END-TO-END SYSTEMS INTEGRATION SOLUTION PROVIDER
WHISTLEBLOWING POLICY
1. INTRODUCTION
Jason Marine Group Limited and its subsidiaries (“the Group”) are committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements and any legislation relating thereto. In line with this commitment, the Whistleblowing Policy (“Policy”) aims to provide an avenue for employees and external parties to raise concerns and offer reassurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
The Policy is intended to conform to the guidance set out in the Code of Corporate Governance which encourages employees to raise concerns, in confidence, about possible irregularities.
​
2. WHO IS COVERED BY THIS POLICY
This Policy applies to all employees of the Group.
New employees will be issued a copy of this Policy upon commencement of employment.
​
3. OBJECTIVES OF THIS POLICY
Deter wrongdoing and to promote standards of good corporate practices.
Provision of proper avenues for employees to raise concerns about actual or suspected improprieties in matters of financial reporting or other matters and receive feedback on any action taken.
Give employees the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
​
4. REPORTABLE INCIDENTS
Some examples of concerns covered by this Policy include (this list is not exhaustive):
-
Concerns about the Group’s accounting, internal control or auditing matters.
-
Breach of or failures to implement or comply with the Group’s policies or code of conduct.
-
Impropriety, corruption, acts of fraud, theft and/misuse of the Group’s properties, assets or resources.
-
Conduct which is an offence or breach of law.
-
Abuse of power or authority.
-
Serious conflict of interest without disclosure.
-
Intentional provision of incorrect information to public bodies.
-
Any other serious improper matters which may cause financial or nonfinancial loss to the Group, or damage to the Group’s reputation.
-
Fraud against investors, or the making of fraudulent statements to the Singapore Exchange Securities Trading Limited, members of the investing public and regulatory authorities.
-
Acts to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of the Group.
-
Concealing information about any malpractice or misconduct.
The above list is intended to give an indication of the kind of conduct which might be considered as “wrong-doing”. In cases of doubt, the whistleblower should seek to speak to his or her immediate superior or follow the procedure for reporting under this Policy.
​
5. PROTECTION AGAINST REPRISALS
If an employee raises a genuine concern under this Policy, he or she will not be at risk of losing his or her job or suffering from retribution or harrassment as a result. Provided that the employee is acting in good faith, it does not matter if he or she is mistaken.
However, the Group does not condone frivolous, mischievous or malicious allegations. Employee(s) making such allegations will face disciplinary action in accordance with the Group’s Disciplinary Procedures.
​
6. CONFIDENTIALITY
The Group encourages the whistleblower to identify himself / herself when raising a concern or providing information. All concerns will be treated with strict confidentiality.
Exceptional circumstances under which information provided by the whistleblower could or would not be treated with strictest confidentiality include:
-
Where the Group is under a legal obligation to disclose information provided.
-
Where the information is already in public domain.
-
Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice.
-
Where the information is given to the Police or other authorities for criminal investigation.
In the event the Group is faced with a circumstance not covered by the above, and where the whistleblower’s identity is to be revealed, we will endeavour to discuss this with the whistleblower first.
7. CONCERNS AND INFORMATION PROVIDED ANONYMOUSLY
Concerns expressed anonymously are much less persuasive and may hinder investigation work as it is more difficult to look into the matter or to protect the whistleblower’s position. Accordingly, the Group will consider anonymous reports, but concerns expressed or information provided anonymously will be investigated on the basis of their merits.
​
8. HOW TO RAISE A CONCERN OR PROVIDE INFORMATION
Acts of misconduct may be disclosed in writing, telephonically or in person. However, all reports are encouraged to be made in writing, so as to assume a clear understanding of the issues raised. The format provided in Appendix 1 may be used for reporting purpose. All reports should be sent directly to any of the persons below. Contact information are as follows:
Email: whistleblow@jason.com.sg
Mail: 194 Pandan Loop, Pantech Business Hub #06-05, Singapore 128383
Attention: Joseph Foo (CEO) or Constance Koh (ARC Chair)
​
In case of reports sent through e-mail, it is recommended to mark the subject as “Whistleblower” for ease of identification.
Although the whistleblower is not expected to prove the truth of an allegation, he / she needs to demonstrate to the person contacted that there are sufficient grounds for concern.
​
9. IMPORTANT POINTS TO NOTE WHEN RAISING A CONCERN OR PROVIDING INFORMATION
The earlier the concern is raised the easier it is for the Group to take action.
​
The Group expects the whistleblower to provide his / her concern in good faith and to show to the appropriate officer that there are sufficient grounds for his / her concern.
​
10. HOW THE GROUP WILL RESPOND
The Group assures you that any concern raised or information provided will be investigated, but consideration will be given to these factors:
-
Severity of the issue raised.
-
Credibility of the concern or information.
-
Likelihood of confirming the concern or information from attributable sources.
Depending on the nature of the concern raised or information provided, the investigation may be conducted involving one or more of these persons or entities:
-
The Audit Committee
-
The External or Internal Auditor
-
Forensic Professionals
-
The Police or Commercial Affairs Department
The amount of contact between the whistleblower and the person(s) investigating the concern raised and information provided will be determined by the nature and clarity of the matter reported. Further information provided may be sought from the whistleblower during the course of the investigation.
The investigating officer(s) will communicate the findings of the investigation(s) to the Audit Committee for their necessary action.
​
11. INVESTIGATING ALLEGED MISCONDUCT OR IMPROPER ACTIVITIES
The Committee member who receives a report will notify the sender and acknowledge receipt of the reported violation or suspected violation within ten business days.
The Committee Members shall meet to discuss about the action / investigation on the reports received from whistleblowers. The Committee may also include or exclude from its meetings any person it deem appropriate, depending on the nature of the complaint.
The Committee Members have the responsibility to conduct investigation. In addition, other parties may also be appointed to be involved in the investigation.
The Committee Members will ensure investigations are carried out using appropriate channels, resources and expertise.
Some concerns may be resolved by agreed action without the need for an investigation to be carried out. Concerns about allegation which fall within the scope of specific procedure on will be referred for consideration under those procedures.
The Committee Members will report to the Committee Chairman on a periodic basis about the reports received and action taken.
​
The Management reserves the right to make any decision based on the findings by the Committee.
​
12. REVIEW OF POLICY
The Audit Committee will conduct annual review of this Policy to ensure its relevance. Where necessary, amendment(s) will be made to the Policy from time to time.
A copy of the updated Policy will be available for reference in the Company’s intranet.
​
1. INTRODUCTION
Jason Marine Group Ltd ("JMG" or the "Company", and its subsidiaries collectively known as the "Group") is committed to conduct our businesses and operations in an honest and ethical manner.
We adopt a zero-tolerance approach to bribery and corruption and are committed to acting professionally, transparently and fairly with integrity in all our business dealings and relationships as well as implementing and enforcing effective systems to counter bribery and corruption.
This anti-bribery and corruption policy (the "Policy") sets out JMG’s policies and guiding principles to conduct our businesses with honesty, fairness and high ethical standards. This Policy sets out the minimum standard that must be followed. Where local laws, regulations or rules impose a higher standard, that higher standard must be followed.
This Policy applies to all employees (full and part-time), contract workers, consultants, officers and directors of the Group ("JMG Persons") in Singapore and any other countries in which the Group operates. JMG employees who are directors on boards of joint ventures where JMG does not have a controlling interest should encourage the joint venture to adopt this Policy or use a similar policy.
As part of our commitment to conduct our businesses with honesty, fairness and high ethical standards, we also need to ensure that people acting on our behalf do so in compliance with this Policy. Please refer to Section 4 below.
​
2. GENERAL PRINCIPLES
JMG Persons may not, directly or indirectly, (i) offer, (ii) promise, (iii) agree to pay, (iv)authorise payment of, (v) pay, (vi) give, (vii) accept, or (viii) solicit Anything of Value to or from any third party in order to secure or reward an improper benefit or improper performance of a function, activity or to procure an unfair business advantage.
Prohibited payments, offers or receipts are not permitted at all times, whether or not they are given to or received from a Government Official or to any person in a private enterprise, business or entity, and regardless of whether they are given or received directly or indirectly by another person or entity on behalf of the Company.
If the employee has to accept the gifts in-kind such as festive hampers due to courtesy, the employee shall submit a declaration of the gift to the respective BU Head’s office for a decision on the manner of disposal or distribution of the gift/s within 2 weeks’ time. The declaration shall include information on the type of gifts name, address and telephone number of the sender so that an acknowledgement of thanks from the company be send back to the sender as soon as possible.
This Policy is to be read in conjunction with other related policies including the JMG Code of Conduct, which sets limits on receipts and presenting of gifts.
​
3. DEFINITION(S)
What does "Anything of Value" mean?
"Anything of Value" means bribes, kickbacks, a financial advantage, services, favours or any other direct or indirect benefit or gratification, whether in cash or in kind, tangible or intangible. The term "Anything of Value" has a wide application. Examples of these include but are not limited to gifts, meals, entertainment, discounts that are out of the ordinary or routine businesses, offers of employment or charitable contributions, including any gratification, services or favours which may not have a tangible or direct financial value attached, such as sexual favours. Prohibited payments can also include what is known as "facilitation payments" which are routine payments typically made to low-level Government Officials to expedite or secure a service or routine action.
Offers of employment or any other benefits, tangible or intangible, made or given to family members of other counterparties (including parties who are not Government Officials) would also be prohibited.
Who is a "Government Official"?
A "Government Official" includes any elected or appointed official of a national or local governmental entity of any country; representatives or employees of a government agency at any level, including customs, immigration and transportation workers, military personnel, representatives of political parties, candidates for political office, representatives of public international organizations (e.g., the Maritime Authorities, United Nations, the World Bank, the International Monetary Fund), employees of state-owned or controlled entities in any part of the world (e.g., state-owned airlines, banks or other postal agencies) and any entity hired by a government agency or instrumentality for any purpose (e.g., consultants, marketing or advertising agencies)
4. CONSULTANTS, REPRESENTATIVES, AGENTS AND INTERMEDIARIES (“THIRD PARTIES”)
​
All third parties who represent us, or who are our suppliers, contractors or other business partners are required to comply with this Policy, and not engage in any form of bribery or corruption.
We adopt zero-tolerance policy towards any form of bribery or corruption, and do we wish to be held liable for, any of our third parties who may have made any bribes whilst acting for us, whether with or without our knowledge. Accordingly, it is very important that the requisite and proper due diligence of all third parties representing us or providing services to us, are undertaken before we engage such third parties. These third parties should also undertake not to engage in any form of bribery or corruption.
​
5. VIOLATIONS AND DISCIPLINARY ACTION
​VIOLATIONS AND DISCIPLINARY ACTIO
JMG could be subject to serious criminal and civil penalties for violating applicable anti-corruption laws, as well as reputational damage for association with corrupt activities, significant costs associated with investigations of allegations of corrupt activities, debarment from government contracting, and denial of export privileges, as well as civil suits by shareholders, clients and competitors. JMG directors, supervisors, employees, and third parties who violate applicable anti-corruption laws may also be subject to severe criminal and civil penalties, including imprisonment and substantial fines. Failure to comply with this Policy may result in disciplinary action, up to and including termination.
​
6. WHISTLEBLOWING
​
Any JMG Person who observes or suspects that another JMG Person or anyone else may be acting in contravention of this Policy has an obligation to report it. All such concerns may be reported via any of the following reporting channels:
Email: whistleblow@jason.com.sg
Mail:194 Pandan Loop, Pantech Business Hub, #06-05, Singapore 128383.
Attention: Joseph Foo (CEO) or Constance Koh (ARC Chair)​​​​​
​
All complaints will be promptly and thoroughly investigated, and the investigation will be dealt with in confidence and on a need-to-know basis in accordance with the Group’s Whistle Blowing Policy. Any JMG Person who fails to report known or suspected violations may be subject to disciplinary action including termination of employment.