Compliance_Jereh Group

Compliance

As an international provider of oil & gas, power and environmental-related services, Jereh operates in countries with different values and legal systems. All employees at Jereh are required to comply with all laws applicable to the Group's business. And everyone receives training in this regard because it is our common commitment and responsibility to adhere to integrity and compliance. The Group adopts a “zero tolerance” attitude towards non conformances. Any employee who does not follow corporate polices/procedures will be subject to disciplinary action. The Group requires all employees involved in international procurement, sales and export to fully understand the export control and sanctions laws related to their work, to participate in the compliance trainings organized by the Group, to report potential compliance issues, to maintain accurate work records, and to report problems to superior management or compliance personnel. The Compliance Committee supports Jereh’s employees in avoiding non-compliance and the risks by providing targeted information, legal advice and regular training.

Jereh’s effective compliance management has won praise from the world's top law firm. The specific measures are as follows:

• Establish the International Business Compliance Department (“IBCD”), which reports directly to the Group’s Chief Legal Officer. The IBCD is responsible for the investigation and examination of the Group’s business transactions in terms of compliance and authorized to suspend any business suspected of non-compliance.

• Establish the Compliance Committee. Each department, business unit, subsidiary and sub-group has its compliance representative and the chief in charge of these organizations is the first responsible person in compliance and signs the Compliance Undertaking Letter.

• Invite Hogan Lovells US LLP, a world class law firm, to help establish a comprehensive compliance system and procedures, and formulate universal and exclusive regulations for specific countries.

• Apply automated screening procedures as well as review of products, usage, users and destinations of related transactions.

• Implement comprehensive compliance control in procurement, sales, finance, legal affairs, logistics, after sales, customer visits, business travel, visa application, etc.

• Organize compliance trainings and assessment for all relevant employees and include compliance training as a part of corporate culture training for new comers, in order to enhance the compliance awareness of the personnel and form a good compliance culture.

• Conduct compliance risk assessments of export control and audit the Group’s compliance system and procedures on a regular basis.

• Adopt the veto power mechanism to determine the punishment of any offending personnel, management or team, as severe as the termination of labor contract.

• Employees should report to their compliance representative or the IBCD if there is any non-compliance.