Whistleblowing Policy

1. INTRODUCTION

JEP Holdings Ltd ("JEP") and the JEP group of companies (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.

While the Policy is meant to protect genuine whistleblowers from any unfair treatment as a result of their report, it strictly prohibits frivolous and bogus complaints. The Policy is also not a route for taking up personal grievances.

2. OBJECTIVES

The objectives of this Policy are to:

  • Deter wrongdoing and to promote standards of good corporate practices;
  • Provide proper avenues or channels for employees and any other persons to raise or report any concerns/issues about actual or suspected improprieties in matters of financial reporting or other matters and receive feedback on any action taken; and
  • Give employees the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.

3. REPORTABLE INCIDENTS

(a) Some examples of concerns covered by this Policy include (this list is not exhaustive):

  • Concerns about the Group's accounting, internal controls or auditing matters;
  • Breach of or failure 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 non-financial 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;
  • Any other acts that may have a material impact on the Group's operating results or financial position; and
  • Concealing information about any malpractice or misconduct.

(b) 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.

4. COMMITTEES

The official avenues or channels referred to are two committees specifically set up to look into such issues/concerns raised by employees:

(a) JEP Whistleblowing Committee ("JWBC") - consisting of Chief Executive Officer, Group Financial Controller and HR Manager. JWBC is empowered to look into all issues/concerns relating to the organisation (except for issues/concerns that are directed specifically on or affecting any JWBC members). The JWBC shall make the necessary reports and recommendation to the Audit and Risk Committee and for its review and further action, if deemed required by them. For serious or criminal offences, the JWBC shall have access to the appropriate external professional advice where necessary and may at its discretion report the matter to the Commercial Affairs Department or other relevant Government or external authorities for further investigation.

(b) Audit and Risk Committee ("ARC") - consisting of independent Directors of the Board. The ARC shall look into the reports and recommendations from the JWBC, as well as issues/concerns relating specifically or concerning any members of the JWBC. The ARC shall present the necessary reports and recommendation to the JEP Board and for its review and further action, if required. For serious or criminal offences, the ARC or the Board shall have access to the appropriate external professional advice where necessary and may at their respective discretion report to the Commercial Affairs Department or other relevant Government or external authorities for further investigation.

5. IMPORTANT NOTES TO WHISTLEBLOWERS

(a) The Group encourages the whistleblower to identify himself/herself when raising a concern or providing information.

(b) The Group will treat all reports, concerns and information provided with strict confidentiality and will only reveal them on a "need to know" basis for the purposes of investigating the reports.

(c) The Chairman of the Audit and Risk Committee ("ARC") will have the ultimate discretion whether to reveal the identity of the whistleblower. If the identity is necessary to be revealed, permission from the whistleblower would be obtained before the information is released.

(d) The same shall apply if the "whistleblower" is not an employee of the Group.

(e) 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 the public domain
  • Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; or
  • Where the information is given to the police or other authorities for criminal investigation.

(f) In the event that the JWBC or the ARC, as the case may be, are faced with a circumstance not covered by the above, and where the whistleblower's identity is to be revealed, the investigator will endeavour to discuss this with the whistleblower first.

(g) No action of any kind will be taken by the Group against a whistleblower nor will his or her position in the Group be adversely affected by his/her merely raising the concerns/issues or making an allegation against a company official; provided always that he or she raises the concerns/issues or allegations in good faith and without malice and has reasonable ground believing them to be true.

(h) The JWBC or the ARC (as appropriate) will take all reasonable measures to ensure that whistleblowers will be protected from any plausible reprisals by any company officials or fellow colleagues.

(i) A malicious or frivolous complaint or allegation made by an employee against company officials or fellow colleagues, however, may result in the Group, after proper investigation, taking disciplinary action against him or her.

(j) 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.

(k) The earlier the concern is raised the easier it is for the Group to take action.

6. SUBMISSION OF ISSUES/CONCERNS

(a) For issues/concerns relating to all matters (except those concerning any member of the JWBC), the employee or any other persons may raise the issue with or send his/her concern to:

  • Any member of the JWBC via email communication at JWBC@jep-holdings.com; or
  • Mail address: 16 Seletar Aerospace Crescent Singapore 797567, attention to "The JEP Whistleblowing Committee"

(b) For issues/concerns relating to or concerning any member of the JWBC, the employee or any other persons may raise the issue with or send his/her concern to:

  • The Audit and Risk Committee Chairman, Mr Kong Chee Keong, via email communication at ckkong@jep-holdings.com; or
  • Mail address: 16 Seletar Aerospace Crescent Singapore 797567, attention to "The Chairman of JEP Holdings Ltd Audit and Risk Committee"

Whistleblowers should provide background, history of events and reasons for concern.
If unsure of what to submit, the whistleblower may use the "Whistleblowing Form" in the appendix.

Note:
(All submissions are kept strictly confidential and any contact information you provide to the JWBC and/or the ARC will only be used to follow up with you regarding your submission. You may also choose to submit a disclosure anonymously without submitting any contact information. However, please be aware that anonymous disclosures may limit our ability to respond to the information that you provide.)

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