EJA Whistleblowing Policy and Procedure

It is the policy of Estaleiro Jurong Aracruz Ltda (“EJA” or the “Company”), as part of the Sembcorp Marine (“SCM”) group, to encourage the reporting by any person of any possible improprieties in financial reporting or other related matters that he/she may encounter.

Improprieties are actions, misconducts or infringements/non-compliance that are likely to or have resulted in loss of reputation, assets, and/or misstatements of financial results, and/or negative impacts to the businesses/operations. Examples of possible improprieties include, but are not limited to:

  • Non-compliance with EJA’s Anti- Bribery Compliance Policy,
  • Fraud, corruption, bribery and violations of applicable anti-corruption laws (including Brazilian law Nº. 12.846/13),
  • Money laundering,
  • Misappropriation / misuse of company assets,
  • Inappropriate acts or inadequate controls that may cause financial loss or damage to SCM or Company´s reputation, and
  • Acts or omissions that are likely to or do deceive or mislead internal or external auditors or accountants relating to the preparation or audit of Company’s records or financial statements.

NO RETALIATION

  • EJA will not accept any retaliatory action taken against any whistleblower that has filed any complaint alleging possible improprieties.
  • EJA does not tolerate any report made maliciously, in bad faith, or considered in abuse of the reporting system and will take corrective actions, in accordance with the Company´s Human Resources Department rules and policies and applicable legislation.
  • EJA may take disciplinary action against any person who threatens to take or is found to have taken retaliatory action.
  • Any complaint alleging retaliatory action shall be received, reviewed and investigated by the Company in the same manner as any complaint alleging possible improprieties.

ANONYMITY

  • Complaints can be filed anonymously but whistleblowers are encouraged to disclose their identity.

CONFIDENTIALITY

  • The identity of a whistleblower and the information provided, so disclosed, shall be kept confidential.
  • Investigation reports and records under this policy are confidential and are not to be released by EJA nor by the appointed investigation team, except if required by law, order or direction of any court, regulatory body or the information is provided to the relevant authority for criminal investigation.

COMPLAINT MONITORING

  • Subject to any legal constraints, any whistleblower can follow, at any time, through a specific protocol number, the status of the complaint.
  • The same protocol number also allows the whistleblower to communicate with the investigation party, and vice versa.
  • If a complaint is deemed to contain inadequate and/or insufficient detail and the necessary supporting information cannot be obtained from the whistleblower(s) then an investigation may not necessarily be carried out.
  • Feedback from the investigation may be made to the whistleblower, anonymous or not, however, the feedback may be generic, taking into account the Company's interest in protecting its confidential information, as well as the rights of third parties.

LODGE A COMPLAINT

All information will be received by an independent third party, both in Portuguese and English, and after the complaint is registered, will be forwarded to EJA Internal Audit for appropriate handling.

A complaint can be submitted to the independent third party through one of the following channels:

  • Website: www.contatoseguro.com.br/jurong,
  • E-mail: Este endereço de e-mail está protegido contra spambots. Você deve habilitar o JavaScript para visualizá-lo. , or
  • Hotline: 0800 800 8028.

 

 

 

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EJA Whistleblowing Channel

• Access the form to make your complaint

• Call to toll-free number 0800 800 8028

• Send an e-mail to denuncia@jurong.com.br


ARACRUZ / ES: +55 27 2237-6900 / +55 27 3270-6900 / +55 27 3270-6940