IMPACT – HIGH

The government has announced that most immigration services and processes are to be accessed online from April 7 through May 4 in an ongoing effort to mitigate the spread of the COVID-19 virus.

Key Points:

  • Individuals should use e-services (MyICA) for Immigration & Checkpoints Authority (ICA) transactions. In-person services for urgent cases are only available by appointment.
  • The Employment Pass Service Centre is closed, and pass holders unable to proceed with card registration or collection can remain in Singapore with their Notification Letter or Card Replacement Letter.
  • Card delivery services are suspended.
  • Most work and dependent passes expiring from April 6 to May 5 will be extended to June 5.

Additional information: ICA’s e-appointment service is suspended, though call center services (6391 6100) will still be available. Those with ICA appointments on or after April 7 must postpone visiting the ICA building until after May 4. Please visit the Ministry of Manpower’s website for more information on work permit-related services.

Analysis & Comments: The response to COVID-19 continues to develop, and Deloitte will provide additional updates as information becomes available.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

 

 

IMPACT – HIGH

The government announced an entry ban for all short-term visitors. Further, only work pass holders employed in essential services can enter or return.

Key Points:

  • As of March 23, all short-term visitors will be barred from entering Singapore.
  • Work pass holders and their dependents entering or returning to Singapore may only enter if they work in a sector providing essential services such as healthcare or transport. All work pass holders and their dependents must obtain Ministry of Manpower (MOM) entry approval prior to returning to Singapore.
  • Singapore residents, permanent residents and long-term pass holders returning to Singapore will continue to receive 14-day Stay Home Notices (SHN).
  • Malaysians holding Singapore work permits may continue to work in Singapore.

Additional information: MOM is encouraging employers to impose Leave of Absence (LOA) on all employees who returned to Singapore between March 14 and March 20, and did not receive an SHN. Affected employers and the self-employed may claim S$100 per day for LOAs. MOM is taking breaches of entry approval, as well as SHN and LOA requirements, seriously, and have recently revoked 89 work passes and permanently banned workers involved in the breaches from working in Singapore.

Analysis & Comments: Employers are advised to adhere to entry approval, SHN and LOA requirements and should continue to anticipate disruptions and delays regarding employee mobility and availability. The response to COVID-19 continues to develop, and Deloitte will provide additional updates as information becomes available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT MEDIUM

What is the change? 
A Singapore-based company was recently convicted of making a false fair hiring declaration in a work pass application.

What does the change mean? The Ministry of Manpower levied an SGD$18,000 fine for the conviction and revoked a newly hired foreign employee’s work pass. The convicted company was also barred by MOM from hiring foreign employees for 24 months.

  • Implementation time frame: Immediately.
  • Visas/permits affected:  Work passes and other employment-related permits.
  • Who is affected: The convicted company and foreign national who was newly hired.
  • Business impact: Employers in violation of the Fair Consideration Framework (FCF) will face stiff penalties, including fines.

Background: The company stated it had fairly considered local job candidates for a new position. An investigation showed the company posted a job ad and had 22 respondents who were not interviewed. The company hired a foreign candidate instead and submitted a work pass application containing this fair hiring declaration. Fair Consideration Framework (FCF) administrative penalties were strengthened by MOM in January of 2020 in order to provide a greater deterrent against workplace discrimination. The convicted company is the first to be prosecuted for making a false fair hiring declaration with the stronger penalties in place.

Analysis & Comments: Employers are reminded that when submitting work pass applications to the Controller of Work Passes all declarations within them are required to be true, accurate and complete. Failing to do so can result in fines of up to SGD$20,000, and/or a two-year jail sentence, for each charge.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

Singapore has announced that officials will issue stay-home notices to all travelers who have been in an ASEAN country, Japan, Switzerland or the United Kingdom in the past 14 days. The measure is being taken in an effort to mitigate the spread of the COVID-19 virus.

Singapore’s COVID-19-related entry restrictions are now as follows:

  • Hubei Province. Short-term visitors, Singapore residents and long-term pass holders who have been in Hubei Province in China in the past 14 days are not permitted to enter or transit through Singapore.
  • Mainland China (excluding Hubei Province), France, Germany, Italy, Iran, South Korea, Spain. Short-term visitors who have been in any of these countries in the past 14 days are not permitted to enter or transit through Singapore. Singapore residents and long-term pass holders will be issued a 14-day stay-home notice.
  • ASEAN countries, Japan, Switzerland, United Kingdom. Short-term visitors, Singapore residents and long-term pass holders who have been to any of these countries in the past 14 days will be issued a 14-day stay-home notice. They will also be asked to provide proof of accommodation in Singapore and may be tested for COVID-19 even if they do not have symptoms. ASEAN countries (besides Singapore) are: Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, Philippines, Thailand and Vietnam.
  • Additional information: In addition to the inbound restrictions, Singapore’s Ministry of Health said Sunday that Singaporeans are advised to postpone all non-essential travel abroad. This advisory will remain in effect for 30 days, at which point it will be reviewed.

Analysis & Comments: Singapore continues to take steps to mitigate the spread of the COVID-19 virus. Employers are advised to account for affected travelers and rearrange travel schedules accordingly. Those planning nonessential travel out of Singapore are urged to reconsider doing so at this time.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

On March 16, The Ministry of Manpower issued guidelines for employers regarding employee travel.

MOM said:

  • Employers should defer all non-essential work-related travel for employees.
  • For essential work-related travel, employers must provide additional paid leave to affected employees to cover self-isolation and quarantine in the destination country, flight availability, obtaining re-entry approval from MOM, and mandatory self-isolation on returning to Singapore.
  • Employers are to respect employee wishes to not travel and should not penalize employees for refusing to travel for work.
  • Employers are to encourage employees to avoid all non-essential travel for personal reasons.

Analysis & Comments: Employers must be prepared for significant disruptions to employee mobility and should anticipate further restrictions and quarantine measures. Employers are advised to check MOM’s website for more information on non-essential travel. The response to the COVID-19 outbreak continues to develop, and Deloitte will provide additional updates as information becomes available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? The Ministry of Manpower (MOM) will no longer accept applications via the Singapore Post (SingPost) for Personalised Employment Passes, Entrepreneur Passes and others.

What does the change mean? Beginning April 3, employment and dependent pass applications must be submitted electronically.

  • Implementation time frame: April 3, 2020.
  • Visas/permits affected: Personalised Employment Passes, Entrepreneur Passes, related passes such as Dependant Passes and Long Term Visit Passes and Miscellaneous Work Passes.
  • Who is affected: Foreign nationals and employers applying for any of the above passes.
  • Next steps: Applications can continue to be submitted via SingPost through April 2, after which, all applications must be submitted electronically through the MOM website.

Analysis & Comments: The new policy means it will no longer be necessary to stand in line at the post office to submit pass applications, as the entire process will be completed electronically. Deloitte will alert clients to any additional changes as information becomes available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

What is the change? 
Singapore’s Ministry of Manpower (MOM) has expanded its travel restrictions for work pass and In-Principle Approval Letters holders.

What does the change mean? All work pass holders, including their dependents, who have traveled to South Korea, northern Italy, Iran or (as previously announced) mainland China within the last 14 days and intend to enter or return to Singapore, are now required to obtain MOM’s approval before beginning to travel. This requirement applies to work pass holders of all nationalities. The entry approval requirement applies to both work pass holders outside of Singapore, and in-principle approval holders who have not yet entered. All work pass holders affected by the new restrictions will be placed on a mandatory 14-day Stay-Home Notice (SHN) when they arrive in Singapore.

  • Implementation time frame: Ongoing from March 4.
  • Visas/permits affected: Work visas used for inbound travel from South Korea, northern Italy, or Iran within the last 14 days.
  • Who is affected: All workers from the specified locations who meet the time requirement.
  • Business impact: The new restrictions will affect travelers on work passes/visas from Iran, South Korea, and northern Italy.
  • Next steps: The expanded restrictions are in force until further notice. Employers should expect that any of their employees who are in the three affected areas and intend to travel to Singapore will likely face a variety of restrictions.

Additional information: The new restrictions apply to employers as well. Employers applying for entry approval must communicate to MOM that arrangements have been made for suitable premises to house the entering or returning employees for the duration of their SHN. When employers apply for entry approval, they must use this online facility.

Employers should inform employees and their dependents not to make travel plans for Singapore until MOM approval has been received.

MOM approval letters need to be sent to employees by their employers so they can show them to airline staff when they arrive in Singapore. When work pass holders are on the 14-day SHN, employers must make sure they can secure meals and other daily necessities. Employers will make such arrangements for work pass holders on SHN if they are unable to do this for themselves.

Employers and employees who are not in compliance with the new restrictions may face enforcement from MOM, including work pass revocation or work pass privilege withdrawal.

Analysis & Comments: The new MOM work pass and approval holder travel restrictions are Singapore’s latest effort to mitigate the spread of COVID-19. Workers with the affected passes and approvals planning travel to Singapore from the target areas may wish to reconsider their plans. The response to the COVID-19 outbreak continues to develop, and Deloitte will provide additional updates as information becomes available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Singapore will soon increase the monthly minimum salary for Employment Pass holders from SG$3,600 to SG$3,900, while older and more experienced candidates are expected to be paid at a higher rate commensurate with their skills and experience. The Ministry is also focusing on the tightening of the Fair Consideration Framework, and will broaden advertising requirements for Employment Passes to include jobs paying up to SG$20,000 per month.

  • Implementation time frame: The changes are set to take effect May 1, 2020. The salary minimums will initially only be applicable for first-time applicants, but will apply to renewals beginning on May 1, 2021.
  • Visas/permits affected: Employment Passes.
  • Who is affected: Companies sponsoring foreign workers on Employment Passes.
  • Next steps: Employers should update their policies and budget for the higher salaries as necessary.

Additional information: The increase to the Employment Pass salary minimum will be the first such increase since 2017, when the minimum was increased from SG$3,300 per month to the current SG$3,600. Officials also announced that beginning May 1, 2020, they will require all jobs paying up to SG$20,000 per month to be advertised on the jobs portal MyCareersFuture.sg for at least 14 days before an Employment Pass application can be submitted. Currently, only jobs paying up to SG$15,000 per month must be advertised.

Separately, the “local qualifying salary” or the minimum salary a local worker must earn to count towards a company’s quota for hiring foreigners on Work Permits and S Passes will be raised from SG$1,300 to SG$1,400 beginning July 1, 2020.

Analysis & Comments: Employers should update their policies and budget for the higher salaries as necessary. Employers should also note that new advertising requirements will take effect from May 1, 2020, and that all jobs paying up to SG$20,000 per month must be advertised locally before they can be opened up to foreign employees.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

Singapore’s Ministry of Manpower (MOM) continues to implement measures to contain the spread of the Covid-19 virus.

Key points:

  • As of Feb. 26, employers must obtain entry approval from MOM for all work pass holders and their dependents with travel history within the last 14 days to mainland China or South Korea’s Daegu City and Cheongdo County who are planning to enter/return to Singapore, before beginning their journey. This applies to existing work pass holders, as well as in-principle approval holders. Upon arrival in Singapore, affected work pass holders will be placed in mandatory 14-day Stay-Home Notice (SHN). Employers must declare to MOM their ability to provide proper housing for SHN before obtaining entry approval. Employers must fulfill additional obligations to affected employees, and employees must fulfill obligations for their affected dependents.
  • Singapore citizens and permanent residents who have traveled to mainland China, Daegu City or Cheongdo County within the last 14 days are also subject to the SHN.
  • All other foreign national visitors who have traveled to mainland China, Daegu City or Cheongdo County within the last 14 days will be refused entry to Singapore.
  • As of Feb. 18, MOM has extended the Leave of Absence Support Programme (LOASP) to businesses and self-employed individuals affected by SHN requirements. Under the LOASP, eligible employers can apply for daily support of $100 for each affected worker for the duration of SHN. Affected workers include Singapore citizens, permanent residents, and work pass holders who traveled to mainland China on or before Jan. 31, 2020, and were then placed on SHN on their arrival in Singapore. Eligible employers also qualify for levy waivers for affected foreign workers for the duration of their SHN. Self-employed Singapore citizens and permanent residents who traveled to mainland China on or before Jan. 31, 2020, and were placed on SHN on their return to Singapore, can also apply for the daily support of $100.
  • A temporary measure to help companies in the manufacturing and service sectors facing staff shortages allows them to hire work permit holders from China (PRC) with the approval of their current employer in Singapore. (Normally, they would have to return to China before being hired.)
  • As of Feb. 23, the Ministry of Health is advising that travelers avoid all non-essential travel to Daegu and Cheongdo County in South Korea.

Background: Jurisdictions across the globe have implemented entry bans and other immigration restrictions in order to guard against the spread of the Covid-19 virus. In this regard, Singapore has issued a work pass application ban, tightened requirements for work pass holders with recent travel history in China, as well as other work pass-related measures.

Analysis & Comments: The response to the Covid-19 virus in Singapore and other countries continues to evolve. Deloitte will alert clients to additional changes or restrictions as information becomes available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

What is the change? Singapore will reduce the ratio of foreign workers in the construction, marine shipyard and process sectors in a two-step process beginning in 2021, according to the new budget.

What does the change mean? Beginning Jan. 1, 2021, companies in the construction, marine shipyard and process industries will only be permitted to employ S Pass holders as 18% of their total workforce, and the cap will drop again to 15% on Jan. 1, 2023. The current permissible percentage is 20% for these industries. For companies in the manufacturing industry, the ratio for S Passes will be reviewed at a later date because of economic uncertainty.

  • Implementation time frame: The two-phase implementation will take place on Jan. 1, 2021 and Jan. 1, 2023.
  • Visas/permits affected: S Pass; Employment Pass (EP) holders who may potentially be downgraded depending on their EP eligibility.
  • Business impact: Companies in the construction, marine shipyard and process sectors should plan for the changes and may need to reduce their reliance on foreign workers and upskill their Singaporean workforce.

Background: The allowable percentage of foreign workers to Singaporean workers is referred to as the Dependency Ratio Ceiling (DRC), and S Passes are a sub category of the overall DRC. The government has observed an increase in the number of S Pass holders in the construction, manufacturing, marine shipyard and process sectors, and these numbers are expected to increase further over the next several years. Nevertheless, S Pass holder growth must be sustainable. The government is already working closely with enterprises to grow local manpower, including mid-career workers. The manufacturing industry will be reviewed in the future and may undergo similar sub-DRC reductions.

The following chart shows the changes to the DRC and sub-DRC in all sectors in the coming years.

  DRC Sub-DRC
Sector Current Jan. 1, 2021 Jan. 1, 2023 Current Jan. 1, 2021 Jan. 1, 2023
Construction 87.5 No change No change 20 18 15
Marine shipyard 77.8 No change No change 20 18 15
Process 87.5 No change No change 20 18 15
Manufacturing 60 No change No change 20 To be reviewed
Services 38 35 (based on Budget 2019) 13 10 (based on Budget 2019)

Analysis & Comments: Following last year’s announcement during the budget on cutting dependency on the DRC and S Pass sub-DRC thresholds in the services sector, this announcement on tightening the foreign workforce quota in three additional sectors comes as no surprise. The reduction in the sub-DRC is aimed at encouraging employers in the construction, marine shipyard and process sectors to enhance their Singaporean workforce by hiring and training more Singaporean workers and transferring skills from their foreign employees to the local workforce.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.