APPLICABLE TO ALL DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES OF THE COMPANY PHILOSOPHY JSAW is a prfessinally managed rganisatin and the cre value underlying ur crprate philsphy is "trusteeship". We believe this rganisatin has been handed t us by the varius stakehlders in "trust" and we as prfessinals are the "trustees" f these stakehlders. It is therefre ur respnsibility t ensure that the rganisatin is managed in a manner that prtects and furthers the interests f ur stakehlders. We recgnise sciety as an imprtant stakehlder in this enterprise and therefre it is part f ur respnsibility t practice gd crprate citizenship. It is als ur belief that in rder t serve the interests f ur stakehlders in perpetuity, we must build JSAW int an institutin whse dynamism and vitality are anchred in its cre values. CORPORATE GOVERNANCE POLICY The Crprate Gvernance Plicy is the apex level instrument guiding cnduct f the affairs f the Cmpany and clearly delineates the rles, respnsibilities and authrities f the key entities in the gvernance structure f the Cmpany. This Cde frms an integral part f the Cmpany's Gvernance Plicy. The directrs, senir management and emplyees must adhere t the Crprate Gvernance Plicy f the Cmpany. GOOD CORPORATE CITIZENSHIP In the cnduct f the Cmpany's business, the practice f gd crprate citizenship is a prerequisite and embraces the fllwing : Dealing with Peple in the Organisatin In dealing with each ther, directrs, senir management and emplyees shall uphld the values which are at the cre f ur HR Philsphy - trust, teamwrk, mutuality and cllabratin, meritcracy, bjectivity, self respect and human dignity. Indeed, these values frm the basis f ur HR management systems and prcesses. In selectin and recruitment, while meritcracy will be a prime criterin, managers will scrupulusly cnsider all factrs that g twards securing the interests f the Cmpany. JSAW will fcus n meritcracy, equity and uphlding f Cmpany values in all peple prcesses including perfrmance management systems, appraisals, remuneratin and rewards. 1
A Gender Friendly Wrkplace As a gd crprate citizen, JSAW is cmmitted t a gender friendly wrkplace. It seeks t enhance equal pprtunities fr men and wmen, prevent/stp/redress sexual harassment at the wrkplace and institute gd emplyment practices. Sexual harassment includes unwelcme sexually determined behavir such as: unwelcme physical cntact; a demand r request fr sexual favurs; sexually clred remarks; shwing prngraphy and any ther unwelcme physical, verbal r nn-verbal cnduct f a sexual nature. JSAW maintains an pen dr fr reprtees; encurages emplyees t reprt any harassment cncerns and is respnsive t emplyee cmplaints abut harassment r ther unwelcme and ffensive cnduct. JSAW demands, demnstrates and prmtes prfessinal behavir and respectful treatment f all emplyees. Relatinships with Suppliers and Custmers All directrs, senir management and emplyees shall ensure that in their dealings with suppliers and custmers, the Cmpany's interests are never cmprmised. Accepting gifts and presents f mre than a nminal value, gratuity payments and ther payments frm suppliers r custmers will be viewed as serius breach f discipline as this culd lead t cmprmising the Cmpany's interests. Legal Cmpliance It is the Cmpany's plicy t cmply fully with all applicable laws and regulatins. Ensuring legal and regulatry cmpliance is the respnsibility f the SBU-Heads and Heads f Departments. The Cmpany cannt accept practices which are unlawful r may be damaging t its reputatin. SBU Heads must satisfy themselves that sund and adequate arrangements exist t ensure that they cmply with the legal and regulatry requirements impacting each business and identify and respnd t develpments in the regulatry envirnment in which they perate. In the event the implicatin f any law is nt clear, the Cmpany's Legal Department shall be cnsulted fr advice. 2
Health and Safety The Cmpany attaches great imprtance t a healthy and safe wrk envirnment. JSAW is cmmitted t prvide gd physical wrking cnditins and encurages high standards f hygiene and husekeeping. Particular attentin shuld be paid t training f emplyees t increase safety awareness and adptin f safe wrking methds, particularly designed t prevent serius r fatal accidents. Envirnment Plicies The Cmpany believes that cmmitment t sustainable develpment is a key cmpnent f respnsible crprate citizenship and therefre deserves t be accrded the highest pririty. Accrdingly, the Cmpany is cmmitted t Best Practices in envirnmental matters arising ut f its business activities and expects each business t fully demnstrate this cmmitment. In additin t cmplying with applicable laws and regulatins, Businesses must establish prcedures fr assessing the envirnmental effects f their present and future activities. They shuld adpt Best Practices in their envirnmental plicies and prcedures. PERSONAL CONDUCT All directrs, senir management and emplyees have the bligatin t cnduct themselves in an hnest and ethical manner and act in the best interest f the Cmpany at all times. They are expected t demnstrate exemplary persnal cnduct thrugh adherence t the fllwing: Avidance f Cnflict f Interest All directrs, senir management and emplyees must avid situatins in which their persnal interest culd cnflict with the interest f the Cmpany. This is an area in which it is impssible t prvide cmprehensive guidance but the guiding principle is that cnflict, if any, r ptential cnflict must be disclsed t higher management fr guidance and actin as apprpriate. 3
Transparency and Auditability All directrs, senir management and emplyees shall ensure that their actins in the cnduct f business are ttally transparent except where the needs f business security dictate therwise. Such transparency shall be brught abut thrugh apprpriate plicies, systems and prcesses, including as apprpriate, segregatin f duties, tiered apprval mechanism and invlvement f mre than ne manager in key decisins and maintaining supprting recrds. It shall be necessary t vluntarily ensure that areas f peratin are pen t audit and the cnduct f activities is ttally auditable. Prtectin f Cnfidential Infrmatin N directr, senir management and emplyee shall disclse r use any cnfidential infrmatin gained in the curse f emplyment/ assciatin with the Cmpany fr persnal gain r fr the advantage f any ther persn. N infrmatin either frmally r infrmally shall be prvided t the press, ther publicity media r any ther external agency except within apprved plicies. Cmpany Facilities N directr, senir management and emplyee shall misuse Cmpany facilities. In the use f Cmpany facilities, care shall be exercised t ensure that csts are reasnable and there is n wastage. Leading by Example The rganisatin's directrs and senir management set the prfessinal tne fr the Cmpany. Thrugh bth their wrds and their actins, the rganisatin's leadership cnveys what is acceptable and unacceptable behaviur. JSAW's directrs, senir management and emplyees must cnstantly reinfrce thrugh their actins and behaviur that JSAW's stated beliefs f respnsible crprate citizenship are rted in individual cnvictin and persnal integrity. Waivers Any waiver f any prvisin f this Cde f Cnduct fr a directr, senir management r emplyee must be placed fr apprval befre the Cmpany's Bard f Directrs/ Crprate Management Cmmittee, as apprpriate. 4
Nn Adherence Any instance f nn-adherence t the Cde f Cnduct / any ther bserved unethical behaviur n the part f thse cvered under this Cde shuld be brught t the attentin f the immediate reprting authrity, wh shall in turn reprt the same t the Head f Crprate Human Resurces. x-x-x-x-x 5