1. Purpose

The purpose of this Epidemic Response Policy is to establish a framework for J-Newton Enterprise Holding Limited to effectively respond to epidemic threats to ensure the health and safety of employees, stakeholders, and the community.

2. Scope

This policy applies to all employees, contractors, and visitors of J-Newton Enterprise Holding Limited across all locations.

3. Definitions

• Epidemic: An outbreak of a disease that occurs in a community or region in excess of normal expectations.
• Pandemic: An epidemic that has spread over multiple countries or continents, affecting a large number of people.

4. Responsibilities

• Management: Responsible for the overall implementation of the policy and ensuring compliance with health regulations.
• HR Department: Responsible for communication and training related to epidemic response.
• Employees: Responsible for adhering to the policy and reporting any symptoms or exposure.

5. Prevention Measures

• Health Assessments: Conduct regular health assessments and screenings as necessary.
• Hygiene Protocols: Promote hygiene practices such as hand washing, use of sanitizers, and respiratory etiquette.
• Vaccination: Encourage vaccination against prevalent diseases as per public health guidelines.

6. Epidemic Preparedness

• Emergency Response Plan: Develop and maintain an epidemic response plan that outlines procedures for various scenarios.
• Communication Plan: Establish a communication plan to disseminate information to employees, stakeholders, and the public.
• Training: Provide training for employees on the epidemic response plan and safety measures.

7. Response Procedures

• Identification of Threat: Monitor public health announcements and identify potential epidemic threats.
• Activation of Response Plan: Upon identification of an epidemic threat, activate the response plan, including:
  • Implementing remote work or flexible work arrangements where feasible.
  • Increasing sanitation and cleaning protocols in the workplace.
  • Restricting or suspending travel to affected areas.

8. Communication

• Internal Communication: Maintain regular communication with employees regarding updates on the epidemic and response measures.
• External Communication: Coordinate with public health authorities and communicate relevant information to stakeholders and the public.

9. Health and Safety Measures

• Isolation and Quarantine: Establish protocols for isolating infected individuals and quarantining exposed employees.
• Support Services: Provide access to medical and counseling services for affected employees.

10. Monitoring and Review

• Policy Review: Review and update the policy regularly or as needed based on emerging health guidelines and lessons learned from previous responses.
• Feedback Mechanism: Implement a feedback mechanism for employees to provide input on the effectiveness of the policy and response measures.

11. Compliance

Failure to comply with this policy may result in disciplinary action, up to and including termination of employment.

12. References

• World Health Organization (WHO) Guidelines
• National Center for Disease Control (NCDC) Guidelines
• Local Health Authority Regulations

1. Purpose

The purpose of this Corporate Social Responsibility (CSR) Policy is to outline J-Newton Enterprise Holding Limited’s commitment to operating in an economically, socially, and environmentally sustainable manner. This policy demonstrates our dedication to contributing positively to society and the environment while ensuring the well-being of our stakeholders.

2. Scope

This policy applies to all employees, management, contractors, and stakeholders of J-Newton Enterprise Holding Limited across all operational locations.

3. Definitions

• Corporate Social Responsibility (CSR): The practice of integrating social and environmental concerns in business operations and interactions with stakeholders.

4. Objectives

• To enhance the quality of life in the communities where we operate.
• To promote sustainable environmental practices.
• To foster ethical behavior and transparency in our operations.
• To engage with stakeholders to understand their needs and expectations.

5. Core Principles

• Ethical Conduct: We commit to conducting business in an ethical manner, ensuring transparency and accountability in all our dealings.
• Community Engagement: We will actively engage with local communities to understand their needs and contribute to their development.
• Environmental Stewardship: We will implement practices that promote environmental sustainability and reduce our ecological footprint.
• Employee Well-being: We will prioritize the health, safety, and development of our employees.

6. CSR Initiatives

• Community Development: Support local community projects, including education, health, and infrastructure development.
• Environmental Programs: Implement initiatives to reduce waste, conserve energy, and promote renewable resources.
• Employee Volunteerism: Encourage employees to participate in community service and volunteer opportunities.
• Sponsorship and Donations: Provide financial support or in-kind donations for community initiatives and charitable organizations.

7. Stakeholder Engagement

• Identifying Stakeholders: Recognize key stakeholders, including employees, customers, suppliers, local communities, and investors.
• Feedback Mechanisms: Establish channels for stakeholders to provide feedback on our CSR initiatives and overall impact.
• Regular Reporting: Communicate our CSR activities and impact through regular reporting to stakeholders.

8. Monitoring and Evaluation

• Performance Metrics: Develop metrics to assess the effectiveness of CSR initiatives and their impact on the community and environment.
• Regular Review: Conduct regular reviews of CSR activities and make necessary adjustments to improve performance.
• Reporting: Publish an annual CSR report outlining our initiatives, progress, and future goals.

9. Compliance

All employees and stakeholders are expected to adhere to this CSR policy. Non-compliance may result in disciplinary action, up to and including termination of employment or contract.

10. Training and Awareness

• Employee Training: Provide training on CSR principles and practices to all employees.
• Awareness Campaigns: Conduct awareness campaigns to promote CSR values and encourage participation in initiatives.

11. References

• United Nations Sustainable Development Goals (SDGs)
• Global Reporting Initiative (GRI) Standards
• Local and International CSR Guidelines

1. Introduction

• Purpose: This AML Policy outlines the commitment of J-Newton Enterprise Holdings Limited to prevent money laundering and terrorist financing within the energy sector in Nigeria.
• Importance: Effective AML measures protect the integrity of our business, clients, and the financial system.
• Scope: This policy applies to all employees, contractors, and third parties associated with J-Newton Enterprise Holdings Limited.

2. Legal Framework

• Regulatory Compliance: J-Newton Enterprise Holdings Limited will comply with all relevant Nigerian laws and regulations, including but not limited to the Money Laundering (Prohibition) Act, Economic and Financial Crimes Commission (EFCC) guidelines, and international standards set by the Financial Action Task Force (FATF).
• Definitions: Key terms such as “money laundering,” “terrorist financing,” “customer due diligence,” and “suspicious transaction” are defined in accordance with regulatory standards.

3. Risk Assessment

• Risk Identification: A comprehensive risk assessment will be conducted to identify potential money laundering risks specific to the energy sector, including high-risk regions and customer categories.
• Risk Evaluation: The company will evaluate risks associated with customers, transactions, and geographic areas, updating the assessment annually or as needed.

4. Customer Due Diligence (CDD)

• Identification and Verification: J-Newton Enterprise Holdings Limited will implement a robust CDD process to verify the identities of clients and understand the nature of their business.
• Enhanced Due Diligence: Additional scrutiny will be applied to high-risk clients, including government officials, politically exposed persons (PEPs), and clients from high-risk jurisdictions.
• Ongoing Monitoring: Continuous monitoring of customer transactions will be conducted to identify unusual or suspicious activity.

5. Record Keeping

• Documentation Requirements: All customer identification records, due diligence documents, and transaction records will be maintained for a minimum of five years.
• Accessibility: Records will be readily available for review by regulatory authorities as required.

6. Reporting Obligations

• Suspicious Transactions: Employees must report any suspicious activities or transactions to the appointed Money Laundering Reporting Officer (MLRO) immediately.
• MLRO Responsibilities: The MLRO will be responsible for assessing reports, determining the necessity of filing a Suspicious Activity Report (SAR) with the EFCC, and ensuring compliance with reporting timelines.

7. Training and Awareness

• Employee Training: All employees will receive AML training upon hiring and regular refresher courses thereafter to ensure awareness of AML policies and procedures.
• Updates: Training materials will be updated to reflect changes in regulations and emerging risks.

8. Compliance Monitoring

• Internal Audits: Regular audits and compliance checks will be conducted to assess adherence to the AML policy and identify areas for improvement.
• Reporting Non-Compliance: Any instances of non-compliance will be documented, and corrective actions will be taken promptly.

9. Confidentiality

• Protection of Information: All information related to customer identification and suspicious activity reports will be treated as confidential and shared only with authorized personnel or regulatory bodies as required by law.

10. Policy Review and Updates

• Regular Review: This AML policy will be reviewed annually and updated as necessary to ensure effectiveness and compliance with changing regulations and industry standards.
• Stakeholder Involvement: Input from relevant stakeholders will be considered during the review process.

11. Enforcement

• Consequences of Violations: Any employee found to be in violation of this AML policy may face disciplinary action, up to and including termination, in accordance with company policies.

Conclusion J-Newton Enterprise Holdings Limited is committed to maintaining the highest standards of integrity and compliance with AML regulations. All employees are expected to understand and adhere to this policy to help prevent money laundering and terrorist financing activities.

1. Introduction

• Purpose: This Diversity and Inclusion Policy reinforces J-Newton Enterprise Holdings Limited’s commitment to creating an inclusive workplace where all employees feel valued and respected.
• Scope: This policy applies to all employees, contractors, and third parties associated with J-Newton Enterprise Holdings Limited.

2. Commitment to Diversity and Inclusion

• Core Values: We believe that diversity and inclusion are essential to our success. Diversity includes, but is not limited to, race, ethnicity, gender, age, religion, disability, sexual orientation, and socio-economic background.
• Inclusive Culture: We are committed to fostering an inclusive culture where differences are celebrated, and everyone has the opportunity to contribute and thrive.

3. Equal Opportunity Employment

• Non-Discrimination: J-Newton Enterprise Holdings Limited is an equal opportunity employer. We do not tolerate discrimination or harassment of any kind. Employment decisions are based on merit and business needs, without regard to race, color, religion, gender, sexual orientation, national origin, age, disability, or any other characteristic protected by law.
• Fair Recruitment: Our recruitment processes are designed to attract a diverse pool of candidates and ensure fair and unbiased hiring practices.

4. Workplace Inclusion

• Inclusive Practices: We strive to create an environment where all employees feel included and valued. This includes providing reasonable accommodations for employees with disabilities and ensuring that our facilities are accessible.
• Employee Resource Groups (ERGs): We support the formation of ERGs to provide a platform for employees to connect, share experiences, and promote diversity and inclusion initiatives.

5. Training and Development

• Diversity Training: All employees will receive training on diversity and inclusion, including topics such as unconscious bias, cultural competency, and inclusive leadership.
• Professional Development: We are committed to the ongoing development of our employees. We provide opportunities for learning and career advancement to ensure that all employees can reach their full potential.

6. Accountability and Reporting

• Measuring Progress: We will regularly monitor and report on our diversity and inclusion efforts to ensure we are making progress towards our goals.
• Reporting Concerns: Employees are encouraged to report any concerns related to discrimination, harassment, or other violations of this policy. Reports can be made to HR or through our confidential reporting channels without fear of retaliation.
• Response to Issues: All reports of discrimination or harassment will be investigated promptly and thoroughly. Appropriate corrective action will be taken, if necessary.

7. Community Engagement

• External Partnerships: We actively seek partnerships with diverse suppliers and community organizations to support our diversity and inclusion goals.
• Corporate Social Responsibility: We are committed to positively impacting the communities where we operate through inclusive and equitable business practices.

8. Policy Review and Updates

• Regular Review: This Diversity and Inclusion Policy will be reviewed annually and updated as necessary to ensure its effectiveness and alignment with best practices and legal requirements.
• Employee Involvement: Feedback from employees will be considered during the review process to ensure the policy remains relevant and effective.

Conclusion J-Newton Enterprise Holdings Limited is dedicated to fostering a diverse and inclusive workplace where every employee feels respected and valued. By embracing diversity and inclusion, we can drive innovation, improve performance, and create a more dynamic and successful organization.

1. Introduction

• Purpose: This Data Protection and Privacy Policy outlines J-Newton Enterprise Holdings Limited’s commitment to protecting the personal data of its employees, clients, partners, and other stakeholders.
• Scope: This policy applies to all data processing activities conducted by J-Newton Enterprise Holdings Limited, including the collection, storage, use, and sharing of personal data.

2. Legal Framework

• Regulatory Compliance: We comply with the Nigeria Data Protection Regulation (NDPR) and other applicable data protection laws and regulations.
• Definitions: Key terms such as “personal data,” “data subject,” “data processing,” “consent,” and “data controller” are defined in accordance with the NDPR.

3. Data Collection and Use

• Data Minimization: We collect only the personal data that is necessary for specific, legitimate purposes related to our business operations.
• Lawful Basis: Personal data is processed only on lawful bases as defined by the NDPR, such as consent, contract performance, legal obligation, legitimate interest, and public interest.
• Purpose Limitation: Data collected will be used solely for the purposes for which it was collected, unless further processing is compatible with those original purposes.

4. Data Subject Rights

• Access: Data subjects have the right to request access to their personal data held by J-Newton Enterprise Holdings Limited.
• Rectification: Data subjects can request correction of inaccurate or incomplete personal data.
• Erasure: Data subjects have the right to request the deletion of their personal data, subject to certain conditions.
• Restriction of Processing: Data subjects can request the restriction of processing of their personal data under certain circumstances.
• Data Portability: Data subjects have the right to receive their personal data in a structured, commonly used, and machine-readable format.
• Objection: Data subjects can object to the processing of their personal data based on legitimate interests or direct marketing.

5. Data Security

• Security Measures: We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.
• Data Breach Response: In the event of a data breach, we will take immediate steps to mitigate the impact, notify affected data subjects and regulatory authorities as required by law, and take measures to prevent future breaches.

6. Data Sharing and Transfers

• Third-Party Processors: Personal data may be shared with third-party service providers who process data on our behalf. We ensure that these third parties comply with our data protection standards and legal requirements.
• International Transfers: If personal data is transferred outside Nigeria, we ensure that appropriate safeguards are in place to protect the data in accordance with applicable laws.

7. Data Retention

• Retention Period: Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.
• Data Disposal: When personal data is no longer needed, it will be securely deleted or anonymized to prevent unauthorized access.

8. Employee Responsibilities

• Training: All employees receive training on data protection and privacy principles to ensure compliance with this policy.
• Confidentiality: Employees are required to maintain the confidentiality of personal data and report any suspected breaches or violations of this policy.

9. Policy Review and Updates

• Regular Review: This Data Protection and Privacy Policy will be reviewed annually and updated as necessary to reflect changes in legal requirements and best practices.
• Stakeholder Involvement: Feedback from employees, clients, and other stakeholders will be considered during the review process.

10. Contact Information

• Data Protection Officer (DPO): For any questions, concerns, or requests related to personal data, please contact our Data Protection Officer at DPO@jnewtonholdings.com.
• Reporting Concerns: Data subjects can report any concerns or complaints related to data protection and privacy to our DPO or through our confidential reporting channels.

Conclusion J-Newton Enterprise Holdings Limited is committed to protecting the personal data and privacy of all individuals associated with our company. By adhering to this policy, we aim to ensure compliance with applicable laws and foster trust and transparency with our stakeholders.