OUR COMPANY POLICY

 

OUR SECURITY POLICY

Mentor Media is committed to ensure

  • All security requirements required to protect the employees’, stakeholders’ and customers’ interests are established and maintained.
  • Customers’ intellectual property and information are protected and secured.
  • Customers’ security requirements are being understood and complied with.
  • All security requirements are being communicated to and understood by all employees at all levels.

OUR CORPORATE QUALITY POLICY

  • The management and staff of Mentor Media are committed to satisfy our customers’ expectations in terms of uncompromising quality, competitive pricing and timely delivery of customized manufacturing services.
  • Employees are trained on the principles and methods to achieve quality improvements, compliance to defined requirements and improving Quality Management System.
  • Mentor Media is ISO 9001:2000 certified and we will conduct our business in compliance with the highest standards as defined by this certification.

OUR CORPORATE ENVIRONMENTAL POLICY
Mentor Media’s activities interact with the environment, since the products we manufacture makes use of resources from nature and the processes we carry out impacts the environment.

Our activities would not be possible without the resources available in the surroundings in which we operate. We have a strong interest in preserving this environment, which is necessary for our long-term viability. As such, Mentor Media fully complies with the stringent standards defined by ISO 14001:2004.

We are committed to

  • Comply with all applicable laws, regulations and standards.
  • Undertake programs for continual environmental improvement and prevention of pollution.
  • Reduce the use of environmental unfriendly materials and products.
  • Strive to develop sustainable alternatives by adopting new technologies, when available.
  • Reduce resource consumption and waste generation.
  • Provide necessary training and support to staff on eco-friendly practices.
  • Undertake constant reviews to ensure compliance with this policy.

CORPORATE WHISTLEBLOWING POLICY AND PROCEDURES
Purpose
Mentor Media Limited (“The Company”) practices zero tolerance towards any form of malpractice, impropriety, statutory non-compliance or wrongdoing by our employees during the course of our work. This Corporate Whistleblowing Policy is intended to guide and promote responsible and secure whistleblowing and protect the whistleblower from fear of adverse consequences from the direct managers/supervisors.

Employees and external parties, such as suppliers, customers, contractors and other stakeholders, may use the procedures set out in the Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, collusion with competitors, serious breaches of Group policy, unsafe work practices or any other matters involving fraud, corruption and employee misconduct.

The Policy allows for reporting by employees or external parties of such matters directly to the Company without the need to copy your direct managers/supervisors as well as without fear of reprisal, discrimination or adverse consequences, and also permits the Company to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.

However, while the Policy is meant to protect genuine whistleblowers from any exposure to unfair treatment as a result of their report, it also strictly prohibits frivolous, false and unsubstantiated complaints. The Policy is also not a channel for personal grievances experienced in the course of work. These personal grievances should continue to be taken up directly with Division or Department heads in line with the Grievance Policy and its governing procedures.

Reporting process
The Company encourages employees and external parties to put their names to their allegations whenever possible. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided. All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.

Concerns may be raised verbally or in writing. As it is essential for the Company to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The complaint should include:

  1. Details of the person/persons involved in the incident
  2. Dates and time of incident
  3. Type of incident (eg. theft, vandalism, safety violations, etc)
  4. Evidence supporting the complaint, where possible (eg. photographs, video footages,eye-witness accounts, etc)
  5. Contact details of the whistleblower, in case further information is required

The Receiving Officer is the Group Senior Vice President of Human Resources. The contact details of the Receiving Officer are as follows:

Address: Mentor Media Ltd, 47 Jalan Buroh, #08-02, Singapore 619491
Hotline: +65-6631-3399
Email : whistleblow@mentormedia.com

All matters reported will be reviewed within a reasonable timeframe, and after due consideration and internal inquiry, a decision will be taken on whether to proceed with a detailed investigation. Direction may be sought from the CEO. While all complaints received by the Receiving Officer will be reported to the CEO, whistleblowing complaints alleging fraud and breaches of corporate governance may be escalated to the Chairman of the Board of Directors subject to the recommendation of the CEO.

Protection
The Company prohibits discrimination, retaliation or harassment of any kind against a whistleblower who submits a complaint or report in good faith. Employees shall be protected against retaliatory actions resulting from reporting unethical conduct to their superior. If a whistleblower believes that he/she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy who feel that adverse action has been taken toward him/her due to a report of improper activity, the Receiving Officer should be similarly notified immediately. Reporting should be done to facilitate investigation and the taking of necessary action, if any.

At the appropriate time, the party making the report may need to come forward as a witness. If an employee or external party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. If, however, an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the external party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

The Company will not retaliate against employees or external parties who in good faith, has reported suspected illegal activity or conduct of another entity that Company has a business relationship with, if the employee has a reasonable belief that the activity or conduct is in violation of law.

Processing complaints
The Receiving Officer, may, in consultation with the CEO, direct the complaint to the relevant internal support function best placed lead the investigation to ensure prompt, independent and appropriate investigation and resolution. All information disclosed during the course of investigation will remain strictly confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

The Company reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.

If, at the conclusion of an investigation, the Company determines that a violation has occurred or the allegations are substantiated, effective remedial action commensurate with the severity of the offence may be taken.

Right of the Company
The Company may modify or vary this Policy to maintain compliance with applicable laws and regulations and accommodate organizational changes within the Company where applicable.

PRIVACY POLICY
Overview
Mentor Media Limited (“Mentor Media”) values the privacy of every individual and is committed to protecting the personal data it collects in accordance with the principles set out in this Policy.

Scope
In accordance with the privacy laws and/or data protection laws of the countries in which Mentor Media operates, this Privacy Policy (“Policy”) outlines how we manage the collection, use, disclosure and handling of your personal data in accordance with these legal requirements.

Principles
Personal Data
In this Policy, “personal data” means any data, whether true or not, about an individual who can be identified either from that data, or from data and other information to which Mentor Media has or is likely to have access.

Personal Data Collection
To enable us to fulfill our responsibilities as an integrated provider of supply chain solutions and, in the case of our Mentor Media businesses, our responsibilities as a business partner, Mentor Media may collect personal data about its employees, customers, suppliers, sub-contractors and others with whom it deals, to enable Mentor Media to effectively conduct its businesses. This personal data must be sufficiently detailed for Mentor Media to effectively conduct its businesses. Where Mentor Media collects data on its employees, additional requirements may apply. Please contact the local site Manager/Director in the jurisdiction where you are employed for additional information in relation to employee information.

You are not required to supply any of the personal data that we may request. However, if the personal data we request is not provided adequately, we may not be able to provide the required services in the most effective or efficient manner, or at all.

We only collect personal data for our business purposes. For example, we collect information that is necessary for the establishment and maintenance of records for our employees, customers, suppliers of goods and services, sub-contractors and others with whom we conduct business in order for Mentor Media to work effectively with them.

We generally collect personal data directly from you in person, in writing, by facsimile, by telephone, by email or via our websites. For example, we may collect information when you ask us to provide services to you.

We may also collect personal data via third parties for the purpose of fulfilling the required service requested or so as to work effectively with our employees, customers, suppliers of goods and services, sub-contractors and others with whom we conduct our business. For example, if we deliver a service to your organization, we may collect personal data from the organization purchasing the service.

Collection Of Information Via Our Websites
When you visit one of our websites, information about your computer or web device is automatically recorded by our website. This includes your IP address and associated domain name, the date and time of your visit to our site, the pages you accessed or downloaded, the address of the last site you visited, your operating system and the type of browser you used. This information may be collected by us or by a third party service provider on our behalf. This information is collected for statistical and system administration purposes, and to improve our web based services. It does not readily identify individuals, and we will not attempt to identify individuals from the records our server generates unless it is necessary to do so for law enforcement purposes. By continuing to access this website or by providing personal data through our website, you consent to the collection, use and disclosure of your personal data by us in accordance with this Policy. If you do not consent to the terms of this Policy, please exit our website and refrain from providing your personal data to us through our website.

Use And Disclosure Of Personal Data
Mentor Media will only use and/or disclose collected personal data for the purposes for which it was collected or for purposes permitted by law.

Mentor Media uses and/or discloses personal data to provide, manage and administer the goods and services it provides. Consistent with these purposes, in the normal course of our business operations we may disclose personal data to related bodies corporate, government or regulatory entities, as well as to our legal advisers, auditors or our contract service providers who act for or on behalf of us, where applicable.

Personal data collected is also used and/or disclosed to facilitate distribution of corporate communications such as our financial results, audit and management reports and other information that is relevant to the promotion or reporting of our business activities.

Mentor Media reserves the right to transfer, and you consent to Mentor Media transferring, your personal data to another entity in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with the principles described in this Policy.

Transfer Of Personal Data Outside The Country In Which It Was Collected
Some organizations to which we disclose personal data may be located, or may store the personal data on data servers, outside the country in which the personal data was collected. Pursuant to any applicable privacy / data protection laws, your personal data may be disclosed, processed and transferred by Mentor Media on a worldwide basis for the purposes of providing our services. Personal data may be disclosed or transferred to agents or third parties authorized to act on our behalf for the purposes of providing our services.

Some countries may not provide the same level of protection for your personal information as the country in which your personal data was collected. Please note, however, that Mentor Media will use its own reasonable endeavours to enter into agreements with the recipients of the personal data in other countries so that they will adhere to similar data protection standards as provided in this policy and ensure that the recipient abides by Mentor Media’s obligations under any applicable privacy / data protection laws.

Access And Correction
We try to ensure that personal data we hold is accurate, complete and up to date. The company should respond to an access or correction request within 30 days from the time the request is made. If the company is unable to respond to the access (or correction) request within 30 days from the time the request is made, the company will inform the individual in writing within a time frame of the time by which it will be able to respond to the request. Subject to the payment of an administrative fee (if applicable), you have the right to access the personal data we hold about you and send a written request to our Privacy Policy Data Protection Office, Complaints and Inquiry Helpdesk (see below), including proof of your identity (e.g. a copy of your driving licence or passport), for details as to how your personal data has been used or disclosed by us within a year prior to your request.

You may also correct any inaccuracies in your personal data within our records. If you wish to correct such personal data, please also send a written request to our Privacy Policy Data Protection Office, Complaints and Inquiry Helpdesk, including proof of your identity (e.g. a copy of your driving licence or passport), specify the personal data which is incorrect and what it should be replaced with. We reserve the right to refuse access to or correct personal data in accordance with applicable privacy / data protection laws.

To ensure the integrity and safety of personal data, Mentor Media only discloses the personal data it holds pursuant to the above and only to the individual concerned, their legally authorized representative, or to fulfil legal or regulatory requirements.

Retention Of Personal Data
Mentor Media will destroy any personal data we hold about you when it is no longer necessary for legal or business purposes.

Security Of Personal Data
Personal data is principally held in electronic databases maintained within Mentor Media’s computer network. Mentor Media maintains appropriate administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure and/or use.

Use Of Our Websites
Our website may contain links to other websites that are not owned, operated or endorsed by us. We are not responsible for the privacy practices of those websites, or for the content, product or services provided by, or contained on, those websites.

Further Information
Mentor Media shall regularly review and improve its Privacy Policy in line with changes in its business operations as well as changes in its legal, social, and IT environments in which it conducts its business operations in.

Inquiries about the Privacy Policy, questions/inquiries on the handling of personal data as well as questions/inquiries regarding notification of intended uses of personal data and the disclosure, revision, addition, deletion, cessation of use, or cessation of provision to third parties of such data should be directed to thePrivacy Policy Data Protection Office, Complaints and Inquiry Helpdesk. Alternatively, you may also choose to address your concerns to the local site Manager/Director in the jurisdiction where you are employed for additional information in relation to employee information.

Privacy Policy Data Protection Office, Complaints and Inquiry Helpdesk
Email: CorporatePrivacyPolicy@mentormedia.com