Whistleblower Policy
Policy

Sinanju Tankers Holdings Pte Ltd and its group of companies (hereinafter referred to as “Sinanju”) is committed to the highest standards of honesty, transparency, ethical and legal conduct and accountability.

The whistleblower policy aims to provide an avenue for employees and external parties to raise genuine concerns relating to any aspect of Sinanju’s operations – at sea and on shore, including serious breaches of the code of conduct by office staff and ships’ crew.

Aim
The aim of the Whistleblower policy is to:
  1. Promote standards for good bunkering operations, financial and corporate practices and to deter wrongdoing.

  2. Provide proper avenues for employees and external parties to raise concerns about suspected improprieties and receive feedback on any action taken.

  3. Give employees and external parties the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.

Reportable Incidents
Some examples of concerns covered by this policy include:
  1. Impropriety, corruption, theft/misuse of Sinanju’s cargo/assets/resources.

  2. Conduct which is an offence or breach of law.

  3. Breach of or failure to implement or comply with Sinanju’s policies.

  4. Concerns about Sinanju’s accounting, internal controls or auditing matters.

  5. Serious conflict of interest without disclosure, resulting in material gain.

  6. Acts which 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 Sinanju.

  7. Abuse of power or authority.

  8. Physical and emotional bullying by colleague.

  9. Sexual harassment:
    a) Physical harassment (sexual gestures, inappropriate touching etc.).
    b) Verbal harassment (sexual comments/jokes, asking for sexual favours etc.).
    c) Visual harassment (showing derogatory or pornographic materials etc.).
    d) Any other serious improper matters which may cause financial or non-financial loss to Sinanju or damage to Sinanju’s reputation.

  10. Fraud or the making of fraudulent statements to members of the public and regulatory authorities.

  11. Concealing information about any malpractice or misconduct.

  12. Intentional provision of incorrect information to public bodies.

Protection against reprisals
  1. Sinanju recognises that the decision to report a concern can be a difficult one to make, not least, because of the fear of reprisal from those responsible for the alleged malpractice. Sinanju will not tolerate harassment or victimisation and will take all possible action to protect anyone who raises a concern in good faith.

  2. However, Sinanju does not condone frivolous, mischievous or malicious allegations and anyone making such allegations may face disciplinary action.

Confidentiality
  1. Sinanju requires the whistleblower to identify himself/herself when raising a concern or providing information.  All concerns will be treated with the strictest confidentiality.

  2. Exceptional circumstances under which information provided by the whistleblower could or would not be treated with confidentiality include:
    a) Where Sinanju is under a legal obligation to disclose information provided.
    b) Where the information is already in the public domain.
    c) Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice.
    d) Where the information is given to the police or other authorities for criminal investigation.

  3. In the event of a circumstance not covered by the above, and where the whistleblower’s identity is to be revealed, Sinanju will endeavour to discuss this with the whistleblower first.

  4. Anonymous complaints would be investigated only if there are clear merits for continuity.

  5. Social media and media contact – Sinanju staff and crew are bound by the company’s social media policy. Only official representatives of the company may release approved information through the proper channels.

Procedure
  1. Concerns should be raised in writing to the Managing Director, Directors or General Manager of Sinanju. Email:  wb@sinanju.com.sg

  2. The whistleblower should set out in detail the background and history of events and the reasons for the concern. Important points to note are:
    a) The earlier the concern is raised, the easier it is for Sinanju to take action
    b) Sinanju expects the whistleblower to provide his/her concern in good faith and to show that there are sufficient grounds for his/her concern
    c) Sinanju also recognises that the whistleblower may wish to seek advice and be represented by his/her advisor.

Proceedings upon disclosure
  1. Any concern raised or information provided will be investigated. Consideration will be given to these factors:
    a) Severity of the issue raised.
    b) Credibility of the concern or information.
    c) Likelihood of confirming the concern or information from attributable sources.

  2. Depending on the nature of the concern raised or information provided, the investigation may involve one or more of these persons or entities:
    a) The Investigation Committee appointed by the Managing Director.
    b) External and internal auditors.
    c) Forensic professionals.
    d) The police or Commercial Affairs Department.

  3. Further information may be sought from the whistleblower during the course of the investigation.

  4. The Investigation Committee will submit the findings and recommendation(s) to the Managing Director for his necessary action/advice.

  5. The whistleblower will be kept informed of the progress of the investigations and, if appropriate, of the final outcome.

Sinanju Tankers Holdings Pte Ltd

Sinanju Logistics Services Pte Ltd

Sinanju Marine Services Pte Ltd

Sinanju Shipping Pte Ltd

Sinanju Tankers Pte Ltd

 

61 Alexandra Terrace

#07-01 Harbour Link Complex

Singapore 119936

Tel:  +65 6376 5066

Fax: +65 6276 3736

Email: enquiry@sinanju.com.sg

© 2018 Sinanju Tankers Holdings Pte Ltd | All Rights Reserved | Legal Notice & Data Protection Policy

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