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 9001:2015 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 14001:2015.

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
Background
Mentor Media Ltd (“Mentor Media”) wishes to thank you for visiting our website and expressing interest in our company and the services we can offer you. We’re serious about your personal integrity. You should feel safe when you share your personal data with us. For this reason, we have established this policy. It’s based on the current data protection laws and clarifies how we work to protect your rights and your integrity.

The purpose of this policy is for you, as a visitor to our website, user of our services or receiver of products we distribute, to gain insight into how we process your personal data, what we use it for, who and under which circumstances we may share it with other parties as well as how you can take advantage of your rights.

What is personal data?
Personal data is information about a natural person that makes a person’s identity known or identifiable. Examples of information considered to be personal data may be a person’s name, address, email address or telephone number. Information which cannot be connected to a natural person is not deemed personal data.

Why do we need your personal data?
For the most part we need your personal data to fulfill our obligations to you. Our main objective is to never process more personal data than is necessary for the purpose, and we strive to always use the least integrity intrusive information possible.

We need your personal data to be able to provide you with good service when, for example, you use our various web-services or when you order the products we manufacture and/or distribute to you as the recipient.

Often we process your personal data in the role of the supplier of products and services on behalf of our customers. We apply the same principles as stated above when processing your personal data with the reservation that we may share this information with the customer, in their active role as the Controller, and on whose assignment we perform the services or offer the products to you.

When do we collect your personal data?
Communication
When you contact us via telephone, email or use an online contact form we may store the data you communicate to be able to answer your inquiries. This may include your name, email-address, telephone number and any other personal data you freely decide to share with us.

The legal basis for processing is mainly to fulfil our obligations to you and also legitimate interest, which is to provide quality services. We will retain this data if it is necessary for the purpose of your inquiry and delete it when it’s no longer needed if we are not obligated to retain it by law.

Order processing and fulfillment
The majority of the personal data we process relies on a main agreement between us and the company you are associated with, either as an employee or as part of a larger supply chain.

In cases were no such main agreement exists processing is based on the performance of a contract that either your request for a quotation or order confirmation constitutes, and your approval of our terms of service with associated information regarding processing of your personal data.

The personal data we need from you to be able to fulfill our obligations towards you may include: your name, email address, telephone number, company address, delivery address, invoice address, home address, the company you are associated with and information about which department or cost center you belong to.

We will retain your information if there is an active main agreement between us and the company to which you are associated.

Online applications and other it solutions
Online applications and other it solutions are often integrated services offered by us to our customers as part of a main agreement and to be used by you, as an employee or as part of a larger supply chain.

Using these solutions will, for the most part, require a user account to acquire access. For this reason, we may need to collect and process your personal data. The information we require is a username and a password but normally we also ask for your name and email address for the purpose of communicating with you.

The account information may require you to enter more personal data such as your company name and address, etc. This information, however, is for us to be able to perform the order processing and fulfillment part of our obligations towards you.

We will retain your information if there is an active main agreement between us and the company to which you are associated with.

Newsletters, press releases and financial reports
In some cases, we may need your personal data for other purposes beyond performance of contract. We will in such cases always ask for your consent for each individual purpose.

You have the right to, at any time, recall your consent. We will then no longer process your personal data or collect new unless it is needed to fulfill our obligations according to a contract or the law.

The period we process your personal data will be determined for each individual purpose for which you will give us your consent.

Third party analytics and tracking
We use analytics tools, such as Google Analytics, to help analyze how you use our website. While our use of analytics software always is steered towards the use of anonymized data it’s important for you to be aware of that much of the information we process is considered personal data under the current data protection laws. Below you can read more details about the information we collect, how we use this information but also how you, as a visitor of our website, may disable our collection of your data.

Google Analytics
The tracking information allows us to better understand the kind of people who come to our website and what content they’re reading. This allows us to make better decisions about design and writing. Occasionally, we will compile aggregate statistics about the number of visitors this site receives and browsers being used. No personally identifying data is included in this type of reporting. Google Analytics is also used to evaluate data from AdWords and the DoubleClick cookie for statistical purposes.

All of our activity falls within the bounds of the Google Analytics Terms of Service.

You may opt out of Google’s advertising tracking cookie or use a browser plugin to opt out of all Google Analytics tracking software.

Cookies
In order to make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.

In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website).

If you do not wish to receive cookies or want to be notified of when they are placed, you may set your web browser to do so if your browser so permits. Please note that if cookies are turned off, you may not be able to view certain parts of the website that may enhance your visit and you may be unable to use some or all of the functionality of the website and services.

You will find more information about cookies, how to tell which cookies are being stored, and how to manage or delete them, under www.allaboutcookies.org.

To adjust your current cookie settings, click on the button below:

Adjust cookie settings

What information do we give you?
When we collect your personal data for the first time we will inform you of how the information was obtained, what we aim to use it for, what rights you have in regards to the data protection laws and how you can uphold those rights. You will also be informed about who is responsible for the personal data processing (the “Controller”) and how you contact them if you have questions or need to make inquiries in relation to your personal data and/or rights.

How do we protect your personal data?
We have routines and work practices to ensure that your personal data is processed in a safe manner. Our starting point is that only employees and people within the organization that need access to your personal data to perform their work tasks should be granted access to them.

When it comes to personal data belonging to special categories we have access controls in place that result in even higher levels of protection.

Our security systems are developed and configured with focus on your integrity and are to a large extent protected against intrusions, accidental deletion or modifications that pose a risk to your personal integrity.

We have policies, guidelines, and instructions surrounding data protection and our employees are trained in current data protection laws to ensure that your personal data is processed safely.

However, if a security incident occurs, despite our best effort, and this incident could represent a high risk to your rights and freedoms, we will promptly inform you of such facts through the provided email address and post such information on our website, including necessary details.

We do not transfer your personal data to other parties for other purposes than expressively stated in this policy.

When do we share your personal data?
Our starting point is to not share your personal data with any third party if you have not given your consent or unless it’s necessary to fulfill our obligations towards you in the performance of a contract or required by law.

In cases where we do share your personal data with a third party we have put in place special data protection agreements to ensure that your personal data is processed in a safe manner in regards to your rights for privacy.

Your rights
Under the EU General Data Protection Regulation, you have the following rights towards us in regards to personal data for which we act as the Controller:

• Right to information (Art. 15 EU GDPR)
• Right to correction or deletion (Articles 16 and 17 EU GDPR)
• Right to restriction of processing (Art. 18 EU GDPR)
• Right to data portability (Art. 20 EU GDPR)
• Right to object to the processing (Art. 21 EU GDPR)
• Right to file a complaint to processing of personal data with relevant supervisory authority (Art. 51 EU GDPR)

Please note that Mentor Media Ltd often act as a Processor for our customers. Any assertion of your rights in regards to personal data where we are not the Controller will need to be addressed to the Controller.

Contact information
You may assert your rights and raise your concerns or complaints about the handling of your personal data by filling in the form provided and sending it by email to dataprotection@elanders.com and PRIVACY@mentormedia.com or by postal mail to the following addresses:

  Elanders_GDPR_Complaint handling form

Under the Singapore’s Personal Data Protection Act, you have the following rights towards us in regard to your personal data for which we act as the Controller:

• Right to withdraw consent (Section 16 PDPA)
• Right to restriction of processing (Section 18 PDPA)
• Right to information (Section 21 PDPA)
• Right to correction (Section 22 PDPA)
• Right to data portability (Section 26 PDPA)

Contact Information – Mentor Media Ltd
You may assert your rights and raise your concerns or complaints about the handling of your personal data by filling in the form provided and sending it by email to PRIVACY@mentormedia.com or by postal mail to the following address:

Mentor Media Ltd
47 Jalan Buroh, #08-02
Singapore 619491

 Mentor Media Data Privacy Complaint Handling Form

Special note on rights to information and data portability
If you would like to assert your right to information and data portability we require the request to be submitted in writing, be signed by you and sent to the above-mentioned postal address.

We appreciate if you also specify what categories of information you want to receive information about (e.g. customer information, employment records, etc.). If we for some reason cannot supply you with the information you’ve requested we will respond with our motivation for not being able to comply.

Please note that we only can release information that we can ascertain belongs to you and that this information always is sent by recommended mail to your registered address. You will be required to identify yourself to collect the letter.

Mentor Media Data Protection Officer (DPO) Information
Mentor Media Data Protection Officer (DPO): Chou Chi-Hung
DPO Office Number: 6631 3339
DPO Business Email Address: PRIVACY@mentormedia.com