OJT Pro-rated based on the duration of training completed

Re-deployment of Existing Employees

Before re-deployment but during or after OJT

Not eligible

After re-deployment but before OJT / Structured Training (whichever is earlier)

Not eligible

After re-deployment but during or after OJT / Structured Training (whichever is earlier)

Pro-rated / full salary support based on the duration of OJT post re-deployment

6 PCP Plan and Pathways

6.1 To participate in the PCP, the company shall submit the PCP Plan Template to IBF for approval before the commencement of the PCP. The plan will reflect the proposed conversion pathways and shall include (but is not limited to) the following:

Job descriptions of both the current and future roles and the change involved;

Skills to be acquired through structured and on-the-job training;

Training programmes and their duration;

Number of trainees and their estimated salary range; and

PCP duration and expected commencement and re-deployment date. 6.2 With IBF’s approval of the PCP Plan, the company can commence on PCP and shall submit trainee

details via Section 1 of the PCP Trainee Level Detail and Claims Template to IBF by the 15th of each month, to reflect trainees who have commenced their PCP in the previous month. The trainees shall be tagged to the respective conversion pathways set out in the PCP Plan Template.

7 Claims Submission Process

7.1 The claims for salary support and non-accredited course fee grant shall be submitted to IBF within 6 months from the end of the quarter within the calendar year in which the trainees completed PCP or have been re-deployed (whichever is later), in the format and with the following supporting documents as required by IBF:

(i) PCP Plan Template (pre-approved); (ii) PCP Trainee Level Detail and Claims Template, including evidence of skills acquired, for

example, successful completion of tasks assigned during on-the-job training; (iii) Management Declaration Form; and (iv) Full supporting documents, Internal Audit, Compliance or External Audit Certificate (refer to

para 7.2 for requirements)


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7.2 Funding claims exceeding or equivalent to $30,000 must be certified by one of the following:

An external auditor appointed by the company; or

Company’s internal audit function; or

Company’s compliance function (in the absence of an internal audit function).

7.3 For funding claims below $30,000, claimants have the following options:

Full supporting documents upload; or

Certification through:

An external auditor appointed by the company; or

Company’s internal audit function; or

Company’s compliance function (in the absence of an internal audit function).

7.4 Funding claims for Tier 1 course fee grant shall be submitted by the company based on the IBF-

STS and FTS funding claims guidelines and processes set out in the “Training Incentive: Information Note” document that can be accessed via IBF’s website.

7.5 Programmes that are not accredited are eligible for Tier 2 course fee grant (refer to table 1). The company may submit claims for the course fee grant via the PCP claims process.

7.6 IBF shall review the claims and disburse the funds directly to the company based on the bank account information that have been provided to IBF via the IBF Portal.

8 Outcomes

8.1 The company shall conduct the necessary survey and report to IBF on the achievement of the

following desired outcomes:

a) Successful completion of training, with:

at least 80% of trainees rated training as satisfactory (on a scale of 4 out of 5); and

at least 90% of trainees applied skills acquired from the training.

b) Successful redeployment, with:

at least 90% of trainees retained for at least 6 months in their new role after completion of the PCP

8.2 Where the above desired outcomes are not achieved, the company shall provide reasons to IBF.

9 Data Collection and Sharing

9.1 The company shall assist IBF and / or WSG to furnish information relating to the PCP for the purposes of (i) assessing the effectiveness of the PCP initiatives, (ii) promotion of PCP or (iii) any related industry surveys.


Page 6 of 11

9.2 Before disclosing personal data of the trainees to the IBF, the company shall undertake to acquire all necessary consents from the trainees for the collection, use and/or disclosure of their personal data for the purposes of processing of the PCP grant. The company agree to bear all liability and shall fully indemnify the IBF against any and all actions, claims, proceedings, costs, damages, legal costs and/or other expenses (including the costs of complying with directions and paying financial penalties that may be imposed by the Personal Data Protection Commission) arising out of the company’s breach of this undertaking.

9.3 IBF may share the personal data collected with the relevant governmental and / or regulatory authorities in Singapore, for the purposes stated in Para 7 of the PDPA policy found in Annex B and on IBF’s website.

10 Audit Requirements

10.1 IBF, WSG, their appointed auditor and / or authorised representatives may contact the company or any trainee to obtain information for the purposes of conducting audits or effectiveness survey in relation to PCP.

10.2 The company and trainees shall provide cooperation and assistance to IBF, WSG, and their appointed auditor and / or authorised representatives to conduct audits on PCP at any point of time during or after the PCP period upon request.

10.3 The company and trainees will assist IBF, WSG, its appointed auditor and / or authorised representative in fulfilling all audit and governance requirements, in a timely manner as well as giving access to examine, audit, excerpt, and transcribe any pertinent materials relating to PCP, based on the scope as determined by IBF and WSG.

10.4 The company is to maintain proper records of all training and expenditure details for PCP, including trainee particulars, training attendance records, assessment / performance records, employment details including names of trainees and job titles, payment receipts and invoices. All records and supporting documents pertaining to PCP (as set out in Annex A) must be retained for audit purposes for three years after the end of the funding period, or final disbursement date, whichever is later.

10.5 All WSG grants supported under this Terms and Conditions are subject to the Income Tax Act payable at the rate or rates specified for each year of assessment as stipulated by the Inland Revenue Authority of Singapore (“IRAS”).

11 Other Terms and Conditions

11.1 WSG and IBF reserve the right to revise the terms and conditions and funding parameters of the scheme at any point of time. In the event of any such changes, IBF will inform the company in a timely manner.

11.2 The parties to this Terms and Conditions are the company and IBF. IBF shall not be liable for any disputes involving the trainee(s) and/or company or any third parties contracted by the company for the purpose of participating in the PCP.


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12 Breach of Any Terms

12.1 In the event that the company breaches any of the terms, IBF reserves the right to:

a) withdraw the company from participating in PCP;

b) withhold any or any further disbursement of the PCP funding support to the company; and/or

c) reclaim part or all of the PCP funding support.


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ANNEX A

List of Documents Required for Audit (Only upon audit and where applicable)

S/N Item

1 PCP Plan Template and Trainee Level Detail and Claims Form

2 Photocopies of trainees’ NRIC/ Passport or the declaration from company’s human resource personnel on the trainees’ nationalities for company sponsored trainees

3 New entrant trainees’ curriculum vitaes

4 Letters from employer indicating employer commitment and sponsorship of new entrant trainees

5 Management Declaration Form

6 Trainees' transcripts

7 Graduation certificates

8 Letter-of-undertaking signed by trainees

10 General ledger for Grant and Income accounts recording course fees collectable from IBF

11 Details for course fees, course structure, course coverage and course duration

12 Relevant certification/record on completion of non-accredited in-house training

13 Assessment records

14 Attendance records

15 Evaluation/ feedback form from participants (completed during the course)

16 Survey form

17 Supporting documents of salary support disbursements to trainees

18 NS portal screenshot to show the ORD date

19 CPF transaction statement to show there has been no CPF contribution in the last 15 months

20 Trainees’ Payslips/CPF 90 for duration of PCP

21 Employment contract stating trainee’s redeployed position

22 Resignation letter for trainees who resign during PCP period

23 PCP External Audit Certification

24 PCP Internal Audit / compliance Certification


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ANNEX B

THE INSTITUTE OF BANKING & FINANCE

PERSONAL DATA PROTECTION POLICY

This Policy statement was last updated on 9 Oct 2014. The Institute of Banking & Finance ("we", "our", "us" or "IBF") is committed to respecting and protecting your personal data. This Personal Data Protection Policy ("Policy") sets out the basis on which we collect, use, disclose, store and/or process your personal data. It applies to personal data in our possession or under our control. Please read the following carefully to understand our practices regarding your personal data and how we handle it. By continuing to visit and use this website, you confirm that you understand and consent to the terms of this Policy.

COLLECTION OF INFORMATION

PERSONAL DATA

1. We collect various types of personal data. As used in this Policy, "personal data" means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we (and all our affiliates, partners, subsidiaries and all relevant third parties mentioned in this Policy) have or are likely to have access. Personal data includes, without limitation, an individual's name; address; telephone numbers; email addresses; date of birth; gender; nationality; marital status; passport number, date and place of issue; personal identification number; driver's licence number and expiration; photographs and other audio-visual material; employment information; payment information; credit and debit card numbers; marketing preferences; preferred communication methods; and any other types of information that you choose to provide to us or that we may collect about you through your interactions with us and our affiliates, partners and subsidiaries.

2. We may collect personal data by way of the information that you provide to us on our website or by any other means. We may also collect your personal data from our partners and other independent third-party sources (e.g. management representatives of financial institutions, IBF-accredited training providers).

COOKIES AND OTHER WEBSITE FUNCTIONALITIES

3. We may automatically collect the following information about you in connection with your visit(s) to our website:

o technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

o information about your visit, including the full Uniform Resource Locators (URL) visited; date and time of visit; products or services you viewed or searched for; page response times; download errors; length of visits to certain pages; page-interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

4. When you visit our website, we may assign your computer (or any other device) with cookies (which are small text files created on your computer or device), Local Shared Objects (also known as flash cookies, which can store data more complex than simple text) and Web Beacons (tiny graphics with a unique identifier that are placed in the code of a webpage) (collectively, "Cookies"). By accessing our website, you agree that we can place Cookies on your computer or device.


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5. The Cookies that we place on your computer or device may be used to facilitate your access to our website, gather statistical data, and personalise your online experience. We currently use Cookies on our website for purposes including, but not limited to, detecting your web browser's multimedia capabilities, recognising you as a previous visitor and saving your website user preferences, maintaining login and password details on secure portions of the website, monitoring the traffic patterns of our website users, tracking which emails have been opened by you, and providing a unique identifier to your computer so that we can generate statistics regarding website usage.

6. You have the option of adjusting your browser settings to restrict or limit the use of various Cookies. However, if you choose to do so, the functionality of the website and your user experience may be affected.

USE OF PERSONAL DATA COLLECTED

7. We currently use and/or may in the future use your personal data for any purpose not prohibited by applicable law. This includes, but is not limited to, the following purposes:

o to verify your identity; o to manage the online account that you may have set up with us; o to communicate with you and to process and respond to your questions and comments; o to process and review any applications that you may submit to us; o to contact you regarding any industry engagements; o to inform and invite you to upcoming IBF events; o to provide you with and allow you and other relevant third parties to verify information regarding

any records you may hold with IBF (e.g. training, funding, examination records, amongst others); o to suggest training and other competency programmes which may be of interest to you; o to perform data analytics for management reporting and generation of customised reports; o to register you for examinations and to carry out all functions necessary to enable you to sit for

such examinations; o to prepare aggregated examination and industry reports which may be disclosed, where

necessary, to relevant examination boards, industry workgroups, and regulators; o to evaluate your eligibility and determine the quantum of any training grants that may be granted; o to process and evaluate job applications that you may send to us; o to keep you updated on latest developments at IBF; o to comply with a court order or other legal process or other statutory and/or regulatory

requirements of any governmental and/or regulatory authorities; o in exceptional circumstances, such as a national emergency, security concern, or other situation in

which we in our sole discretion deem to be prudent; and o any other purpose permitted by applicable law, or as may be described to you from time to time

at the point of collection of your personal data.

(collectively, "Purposes")

SHARING OF PERSONAL DATA

8. We may share your personal data (including your name, the organisation that you belong to, photographs, examination results, certification status and CPD status), with and among other affiliates, partners and subsidiaries, or with unaffiliated third parties including our third-party service providers, prospective and/or current employers, and the relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned Purposes. Some of your personal data may also be posted on our website. Please contact our Data Protection Officer at the address indicated below if you wish to have your personal data removed from our website.


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TRANSFERS OF PERSONAL DATA OUTSIDE SINGAPORE

9. In situations where we transfer your personal data to countries outside of Singapore, we will take steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal data are in place.

WITHDRAWAL OF CONSENT

10. If you do not want your personal data to be collected, used, and/or disclosed by us in the aforementioned manner, you may withdraw your consent by writing to our Data Protection Officer at the address indicated below. Please note that we may not be able to continue to provide you with services, in the event that you choose to withdraw your consent.

ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA

11. If you wish to access or correct any of your personal data, please contact our Data Protection Officer at the address indicated below. Please note that a fee may be payable on access requests made.

RETENTION OF PERSONAL DATA

12. Personal data may be retained by us for as long as the purpose for which the personal data was collected continues, or if the retention is necessary for our legal or business purposes, even in circumstances where you have closed your account with us. We will cease to retain personal data once we have no reason for doing so.

DATA SECURITY

13. We take reasonable care and have implemented technical, procedural and other measures to protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss.

CHANGES TO POLICY

14. We may update this Policy from time to time without prior notice by posting a new version on this website. You should check this page regularly to ensure that you are familiar with any changes.

15. Your continued use of our website and continued dealings with us for the provision of our products and services, after any changes to this Policy has been made, constitutes your acceptance to such changes.

CONTACT US

16. If you have any questions in relation to how your personal data is handled by us, please contact our Data Protection Officer at [email protected].

mailto:[email protected]

Annex 6 - Non-Disclosure and Security Awareness Undertaking

1

Non-Disclosure and Security Awareness Undertaking (Third Parties)

IMPORTANT NOTES 1. The Institute of Banking and Finance (“the Organisation”) is legally required to comply with

the provisions of the Personal Data Protection Act (No. 26 of 2012) (“the Act”). Failure to comply with the Act may result in penalties being issued against the Organisation.

2. To ensure compliance with the Organisation’s internal policies in relation to the Act, all third party contractors and/or service providers are required to sign this Undertaking.

3. This Undertaking shall be signed before the commencement of work and/or services for

the Organisation.

A. CONTRACTOR / SERVICE PROVIDER’S DETAILS

1. Name of Contractor / Service Provider’s Company (“Service Provider”):

2. Company UEN No:

3. Contact Number:

4. Address:

5. Email Address:

6. Nature of Work / Service provided to Organisation (“Purpose”):

B. UNDERTAKING

1. Access to Personal Data, non-public and sensitive information (“Confidential Information”) may be required in the performance of the Service Provider’s Purpose. “Personal Data” shall have the meaning given to it in the Act, and refers to information about an identified or identifiable individual, where the individual refers to a natural person, whether living or deceased. It covers all forms of personal data, whether in electronic or non-electronic form. 2. Should the Service Provider have access to such Confidential Information, the Service Provider undertakes that it shall not under any circumstances, release or disclose such Confidential Information to any third party or third party organisation. The Service Provider shall protect such Confidential Information and will employ all reasonable efforts to maintain the confidentiality of such Confidential Information. 3. The Service Provider shall implement such security measures as are reasonably necessary to protect the Confidential Information against unauthorised access, collection, use, disclosure, copying, modification, disposal or any other form of processing (as defined under the Act). 4. The Service Provider shall immediately notify the Organisation of any suspected or confirmed unauthorized access, collection, use, disclosure, copying, modification, disposal or any other form of processing (as defined under the Act) and/or misuse of Confidential Information. Without prejudice to any other rights and remedies that the Organisation may have, the Service Provider shall at its own

Annex 6 - Non-Disclosure and Security Awareness Undertaking

2

expense render all necessary assistance to the Organisation to investigate, remedy and/or otherwise respond to such unauthorised access, collection, use, disclosure, copying, modification, disposal or any other form of processing (as defined under the Act). 5. The Service Provider shall immediately inform the Organisation if any Confidential Information is lost or destroyed or becomes damaged, corrupted or unusable. Without prejudice to any other rights and remedies that the Organisation may have, the Service Provider shall restore such Confidential Information at its own expense. 6. Before the Service Provider discloses Personal Data of any third party individuals to the Organisation, the Service Provider undertakes to obtain all necessary consents required under the Act for the Organisation to collect, use and/or disclose such personal data.

7. The Service Provider undertakes to comply with any and all obligations that apply to it under the Act and all subsidiary regulations that may be enacted from time to time under the Act. C. CONSEQUENCES OF BREACH OF UNDERTAKING The Service Provider acknowledges that: 1. In the event of any breach or neglect of its obligations under this Undertaking, the Organisation may exercise its right to refuse the Service Provider access to the Organisation’s premises and facilities. 2. If the Service Provider should breach any provisions of this Undertaking, the Organisation may suffer immediate and irrevocable harm for which damages may not be an adequate remedy. Hence, in addition to any other remedy that may be available in law, the Organisation is entitled to injunctive relief to prevent a breach of this Undertaking. 3. Without prejudice to any other clause(s) in this Undertaking, the Service Provider shall bear all liability and shall fully indemnify the Organisation against any and all actions, claims, proceedings (including proceedings before the Personal Data Protection Commission (“PDPC”)), costs (including costs of complying with any remedial directions and/or financial penalties that may be imposed by the PDPC on the Organisation), damages, legal costs and/or other expenses incurred by the Organisation or for which the Organisation may become liable due to any failure by the Service Provider or its employees or agents to comply with any of its obligations under this Undertaking. 4. Even after the Service Provider ceases its Purpose at the Organisation, it agrees that the obligations herein shall continue. Name of Service Provider:

_________________________________

Service Provider’s Company Stamp:

_________________________________

Name of Representative of Service Provider:

_________________________________

Signature of Representative of Service Provider:

_________________________________

Date:

_________________________________