Ong Ye Kung
Singapore
“The Ministry of Health (MOH) recently enhanced the Community Health Assist Scheme (CHAS) dental subsidies, which are tiered by income, for common preventive and restorative procedures.”
“Healthier SG GP clinics may also refer their enrolled patients to Active Ageing Centres and Community Health Posts to fulfill their social prescriptions and for subsidised services, such as medication management.”
“Public hospitals, such as the National University Hospital, the Singapore General Hospital and Tan Tock Seng Hospital, have deployed robotic-assisted surgical (RAS) systems for minimally invasive soft-tissue surgeries.”
“The Health Sciences Authority (HSA) welcomes drug producers to choose Singapore as part of their first-wave filings. As long as a pharmaceutical product is approved by at least one regulatory agency, such as China's National Medical Products Administration (NMPA), it would also qualify for the abridged route.”
“A decrease in estimated glomerular filtration rate in patients with diabetes can be due to multiple reasons. Doctors will first investigate the underlying cause before determining whether the patient should be referred to a specialist. Some causes are reversible and cause transient reduction in renal function.”
“Information on the Lasting Power of Attorney (LPA) cannot be made visible on the National Electronic Health Record system as it is protected under the Mental Capacity Act. Such information may only be disclosed by the Public Guardian to specified persons upon satisfactory submission of evidence(s) required under the law.”
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“Over the last two years, the Land Transport Authority (LTA) has more than tripled its enforcement resources to more than 200 enforcement officers deployed against errant active mobility riders. Today, LTA conducts daily operations on public paths, including enforcement against cyclists who ride recklessly on footpaths, and works with the National Parks Board to conduct targeted enforcement at parks and park connectors. Since 2019, LTA has taken enforcement action against more than 720 errant cyclists. With close to 6,000 km of footpaths and cycling paths island-wide, enforcement will always be a challenge. LTA has been harnessing technology such as the use of mobile CCTVs and the public reporting function in the MyTransport.SG mobile app to augment its enforcement presence. LTA will also step up public education to foster a safe riding culture.”
“Bunker tanker crew are no longer required to board ships to service them during refuelling operations. Fourth, shore-based personnel such as surveyors, cargo officers and marine pilots who need to go on board ships must now undergo rostered routine testing (RRT) every seven days, instead of every 14 days previously. Fifth, we implemented SafeEntry@Sea for shore-based personnel. They are required to produce a valid negative COVID-19 test result from a RRT programme or an ad-hoc test within 72 hours before going on board ships. Sixth, agencies are stepping up checks, and firm actions will be taken against companies and individuals for non-compliance. Persons found guilty of an offence will be liable, on first conviction, to a fine not exceeding $10,000, or to imprisonment for a term not exceeding three months, or both, under the Maritime and Port Authority of Singapore (Port) Regulations. Finally, we have started vaccinating 17,000 frontline maritime personnel, including all those who need to board ships. This is the most significant step to secure our maritime border. 95% of eligible personnel have registered for vaccinations, and as of yesterday, more than 13,000 maritime personnel have received their first dose of the COVID-19 vaccine. We should substantially complete the vaccination exercise by end February 2021.”
“Subsequently, 11 of 12 other crew members who worked on board "NewOcean 6" and one Singaporean shore-based cargo officer who had boarded the vessel also tested positive for COVID-19, between 2 and 14 January 2021. By then, all of them were already contact traced and under quarantine. As a result, there were no other community infection cases linked to this cluster. Our safety measures are effective and have worked well, but they cannot fully eliminate all possible risks. Given the worsening COVID-19 situation globally, including the emergence of more infectious strains of the virus and odd cases with long incubation periods, cases like the "NewOcean 6" crew have slipped through. MPA has therefore reviewed and enhanced its measures, to reduce the risk of COVID-19 transmission to harbour craft crew and shore-based personnel who board vessels for work. First, instead of 14-day SHN in their home country, we will require incoming harbour craft crew to serve 5-day SHN in their country of origin and be tested negative for COVID-19, before travelling to Singapore. They will be tested on-arrival, and undergo another 14-day SHN here. The crew member will only be allowed to board a vessel to work, if he tests negative for COVID-19 at the end of his 14-day SHN. Second, as a precaution, we are testing all crew on board harbour craft in our port waters that have conducted crew change since 17 December 2020. We expect to complete this exercise by mid-February 2021. This is similar to the previous exercise where MPA tested 27,000 shore-based personnel who board ships for work in January 2021, where we detected one individual who tested both PCR and serology-positive, and was assessed to be a recovered patient. Third, we introduced "contactless bunkering operations" in our port.”
“As a global maritime hub, many ships call at Singapore. They ensure that we get our supplies, and sustain a vibrant maritime industry of some 170,000 jobs. On average, more than 200 ships call at Singapore daily and conduct cargo operations and other activities such as refuelling and resupplying. Harbour craft such as bunker tankers and launches provide essential marine services in our port, and are manned by crew who work and live on board the vessels. The Maritime Port Authority of Singapore (MPA), together with its industry stakeholders, developed a safe way for crew change – through tests, quarantine and 'bubble wrap' movement while in Singapore. In summary, the old crew will disembark, segregated from everyone else, and are then taken to the airport and fly home. The new crew, typically from neighbouring countries, would have to serve a 14-day Stay-Home Notice (SHN) in their home country and be tested negative for COVID-19, before coming to Singapore. Upon arrival here, they will be tested again, and are segregated or 'bubble wrapped', until their test results are known. Once they test negative for COVID-19, they will board the harbour craft for work. The crew stay on board the vessels and do not come ashore. It is in this context that the "NewOcean 6" imported case occurred. An Indonesian crew member did his 14-day SHN at a dedicated facility in his home country, was tested negative twice pre-departure, before he came to Singapore on 17 December 2020. He tested negative again upon arrival, and then boarded "NewOcean 6" and started work. But shortly after, he developed symptoms. On 30 December 2020, he tested positive for COVID-19.”
“COVID-19 has unfortunately affected the progress of the construction of the JRL, because of manpower crunch, disruption to supplies and the need for strict safe management measures at work sites. The estimated delay is about a year, which means that JRL will now open in phases from 2027 to 2029. It is however not practical to rush the project, especially given that JRL is a complex project that will interface with three existing MRT stations and is built in close proximity with existing buildings and within road corridors. I would like to assure the Member that LTA and its contractors are already doing their best to expedite the JRL project, but in a way that does not compromise safety.”
“The Civil Aviation Authority of Singapore (CAAS) will only allow the Boeing 737 MAX to return to service when it has assessed that it is safe to do so. The review of the airworthiness of the aircraft is in progress. As part of this review, CAAS will consider the US Federal Aviation Administration (FAA)'s approved changes to the aircraft flight control system and pilot training regime, as well as the requirements by other regulators, such as the European Union Aviation Safety Agency (EASA).”
“Being a motorised mode of transport on public paths, registered PMDs need to be subject to mandatory inspections for safety. The inspections help to ensure that all registered PMDs comply with the weight, width and speed limits, and the UL2272 standard for fire safety. Inspections are necessary throughout the lifespan of all PMDs, to ensure that they have not been illegally modified and remain safe to be used. To provide ease of accessibility, LTA has set up inspection centres at nine locations islandwide. Besides inspections, LTA enforces against the use of non-compliant PMDs on public paths and roads. Members of public can also provide feedback on non-compliant PMDs through LTA’s MyTransport.SG mobile application. LTA is also exploring the use of CCTVs to extend its enforcement reach. These efforts have contributed to LTA’s detection of 760 cases of non-compliant PMDs being ridden on public paths from January to November 2020. Those found guilty may be fined up to $10,000 and/or imprisoned for up to six months.”
“Over the past year, LTA rolled out public education campaigns to educate users on the safe usage of footpaths and cycling paths. This complements existing efforts such as community and school engagements and the Safe Riding Programme, which educate active mobility users on safe riding practices, proper use of active mobility infrastructure, rules and code of conduct. Over 82,000 participants have attended the Safe Riding Programme since 2018. We will continue to carry out such public education efforts, with the support of our Active Mobility volunteers. These efforts have helped reduce the number of public path accidents between pedestrians and active mobility users, which fell by almost half over the past year.”
“Air crew of Singapore-based airlines are subjected to stringent COVID-19 preventive measures. For example, while serving on board, they will wear masks and face shields, and refrain from interacting with passengers. Where it is necessary to stay over at the overseas destination, they take dedicated transport to their hotels, wear location trackers and must remain in their hotel room until their departure flight. In addition, all air crew of Singapore-based airlines who are returning from higher-risk countries and regions must undergo a COVID-19 Polymerase Chain Reaction (PCR) swab test when they are back in Singapore. In light of the recent COVID-19 cases involving SIA air crew, we have enhanced the measures, such as more frequent testing for air crew who have layovers in higher risk countries after they have returned to Singapore and requiring them to self-isolate for a few days. We are also exploring including air crew as a priority group for vaccinations. This treatment is consistent with those of frontline workers like doctors and nurses, who do not have to serve stay-at-home notices (SHNs) after performing their duties in view of the preventive measures taken to protect them while they are on duty. If foreign-based airlines can comply with these preventive measures, their air crew will be subject to the same rules. If not, they will have to serve SHNs for the duration of their stay in Singapore, regardless of which countries they flew in from.”
“The quota premium is dependent on supply and demand for Certificates of Entitlement (COEs). As the Vehicle Growth Rate for motorcycles has been 0% per annum since 2018, the supply of Category D COEs depends on the number of motorcycles deregistered in the preceding months. Based on the current distribution rule, the COEs from deregistration in a particular month are recycled for bidding over the next quarter. For the last six months, bidding was disrupted from April to June 2020 due to COVID-19. To even out the supply of COEs, LTA therefore made an adjustment to the distribution rule, by returning one-third of the COEs accumulated to the bidding exercises from July to September 2020, and distributing the rest from October 2020 to June 2021. Over the last six bidding exercises, Category D COE Quota Premiums (QPs) have held quite steady at around $7,250 to $7,700, although higher than pre-COVID-19 levels. For the temporary COEs secured in July 2020, which have a six-month validity, close to 90% have already been used to register a motorcycle as of 1 December 2020, which suggests that these are genuine demand and not speculative or manipulative bidding. We are mindful that many lower income Singaporeans require a motorcycle to go about their work. That is why the bid deposit is set lower at $200 for Category D COEs. If we raise the $200 bid deposit, this will raise costs for dealers, which may mean higher prices for buyers. Motorcycles are also subject to much lower Additional Registration Fees, road tax and Electronic Road Pricing charges compared to cars.”
“In the last three quarters of 2020, 13,637 Certificates of Entitlement (COEs) were renewed for five years and 13,281 COEs were renewed for 10 years. If we allow COEs to be renewed for five years more than once, then there will be fewer COEs being recycled for bidding, and this will tilt the current balance in addressing the needs of existing and prospective car owners. It is a balance that we must continue to strike carefully. The current rule of a single five-year renewal came about because when the system was first implemented, all COEs were meant to be valid for 10 years. But there were existing owners who felt that their vehicles may not last another 10 years, so an exception was made to provide a one-off five-year renewal option, on the condition that their vehicles must be deregistered at the end of five years. Most owners have de-registered their vehicles as required but understandably, some owners feel differently after five years. Allowing this group of owners to renew their COEs for another five years means allowing them to pay for a 10-year COE in two instalments, which is also unfair to those who decided to pay the entire amount upfront. Taking all these factors into consideration, LTA has preferred to keep to the existing rule.”
“In 2006, we launched the Contactless e-Purse Application Standard (CEPAS) technology for smart cards. CEPAS is an open standard, allowing any card issuer to participate, and both EZ-Link and NETS have been issuing CEPAS cards. In 2009, the in-vehicle unit (IUs) for Electronic Road Pricing (ERP) was also upgraded to be compatible with CEPAS cards. 85% of the vehicle population today use this IU. The remaining 15% either have no IUs or use the 1st generation IUs which can only use the NETS CashCard. For these motorists, they can continue to use the NETS CashCard, opt to upgrade their IUs, or sign up for electronic payment of ERP charges using their credit or debit cards. As for carpark acceptance, all publicly-owned carparks by URA and HDB that adopt the Electronic Parking System (EPS) can accept both EZ-Link and NETS issued CEPAS cards. As for the remaining carparks, the owners decide which payment modes to accept, taking into account factors such as cost of upgrading the carpark system and motorist experience. So there is a proportion of carparks that accepts only CEPAS cards issued by NETS. There are about 460 of them, out of 3,300 carparks that have implemented EPS. Today, the maximum stored value in EZ-Link cards is $500. The determination of this quantum is a business decision by EZ-Link. A high stored value can expose both the user and the issuer to high risks. On average, EZ-Link cardholders top up around $20 per transaction on their cards. Cardholders who make frequent transactions on their EZ-Link cards can register for EZ-Link’s free automatic top-up service using any Mastercard or Visa cards.”
“We have about 1,800 Electric Vehicle (EV) charging points today, and we plan to increase this to 28,000 by 2030. Given rapidly advancing battery technology, and imminent cost parity between EVs and internal combustion engine vehicles, LTA is reviewing our EV charging infrastructure plans to better support EV growth in Singapore. This will include exploring the expansion of the charging network in public car parks, and provision of charging facilities in private car parks. In this context, we are studying a range of options, including whether we should mandate the installation of charging points in public and private residential carparks.”
“All traffic lights at junctions and standalone pedestrian crossings have been connected to the Green Link Determining (GLIDE) system. GLIDE adjusts traffic signal timings dynamically to balance traffic demands between motorists and pedestrians. However, it is an old system with its limitations, as it measures traffic volume using detectors installed under the road surface at traffic junctions, which may not be sufficient. Our intention is to upgrade the technology and more details will be announced when ready.”
“In 2019, the Government introduced a requirement for all active mobility device users to "slow down, stop and look" at road crossings. This is stipulated in legislation. This requirement is based on the Active Mobility Advisory Panel’s review. During their public consultation, they found broad consensus that the requirement was sufficient for ensuring safety. There were concerns regarding the suggestion to require cyclists to dismount at crossings, because this would introduce additional safety concerns for users carrying pillion riders or loads, and create inconvenience for elderly users. All path and road users, whether pedestrians, active mobility device users or motorists, should stop and keep a lookout when using or approaching crossings. LTA will continue to work with the Traffic Police to raise awareness on safe behaviour at road crossings, through public education campaigns and the Safe Riding Programme.”
“These caps are actually enshrined in the main Act, so if there are any changes to remove the caps, we will have to consult and come back to the House to make the necessary changes. On Mr Leon Perera and Mr Louis Chua's request for a success rate of application for DPT service provider licences, it is too early to provide a representative success rate currently. MAS has received over 300 applications so far. Many require very close consultations, even hand-holding and guidance due to their unfamiliarity with AML requirements and the applicability of the Payment Services Act to their business. So, everyone is learning in this very fast moving and evolving space and MAS will continue to review how best to speed up the process and strike a good balance between encouraging entrepreneurship and regulation. Mr Deputy Speaker, Sir, the regulatory issues for payment services are multi-faceted and dynamic as the industry continues to innovate and evolve. MAS seeks to ensure that its regulatory regime is aligned with international standards and that it has the necessary tools to respond quickly to market developments. With that Mr Deputy Speaker, Sir, I beg to move.”
“I also want to assure Assoc Prof Jamus Lim that DPT service provided in respect of a central bank DPT function is also carved out in the Act currently. The new user protection powers introduced under section 21A of the Act is to empower MAS to impose user protection requirements when needed. It will not be implemented immediately, as I have explained. The adoption of DPTs remains small in Singapore and it remains that we are regulating for ML/TF. If MAS was to exercise the powers, the industry can be assured that we will keep to the principle of the Payment Services Act – risk-based, modular. As such, it is likely that requirements will be imposed for major payment institutions first and if we do not detect the same concern for standard payment institutions. Assoc Prof Jamus Lim also asked about moneychangers and he highlighted that business is affected, and indeed so. But it is really not due to this legislation. Because of COVID-19, tourism has been affected badly, that has affected moneychangers' business quite adversely as well. Also, they are affected by technology, as there are now alternatives to remittances. We have a six to 12 months' grace period for existing players to transit into the new regulatory framework, so this applies also to moneychangers. So, new applicants that are seeking to enter the market will not enjoy this six months' grace period, which I think is reasonable. Several moneychangers have made requests to MAS to temporarily cease their licences due to poor business. Several requested for further extensions beyond the six months and MAS will consider their request on a case-by-case basis. As for higher limit on the stock and flow cap of e-money, as raised by Mr Louis Chua, we will continue to study the issue.”
“Mr Don Wee asked whether capital adequacy ratios would be imposed on DPT service providers. Banks take in deposits and on-lend these funds. They play a critical intermediating role in the economy and are, therefore, subject to stringent prudential regulation and supervision, including deposit insurance and capital adequacy ratios. DPT service providers are not banks, do not perform similar economic functions or pose similar systemic risks. We should use alternate means in our regulatory toolbox to deal with risks associated with DPT, which is what the Payment Services Act seeks to do. That is why the Payment Services (Amendment) Bill today provides MAS the powers to require DPT service providers to put in place consumer protection safeguards. Today, under the Payment Services Act, major payment institutions are required to safeguard customer monies by depositing them in a separate trust account, or obtaining either an undertaking or guarantee from a bank in Singapore. Such safeguards currently do not apply to DPT service providers. With the provisions made, MAS will review the need to impose safeguarding measures on DPT service providers. To ensure all our regulations are not so onerous that we stifle entrepreneurship, let me reiterate the basic architecture of the Payment Services Act, which is that it is risk-based, three different licences, three different tiers, with requirements calibrated to the risk they pose, and taking a modular approach. Assoc Prof Jamus Lim raised some questions. I want to assure him that the intent of the Act is to regulate entities that are carrying out payment services as a business and not for individuals.”
“But, actually, digital payment uptake in Singapore is quite rapid. We can see many merchants taking up, individuals using, and this is after years of work putting in place infrastructure such as the FAST and PayNow system, which makes things a lot more convenient. And then, the Singapore Quick Response Code (SGQR), a unified point-of-sale system. So, all these helped create a very strong momentum of digital payment uptake. But when it comes to hawkers in coffeeshops, they are actually one of the hardest to convert. But we will continue to work on them. There are improvements that we can make including on the software, on the user interface as well as the user experience. This is something that MAS will continue to work with agencies, such as IMDA, to continue to push the process. Finally, Members asked about the risks to consumers and businesses who accept or hold DPTs for payments or as collateral for lending to DPT owners. As DPTs have little or no intrinsic value, and their market value is highly volatile, they have not taken off in a big way as an accepted payment mode in Singapore. And it is actually quite a sensible outcome. Mr Don Wee asked for an assurance that DPTs should not be used as collateral to grant working capital loans. Businesses and lenders must understand the nature of DPTs, and those that wish to accept DPTs either as payments or collateral for lending to DPT owners would thus have to bear the risk of value depreciation. MAS conducts thematic checks on banks’ collateral management practices to ensure that they maintain prudent credit risk management. There are, in fact, many alternatives to facilitate the normal conduct of business. Mr Saktiandi suggested a scheme similar to deposit insurance, to safeguard customers against potential losses.”
“Thank you, Leader and Deputy Speaker. Let me repeat. Where the digital tokens are used by issuers as a way to raise capital from the public, the issuers will be subject to the full set of regulatory requirements applicable for securities issuance, such as the need to issue a prospectus. Let me address another question by Mr Leon Perera as well as Assoc Prof Jamus Lim. They voiced the concern of small players and licence holders being caught under the consumer protection requirements. But this is where we also need to strike a balance. We want to encourage entrepreneurship but, at the same time, need to protect consumers especially given the current circumstances that DPTs can become more popular, companies can come up with products that are more attractive. And, today, what we are doing, we believe, is an appropriate and calibrated response. As suggested by several Members, MAS will continue to educate the public on DPTs, through the national financial education programme, MoneySense. We will also explore ways to better reach out to seniors, such as through mainstream media channels, working with agencies such as IMDA and SkillsFuture Singapore, and through the communities. MAS and the CAD have also rolled out consumer education initiatives to raise public awareness of the risks of putting their money in DPTs. Since 2017, several advisories have been issued to warn the public of the risks and of common tactics used by scammers, to cheat people of their money or make use of them to carry out money laundering activities. We will continue our efforts, together with the industry and the community. Let me address one more comment on what Mr Louis Chua raised. He said that digital payment uptake is not fast enough.”
“Mr Louis Ng also asked if there are measures to prevent false marketing to mislead customers. MAS requires licensed DPT service providers to clearly disclose to their customers that they should buy DPTs only if they are familiar with the product and are prepared to accept the risk of losing all the money put into the DPTs. If DPT service providers make a statement that suggests that investment in DPT is protected under the Payment Services Act, MAS will require them to immediately correct or remove the statement, and they will be subject to enforcement actions. In response to Mr Saktiandi’s question, any entity which facilitates DPT transactions as described in the Payment Services Act today or in the amendments under today’s Bill, including persons facilitating transactions, will be required to obtain a licence. Financial advice received in relation to DPTs may be separately regulated under the Financial Advisers Act. However, potential investors should be aware that not all advice they receive in relation to DPT investments is regulated by MAS. Only advice concerning investment products are regulated under the Financial Advisers Act. Investors should check with their financial institutions if the particular DPT investment they are considering is a regulated investment product and understand the risks of dealing in unregulated investment products. Where the digital tokens are used by issuers as a way to raise capital from the public, the issuers will be subject to the full set of regulatory requirements applicable for securities issuance —”
“For example, two persons were convicted in 2020 for promoting an illegal pyramid scheme involving a purported fraudulent digital token called "OneCoin". The CAD has also, to-date, removed or blocked more than 150 advertisements and websites promoting suspicious investments featuring or involving DPTs. Next, investment risks. Members are concerned that today’s enhancements could give consumers a false sense of security and encourage them to jump into DPT-related investments. Some Members may recall we had this same debate, when we first tabled the Payment Services Bill in this House in January 2019, except the tables were then turned. Then, there were requests that MAS regulate DPTs more strictly. I explained that we were not ready to do so, because DPTs were still at a nascent stage of development and we should be mindful that more regulation may have a legitimising effect. Compared to January 2019, while the usage of DPTs in Singapore remains low today, recent developments, such as stablecoins, can spur greater adoption of DPTs within a short time. So, it is timely to have new powers to be able to tighten the regulation, notwithstanding the concern of a legitimising effect. The fact is DPTs remain unsuitable for most retail investors. Placing funds in DPTs like bitcoins comes with very high risk. Today’s amendments introduce additional user protection powers in the Payment Services Act, but it is not possible for laws to protect against investment losses. Ultimately, investors need to exercise extreme caution. They should seek to understand the product, its characteristics and risks before committing their money. Ms Ng Ling Ling is especially concerned about seniors and rightfully so. She suggested risk disclosures and suitability assessments for seniors.”
“For instance, MAS can impose stricter controls and processes to protect data from unauthorised use, in addition to the Personal Data Protection Act. Mr Derrick Goh suggested a ratings system for payment service providers. But unlike the food and property development industries, payment service providers are licensed and subject to on-going supervision by MAS. I would thus encourage consumers to ensure that the payment service providers they engage, such as the platform they use to buy or sell DPTs, are licensed by MAS. Mr Saktiandi also asked if cyberattacks lead to massive losses, how will customers be compensated and what are the penalties. In such an event, MAS will oversee the payment service provider’s dispute resolution process to ensure that they handle customer claims fairly and promptly. Further, if the entity is found to have breached MAS’ cyber hygiene requirements, it can be subject to fines of up to $100,000 on conviction. The next set of risks raised by Members – Ms Ng Ling Ling, Mr Louis Ng, Mr Yip Hon Weng and Mr Saktiandi – pertain to fraud and scams. The first set of actions to prevent this is to have a rigorous, robust, regulatory regime. MAS grants licences only to entities that have in place proper governance and risk management processes. Further, MAS and the Commercial Affairs Department or CAD will take enforcement actions against entities that operate illegally or fail to comply with regulatory requirements. In response to Mr Yip Hon Weng’s specific questions, our enforcement agencies have the power to investigate, seize and confiscate assets in their pursuit of DPT-related scam and fraud cases.”
“But if there is a need to evolve our regulatory regime further in future, we will be ready. Next are questions on technology and cybersecurity risks, as well as data privacy standards. Mr Derrick Goh proposed differentiated technology and cybersecurity requirements for payment institutions, and in particular, for standard payment institutions to perform self-assessment of their technology and cyber risks. The underlying principle behind Mr Goh's suggestion is that MAS should take a risk-based approach when applying technology and cyber security requirements on different types of financial institutions and we agree with this underlying principle. Payment service providers must meet MAS' standards on technology risk management and cyber hygiene practices. Examples of these regulatory requirements include establishing robust security controls to mitigate the risk of malware infection and data loss, and ensuring strong user authentication for systems that are used to access customer information. New entrants who are not able to meet these standards will not be allowed to commence business. MAS imposes more stringent requirements on payment service providers as they become significant players in the payment industry. Payment service providers are expected to independently perform risk assessment against these MAS requirements. However, as part of our on-going supervision, it is still necessary for MAS to periodically assess the cyber resilience of payment service providers by reviewing the effectiveness of their processes and controls. The amendments under the Bill will allow MAS to impose additional requirements on DPT service providers to protect customers' data, precisely for the reasons raised by Members.”
“We are active in this space internationally and we keep abreast of the developments and certainly not running ahead of international best practices. So, whatever the legislation we are proposing, US, Japan, Australia, Switzerland, several EU members have already passed similar legislation to regulate their DPT service providers. On monitoring cross-border flows that Mr Leon Perera asked, our rules require licensees to keep transaction records and we have supervisory oversight to review them. So, monitoring and enforcement is more ex post than ex ante. And of course, we rely on active cooperation with foreign counterparts and sharing of intelligence. Also, as mentioned by Mr Leon Perera, MAS has carved out from regulation, any payment service that is solely incidental to carrying on a business that is already regulated under the Securities and Futures Act. And this is to avoid double regulation. On the need to provide clearer definition of the word "incidental", it is already defined in the Payment Services Act, which is that a payment service is incidental if it is "to support the other business and provided by the person in connection with carrying on of the other business". If necessary, MAS can issue further guidance on this, as we receive more feedback from the industry. Next, I will address crypto-related developments which were brought up by Mr Saktiandi and Mr Don Wee, specifically on stablecoins and decentralised finance or DeFi. These services are still nascent in Singapore but it can change quickly. MAS has therefore issued a consultation paper to review if further changes are needed to address risks associated with stablecoins. DeFi is currently the most common form of DPT services which will be captured with the expanded scope introduced today.”
“Payment service providers are also required to retain the necessary information on customers and transactions to maintain proper audit trails and facilitate investigations by law enforcement agencies. Mr Don Wee asked if MAS requires DPT service providers to use search engines, like in the maritime sector, to authenticate shipments. MAS expects DPT service providers to apply a risk-based AML/CFT approach that is appropriate for the risks of their business and nature of transactions. Hence, MAS does not prescribe the use of specific systems. However, DPT service providers should take enhanced risk measures such as ascertaining the purpose of the transaction or source of funds using relevant sources of information when they encounter higher risk situations. Mr Leon Perera raised several questions. He raised various instances where DPT service providers need not be subject to perhaps the full suite of regulatory measures. These are valid concerns and indeed, we, as I explained earlier, that is why we take a risk-based, modular approach for the Payment Services Act. And in fact, that defines the entire architecture of this Act. For example, it is not the intent of the Payment Services Act to capture entities that conduct general marketing or advertising activities. Whether an entity is caught by the Act, is dependent on the facts and circumstances of each case. The exact rules will be spelled out in subsidiary legislation or guidelines on licensing for licensees; and we will consult the public and the industry as MAS do so. I want to assure Mr Leon Perera that our rules are aligned to the FATF as well as international best practices. This includes the regulation of cross-border remittance of monies.”
“So, the efforts as suggested by Mr Ng is on-going. Mr Don Wee also asked if there could be a centralised platform for DPT service providers to research on transaction details, share information and improve efficiency. We agree with this suggestion, the principle of it. MAS has been working with the industry and relevant associations, on the sharing of emerging risks and typologies, and best practices to collectively raise Anti-Money Laundering/Combating the Financing of Terrorism or AML/CFT standards, and improve their effectiveness and efficiency. Mr Louis Ng asked if there is a space for anonymised financial transactions. Usually, that is cash, that is the most anonymised. But if it is digital, indeed, in this digitised world, everything we do, from buying something online to even surfing the net, we leave a digital trail that is in someone's possession. Yet, we willingly do so. And usually the data is used to push to you the next advertisement that you should take note of. For financial transactions, where there are real concerns of money laundering or terrorism financing, it is all the more necessary to have regulations that require the keeping of data and records. Hence, MAS imposes stringent AML/CFT requirements on licensed DPT service providers in Singapore to mitigate against the risks of abuse of our financial centre by bad actors. Mr Yip Hon Weng also raised questions on whether these service providers would be required to identify and verify their customers. In line with the Financial Action Task Force or FATF standards, DPT service providers must conduct know-your-customer measures for this purpose.”
“Mr Deputy Speaker, Sir, I thank Members who have spoken on the Bill and for their support of its introduction. There were quite a number of comments about protecting consumers, protecting seniors, educating the public on the risk of DPTs or digital payment tokens. But there are also others who commented that we should not over-regulate and we have to encourage entrepreneurship. This is in essence what this Bill is about, to strike that balance, and in that process, take a risk-differentiated approach. When we passed this Bill, I did so in January 2019, and we explained this. It is fundamentally the entire architecture of the Payment Services Act to have different classes of licences, differentiated approach and adopt the principle of taking a risk-based approach. Let me address Members' questions. There are quite a number of them. Let me try my best. First, let me deal with the risks that the Bill mainly seeks to address – money laundering, terrorism financing and other illegal activities. Mr Louis Ng suggested sharing more information and feedback with financial institutions to improve the efficacy of suspicious transaction reporting. Mr Louis Ng asked his question in the context of identifying illegal wildlife trade, but really, the broader purpose is to counter all illegal activities in general. Financial institutions are required to report suspicious transactions to the Suspicious Transaction Reporting Office in the Singapore Police Force. Relevant agencies have shared case studies and red flag indicators on risks with financial institutions to help them better detect and report these illicit activities. Agencies also provide feedback to financial institutions to sharpen their efforts in reporting suspicious transactions.”
“However, that means that an individual involved in a domestic money transfer transaction with a financial institution is not accorded protection under the Act. The Bill will therefore broaden the scope of protection of the PS Act to carve out only situations where both payer and payee are financial institutions. Secondly, only major payment institutions providing services like e-money issuance are currently required to safeguard customer money. With the fast-evolving landscape, user protection concerns associated with other types of licensees can also arise. The Bill will thus allow MAS to prescribe, where necessary, additional classes of licensees conducting specific payment services to be subject to the requirement to safeguard customer money. Thirdly, the PS Act today requires an individual to use reasonable care to ensure that any information he or she provides to MAS under the PS Act is not false or misleading in any material particular. The Bill will clarify that this general duty of care applies to all persons, whether or not the person is an individual. Mr Speaker, Sir, this Bill will enhance the regulatory framework for payment services in line with global regulatory standards and will allow MAS to be nimble and responsive in addressing various risks in the payment landscape. Mr Speaker Sir, I beg to move. [(proc text) Question proposed. (proc text)]”
“The risks to consumers are not significant currently because of the relatively low usage of DPTs in Singapore today. However, user adoption of DPTs could gain traction quickly as the industry comes out with products to attract customers. We have seen recent development of new forms of DPTs which values are pegged to stable assets to gain users' confidence. It is therefore important for MAS to be able to respond to market developments and address new risks in a timely manner. The Bill will enable MAS to impose user protection measures on DPT service providers when necessary. This could include, for example, requiring a DPT service provider to segregate customer assets from its own assets. This will augment current powers that allow MAS to require DPT service providers to safeguard customer money from loss in the event of insolvency. MAS will also be empowered to impose additional measures on certain DPT service providers to maintain stability in Singapore's financial system, safeguard the efficacy of the monetary policy or where it is in the interest of the public to do so. The scope of this new power is necessarily broad so that MAS can respond flexibly and swiftly in the fast-moving DPT landscape. MAS will consult the public and the industry when drafting subsidiary legislation on the specific measures. Finally, the Bill will make three other miscellaneous amendments to the Act. Firstly, the PS Act currently accords protection to consumers, whether they are payers or payees, during a domestic money transfer. As financial institutions are sophisticated entities that can protect themselves, the Act carves out the situation where a financial institution is part of the transaction.”
“These are common business models of DPT service providers that operate in Singapore. The scope of the PS Act will be expanded under this Bill to confer on MAS powers to regulate service providers of DPTs that facilitate the use of DPTs for payments and may not possess the monies or DPTs involved. The FATF standards term these service providers as virtual asset service providers. In regulating these virtual assets service providers, the Bill will expand the scope of DPT services in the PS Act to include the following three activities: one, facilitating the transmission of DPTs from one account to another; two, custodial services for DPTs; and three, facilitating the exchange of DPTs where the service provider does not come into possession of the moneys or DPTs involved. The Bill will require an entity that provides any of these services as a business in Singapore to be licensed and subject to rules and regulations set by MAS in subsidiary legislation. This will help minimise the risk of DPT service providers being exploited by criminals to launder illicit proceeds or hide illicit assets. The Bill will also pre-emptively address ML/TF risk that is outside of the DPT space. The Bill will broaden the definition of cross-border money transfer service to include facilitating transfers of money between persons in different jurisdictions where money is not accepted or received by the service provider in Singapore. That way, such service providers will come under the regulatory ambit of MAS even if the monies do not flow through Singapore. The second set of amendments provides MAS with powers to impose measures on DPT service providers to ensure better consumer protection and to maintain financial stability and safeguard the efficacy of monetary policy.”
“Mr Speaker, I beg to move, "That the Bill be now read a second time." The Payment Services Act, or PS Act, came into force in January last year. Since then, payment services have continued to evolve rapidly, with innovative activities and new business models emerging. One significant development is in the area of digital payment tokens, or DPTs. These are cryptocurrencies – such as Bitcoins – which are not denominated in any currency but can be used as a form of payment. The speed and cross-border nature of such DPT activities carry higher inherent money laundering and terrorism financing or ML/TF risks. They need to be regulated and service providers need to carry out proper customer due diligence and monitoring of transactions. Global standards setting bodies, regulators and policy makers around the world are focused on addressing these risks. As a major financial centre and fintech hub, Singapore has played an active role in shaping international standards, including at the Financial Action Task Force, or FATF, which sets standards for combating ML/TF. The Monetary Authority of Singapore (MAS) is therefore enhancing its regulatory framework and updating the PS Act to keep pace with changes to international standards and to better mitigate ML/TF risks related to DPTs. MAS has conducted a public consultation on the Bill and noted the broad support from respondents. MAS has considered the feedback received and, where appropriate, has taken them into account in finalising the Bill. The Bill makes amendments to the PS Act in three broad areas. First, mitigating ML/TF risks. Under the PS Act, MAS currently regulates service providers dealing in DPTs and facilitating the exchange of DPTs where the service provider comes into possession of monies or DPTs.”
“I thank the Member for the question, but I really cannot speak for the Malaysian government.”
“Out of the 80, 70 or so have been redeployed to LTA and the other 10, we are looking them. We are confident we can redeploy all of them in LTA or within the larger transport eco-system. There are many important projects that are happening, and there will always be a need for good people, such as those 80 people working on the HSR Project.”
“What is the impact of HSR termination by Malaysia on our aviation air hub? As I have mentioned earlier, there are some reasons given as to why the Project was terminated and the impact on air hub was cited in some media reports. But as mentioned, our main concern was the removal of the AssetsCo. Having said that, Malaysia's new proposal to connect the HSR to Kuala Lumpur International Airport or KLIA means that HSR will share tracks with the express rail link to KLIA. The Express Rail Link is an existing train system, not an HSR, and runs at half the full speed of HSR. So, should we have proceeded, there would have been many technical issues to resolve. But having said that, the main concern for us was the removal of the AssetsCo. Since the Member has asked about the impact on aviation, actually, without the HSR, the Singapore-KL aviation route will continue to ferry and transport many passengers, in fact, closer to five million than the four million number stated by the Member. But throughout this whole discussion, the status of our aviation hub due to the HSR Project has not been the key consideration. We knew that this Singapore-KL air corridor is the busiest in the world – 46 flights a day, almost five million passengers a year – a number that is almost equivalent to Singapore's residential population. But it is precisely because of this heavy air traffic between Singapore and KL that we believe that the HSR Project was viable, mutually beneficial and strategic for the long term. So, Singapore will always assess the cost benefit of such major infrastructure projects from a national and long-term perspective, and not just from the perspective of one company or one industry. As for the Member's second question about manpower, 80 staff are affected.”
“I think the Member just now meant five hours by car, not five hours by air.”
“Thank you. The short answer to the first question is no. RTS is progressing well so far. The Johor Bahru side has broken ground; on our side, we will break ground soon and we hope the Project and the service can commence in 2026 as scheduled. As for Jurong Regional Centre, let me assure the House that MND had started planning to transform Jurong as early as 2008. So, the Jurong Lake District is part of a broader effort to develop urban centres outside of our CBD and our city centre. The plans for Jurong Lake District, or JLD were, therefore, developed well before Malaysia proposed the current HSR Project in 2012. It was only much later, in 2015, that we decided to locate the Singapore terminus of the HSR in Jurong. The termination of the HSR Project, therefore, does not affect the overall impetus and vision for JLD, although some details may need to be adjusted along the way. When completed, this will be the largest commercial and regional centre outside of our city centre, bringing many jobs, business and recreation opportunities for Singaporeans and Singapore companies. The land parcels that the Government has acquired are still needed to realise these plans. For example, the Jurong Country Club site will provide for new mixed-use developments and community facilities. The Raffles Country Club site is also still needed for the Cross Island Line's western depot and the Integrated Train Testing Centre. We will be able to realise the full potential of the land to benefit Singaporeans.”
“Thank you. As I have mentioned in my earlier clarifications, at the request of Malaysia, we suspended the Project for two years up to May 2020. And then, there was a second request from Malaysia to extend it until 31 December 2020, that is, another six months, which we were not obligated to agree, but we agreed to it. So, there were two extensions, at the Malaysians' requests and we agreed to it in good faith and in the spirit of good bilateral relations. But we cannot extend indefinitely and, so, for the second extension to 31 December 2020, both sides agreed that it shall be the final extension, and it is part of the agreements. So, I think there will have to be a finality to the suspension and extension of the Project. Having said that, there is a fundamental difference which I have explained earlier with regard to the removal of the AssetsCo. Whether we are open to future discussions, of course, we are. But it should be on a clean slate, after we have settled the current HSR BA.”
“To Singapore, AssetsCo is the centrepiece of the HSR Project. It is necessary to ensure that the interests of both countries are protected. This will minimise the possibility of future disagreements and disputes over the long duration of the Project, lasting decades. Singapore, therefore, informed Malaysia that the removal of the AssetsCo constituted a fundamental departure from the HSR BA and could not be accepted. Malaysia has since decided to allow the HSR BA to be terminated. In these circumstances, it has to compensate Singapore, in accordance with the HSR Agreements. Now that the HSR BA has been terminated, Singapore is willing to discuss any new proposal on a KL-Singapore HSR from Malaysia in good faith, but starting from a clean slate.”
“So, the HSR Agreements are legally binding international agreements. Parties come to the table as equals, discuss the various terms, such as how to structure and implement the cross-border HSR Project, and the rights and obligations placed on both Parties. As Members know, this process involves understanding each other's concerns, addressing them, striking compromises and finding mutually acceptable common ground. Singapore was fully committed to carry out our obligations under the HSR BA. But Malaysia felt that circumstances had changed, including due to COVID-19, and proposed several changes to the HSR Project. Be clear about this, which is, Singapore was not obligated to agree to any of such changes because we had signed an agreement in 2016 already. But, notwithstanding, we considered them in good faith. But we were unable to agree to one particularly significant change proposed by Malaysia. This involved the removal of the Assets Company – in short form, we call it "AssetsCo" – which is the systems supplier and network operator of the HSR service between Singapore and Kuala Lumpur (KL). Let me explain why. As the HSR is a cross-border service, it must be a single train system operating between Singapore and Kuala Lumpur in Malaysia. Because neither country has the expertise and experience in operating an HSR, we agreed, under the HSR BA, to appoint a best-in-class industry player through an open and transparent international tender to assume the role of the AssetsCo. Once appointed, the AssetsCo would supply the train system, operate the network, ensure that appropriate priority is given to cross-border HSR service vis-a-vis Malaysia's domestic service, and AssetsCo would be accountable to both countries, that is, Singapore and Malaysia.”
“Let me answer the Member's second question first. Then-Minister Khaw Boon Wan did mention the figure of S$250 million. He also mentioned that costs continue to be incurred and, therefore, it may reach S$300 million or so later. Today, our expenditure is roughly S$270 million, less than what he had indicated earlier, because when the Project was suspended and we agreed to the suspension, we wound down the contracts and we maintained activity at a low level, which is why we did not incur as much as it was indicated earlier. Will we be able to claim the full amount? The amount to be compensated, as I have mentioned, and the schedule for payment, these are specified in the agreements. So, it is a fixed amount specified in the agreements. Unfortunately, due to confidentiality obligations, I cannot disclose the amount. But we have started the process of compensation. As for the first question, it is an important one – the substantive point of difference. Let me go back a little bit. Singapore and Malaysia signed the HSR Bilateral Agreement – we call it HSR BA – in 2016. And that is after three years of negotiations to implement the HSR Project. Subsequently, both Parties signed two supplementary agreements relating to the suspension of the construction of the HSR Project. Both suspensions were at Malaysia's requests. So, the first supplementary agreement was signed in 2018, to suspend the construction of the HSR Project. The second, in 2020, extended the suspension period to 31 December 2020, with the explicit understanding that it would be the final extension. By then, it would have been extended by two and a half years. I will refer to the HSR BA, subsequently amended by the supplementary agreements, generically as the "HSR Agreements" as a short form.”
“Singapore has incurred more than S$270 million for the Kuala Lumpur – Singapore High Speed Rail, or HSR Project. Some of these costs, such as for consultancy services, design of infrastructure and manpower to deliver the HSR Project, are abortive costs if the HSR Project does not proceed. To date, Singapore has already received about S$15 million from Malaysia, arising from Malaysia’s request to suspend the construction of the HSR Project back in 2018 and up to May 2020. Subsequent to that, at the request of Malaysia, the HSR Project was further suspended until 31 December 2020. Malaysia has now decided not to proceed with the HSR Project. According to the terms of the Parties' agreement, Malaysia is obliged to pay termination compensation to Singapore. This will include various abortive costs but not land acquisition costs since the value of the land can be recovered. The compensation amount for the termination and schedule for payment are specified in our agreement. In addition, there is a small component of miscellaneous abortive costs for the suspension of the Project requested by Malaysia that Singapore is currently verifying, before we send to Malaysia. Due to Singapore’s confidentiality obligations under the HSR Bilateral Agreement, we are unable to reveal the exact terms in relation to the compensation for the termination of the HSR Project. We look forward to continue to build good relations and work closely with Malaysia to improve connectivity in other ways, and in many other fields, for the mutual benefit of the people of both countries.”
“Currently, Singapore does not allow entry of short-term visitors from the United States of America (USA) unless they are (a) immediate family members or relatives of a Singapore Citizen or a Singapore Permanent Resident (PR), (b) spouses-to-be of a Singapore Citizen or Singapore PR, or (c) non-residents who have extenuating or compassionate reasons to enter Singapore. Travellers from the USA who are entering Singapore must serve a 14-day Stay-Home Notice (SHN) at SHN Dedicated Facilities. Like all travellers who serve SHN, they are required to undertake a COVID-19 swab test before the end of the SHN period. The prevailing advisory is for Singaporeans to defer all non-essential travel to the USA. As of now, we have yet to begin negotiations of a green lane or special travel arrangements with the USA.”
“Like many applications and payment systems we use today, the next-generation Electronic Road Pricing (nexgen ERP) system will collect transaction data such as whether the vehicle is on ERP-priced roads, the amount charged and whether the transaction is successfully completed. The system will also collect road traffic data such as vehicle speeds. Nexgen ERP was designed with strict data security safeguards. This was a key consideration when LTA, in consultation with other agencies, decided on using an on-board unit (OBU) to process the transactions, as opposed to an open system using our smartphones. There are also safeguards in place governing the storage, usage and sharing of data, in line with Government-wide standards. For road traffic data, once it is transferred from the OBU to LTA's backend system, the data will be automatically anonymised. The data will be aggregated for traffic management and transport planning purposes. As an existing practice, such data can also be shared with third-party developers and researchers to develop traffic management solutions. For example, LTA publishes aggregated land transport datasets on the LTA DataMall website. As for vehicle-specific data, LTA will only use it for payments, charges and enforcement. Summons related to such non-payments will largely be auto-generated. Like all Government agencies, personnel who can access nexgen ERP data will be tightly controlled and restricted to a need-to-know basis, and data access will be logged and regularly reviewed. LTA also adheres to Government-wide standards on data sharing with other Government agencies. For example, sharing of data to support policy and planning purposes will only be done on an anonymised or aggregated basis, in accordance with the Public Service (Governance) Act.”
“As of end August 2020, there are: (a) About 97,000 Taxi Driver's Vocational Licence holders of whom 32,000 are registered drivers in the month of August 2020; and (b) About 52,000 Private Hire Car Driver's Vocational Licence (PDVL) holders, of whom 43,000 drove at least one PHC trip in the same month. Given the flexible nature of PHC driving, there is no official definition for a full-time PHC driver. Currently, about 95% of PDVL holders are Singaporeans, and the rest are permanent residents; 85% are above the age of 30. Since 15 September 2020, new PDVL applicants must be Singapore Citizens who are at least 30 years old. Existing PDVL holders are not affected by the new rule as long as they continue to renew their PDVLs.”
“Between 2018 and September 2020, the average monthly hired rates for taxis and private hire cars (PHCs) are about 90% and 79% respectively. There is a limit to the growth of taxi and PHC populations. For taxis, LTA only allows taxi operators to grow their fleets by up to 2% annually. As for PHCs, they are part of the COE system. Within these limits, the vehicle populations adjust according to the market. Hence, since January 2020, the population of taxis reduced by about 13% while that for PHCs fell by 9%. The Government's policy is to encourage mass public transport. Notwithstanding, point to point services such as taxis and PHCs have a place in the land transport system. They provide jobs to many drivers and offer commuters a convenient service at a higher price point. It was not too long ago when taxis were in shortage, which frustrates many commuters. Today, with the advent of PHCs complementing taxi services, this is no longer an issue.”
“There were four. Two was when the system was first commissioned; that was 2018. So, of course, there were concerns. In 2019, there were no failures. And this year, there were two earlier failures, now this one. So, the reasons for the failure has not been established which is why, given that what has happened, we should send it for forensic examination and understand the reason why. In the meantime, regardless of the reason, the cables would be replaced.”
“The purpose, depending on the circumstances, need not always be punishment. Sometimes, it is really a matter of retraining, refresh what you have learnt, self-reflect and go back, you do better and share your learnings with your colleagues. And I think it is a good system to ensure that we keep on improving. The question specifically asked if there would be improvement in work processes. Definitely. As I have mentioned, every time there is a major disruption, it is always unique. This time, it is also unique. SMRT has not encountered such a situation before where a cable fault, coupled with a trip-coil fault, resulting in a disruption. So, they will be improving their SOPs. But frankly, when it happens, you do not have time to go and refer to them. It has to be internalised into the experience and lessons learnt by all the operators, and by the engineers. And I think this incident provided a lot of lessons for them.”
“Let me answer the second question first – will more stringent tests be conducted? I think to put it in context, this set of components and equipment are not new. It has been used on other lines. And they typically have a life span of 20, 25, or 30 years. So, this is a bit premature to have four faults in the last few years, which I think explains why Alstom is stepping forward and replacing everything. I do not want to prejudge why the cable was faulty. It is going through forensics and once the results come out, I am sure it will provide insights. But there is an SOP and there is an inspection regime for all cables and trip-coils throughout the system. For this stretch, while the components are being replaced, we will step up, double the frequency, so that we make sure it works. As for the first question, I should I emphasise, suspension does not necessarily mean we are blaming the workers or they are being punished. Because they may not have committed wrong. If there is gross negligence, in fact, if there is wilful wrongdoing, disciplinary actions will be taken, including even bringing in the Police, if there is wilful wrongdoing. But in most operations involving live operations and in a place where there is a strong safety culture, suspensions are not uncommon. It is actually carried out, quite routinely, as a matter of professional conduct and safety protocol. You will find that in the SAF, you find it in bus operations. You have a near-miss, or a side swipe of a bus, the captain might be suspended for a week. It does not mean it is a punishment. Sometimes, it is not their fault, or even running theme parks or manufacturing plants, process plants. These are always carried out. It is part and parcel of a professional conduct of an engineering company.”
“But I think in this case, the investigation report went up. The equipment supplier came forth, agreed to replace all 113 of trip coils, and 150 km of cable wires and within SMRT and LTA, everyone self-reflected what they could do better. So, I think what is more important than meting out punishment, is the team able to come together, reflect upon what could be done better and take it upon themselves, take responsibility to say, "I can do things better". And together, without finger-pointing, work together to better serve commuters. The mood can easily change and go wrong. When it becomes one of penalty and punishment, then the mood changes when everyone become defensive, everyone, to put it crudely, will cover their behinds. And after a while, you do not get the best outcome. So, as far as possible, there is a disciplinary structure and we will use it if we have to. But as far as possible, I feel, hold the team together, be able to work together for the benefit of commuters – that is a lot more important.”