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Under Section 3 of the Code of Practice, which tier do the following Accounting and Corporate Regulatory Authority (ACRA)-registered HCSA Licensees that are non-foreign companies fall under: i. an exempt private company limited by shares; ii. a private company limited by shares; iii. a limited liability partnerships; iv. an exempt charity that is an Institution of Public Character (“IPC”); or v. a public company limited by guarantee

Healthcare Services (General) Regulations, Governance of Licensees

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For (i) An exempt private company limited by shares and (ii) a private company limited by shares:

  • HCSA Licensees which are registered as an exempt private company limited by shares or a private company limited by shares may still fall under the Basic Tier, if it is (a) a small company that is exempt from the audit requirements under Section 205C of the Companies Act 1967, or (b) a company which is not a small company exempt from audit requirements under Section 205C of the Companies Act 1967, that has only one Board Director.

  • However, such licensees will fall under the Enhanced Tier if they do not satisfy the requirements listed in (a) or (b) above.

For (iii) a limited liability partnership:

  • A limited liability partnership is a form of partnership, hence HCSA licensees registered as a limited liability partnership falls under the Basic Tier. However, if there is one or more of the registered partners of the HCSA licensee is / are an entity that falls under the Enhanced Tier, the HCSA Licensee will fall under the Enhanced Tier.

For (iv) an exempt charity that is an Institution of Public Character (IPC):

  • HCSA Licensees which are registered as an exempt charity that is an IPC falls under the Basic Tier, as it is a charity.

For (v) a public company limited by guarantee:

  • HCSA Licensees which are registered as a public company limited by guarantee will fall under the Basic Tier, as a public company limited by guarantee is a type of company limited by guarantee.


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