End-to-End Systems Integration Solution Provider

 

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.

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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.

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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”)

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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.

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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.

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6. WHISTLEBLOWING

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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)​​​​​

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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.