JARDINE, MATHESON & CO., LIMITED NOTICE TO NEW EMPLOYEES AND JOB APPLICANTS RELATING TO THE PERSONAL DATA (PRIVACY) ORDINANCE (THE ORDINANCE )

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1 JARDINE, MATHESON & CO., LIMITED NOTICE TO NEW EMPLOYEES AND JOB APPLICANTS RELATING TO THE PERSONAL DATA (PRIVACY) ORDINANCE (THE ORDINANCE ) Definition The Group means all subsidiaries and associates of Jardine Matheson Holding Limited. The Company means Jardine, Matheson & Co., Limited. New employees and job applicants of the Company should read this notice carefully. If you are in any doubt as to its meaning or application, you should consult the Group Human Resources Department of Jardine, Matheson & Co., Limited at ghr@jardines.com. 1. COLLECTION OF PERSONAL DATA DURING THE RECRUITMENT PROCESS Applicants for employment with the Company are required to provide the Company with sufficient personal data in connection with their application. At a minimum, such personal data will include: the applicant's name and contact details, including address and telephone number(s); previous employment and relevant experience; and education background and relevant training. Additional information may also be required dependent on the nature of the position being applied for. 1

2 2. CONSEQUENCE OF FAILURE TO SUPPLY ACCURATE DATA The applicant is responsible for ensuring all personal data he/she provided is accurate and complete. The provision of inaccurate information or the withholding of requested information may: prevent the Company from processing his/her application and making an offer of employment; invalidate such an offer if the inaccuracy or omission is discovered after an offer has been made; or lead to termination of employment if the inaccuracy or omission is discovered after employment has commenced. 3. COLLECTION OF PERSONAL DATA AFTER EMPLOYMENT If an application for employment is successful, data about employees may also be collected from employees during the period of their employment with the Company. 4. PURPOSES FOR WHICH THE DATA MAY BE USED Data relating to the employees and potential employees are collected, held, used, processed or transferred for purposes related to the employment or prospective employment with the Company, including: (d) the processing of employment application; the verification of credentials and/or experience; the performance of security vetting and/or integrity checking; human resources management purposes, such as: the planning and implementation of staffing and training; promotions, transfers, secondments, termination and other career related matters; the review, implementation and administration of staff benefits, and payroll and pension funds administration; 2

3 (e) (f) (g) (h) the provision of employee references upon employees requests; the monitoring of the compliance of the internal code of conduct of the Group; intra-group communications; and any other purposes relating to any of the above. 5. ONLINE APPLICATION The Company may collect online applications. All online applications received will be downloaded to our local disk drive for storage. In addition, communication (e.g. regarding the application status/result) sent by the Company to employment applicants, either online or not, maybe through either the or postal service or any other means, at the discretion of the Company. 6. RETENTION OF PERSONAL DATA Personal data of the employees and job applicants will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless such data is also retained to satisfy any applicable statutory or contractual obligations. Personal data of the employees and job applicants will be erased when the purposes of collection are fulfilled and the applicable statutory or contractual obligations (if any) have been discharged. 7. TRANSFER OF PERSONAL DATA Personal data held by the Company will be kept confidential but subject to the provisions of any applicable law, the Company may provide such information to the following parties for the purposes set out in paragraph (4) above: any other companies, operating unites/departments and/or central services department within the Group other than the Company; any agents, contractors or third parties who provide administrative or other 3

4 (d) (e) (f) services to the Group in Hong Kong and elsewhere and who have a duty of confidentiality to the Group; examples of such persons: external auditors, medical practitioners, trustees, insurance companies, actuaries and any consultants / agents appointed by any Group members to plan, provide and / or administer employee benefits; any persons seeking employee references in respect of employees with the prescribed consent of the employee concerned in accordance with Section 2(3) of the Ordinance; any persons or companies who are acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided; any persons or companies who are under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such persons or companies have a legitimate right to such information; any actual or proposed purchasers of all or part of the business of the Company or, in the case of any mergers, acquisition or other public offering, the purchasers or subscribers for shares in the Company; and Personal data may also be disclosed to any persons, companies or institutions pursuant to any statutory or contractual obligations or as required by court of law, provided such persons, companies or institutions are able to prove the required right/authority to access such information. In addition, personal data may be disclosed under any of the circumstances described in Part VIII of the Ordinance in which the concerned personal data are exempt from the provisions of Data Protection Principle 3 of the Ordinance. At times it may be necessary and/or prudent for the Company to transfer certain personal data to places outside of Hong Kong in order to carry out the purposes, or directly related purposes for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance. 4

5 8. ACCESS AND CORRECTION OF PERSONAL DATA Under the Ordinance, you have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, and to correct your personal data that is inaccurate. You also have the right to ascertain the Company s policies and practices in relation to personal data and to be informed of the type of personal data held by the Company. Requests for access to data or correction of data or for information regarding policies and practices and kinds of data held and should be addressed in writing to the Group Human Resources Department of Jardine, Matheson & Co., Limited at ghr@jardines.com. A reasonable fee may be charged to offset our administrative costs in complying with your access requests. The Company will, upon satisfying itself of the authenticity and validity of the correction request, make every endeavor to comply with and respond to the request within the period set by the Ordinance (i.e. within 40 days after receiving the request). If the request to access to personal data or correction of personal data is to be refused on one of the grounds permitted under the Ordinance, the reason of refusal will be given to you and the details of refusal will be recorded in a log book of the Company which should be kept for 4 years. 5