Strategic Marine (S) Pte Ltd’s (herein referred to as “SMS”) provides a platform for individuals to disclose any improprieties that involve SMS’s employees and/or business partners, without fear of reprisal.


All cases will be reviewed and investigated by an Investigative Committee chaired by our majority shareholder. Results of any investigation will be shared at the discretion of the Investigative Committee.  Whistleblowers should report their concerns in good faith. The whistleblower’s identity and the concerns raised will be kept confidential, unless as required by law to reveal to authorized parties such as lawyers, the police or investigators.


Types of Improprieties


Improprieties include the following:


Corruption/bribery Corruption is receiving, asking for or giving any gratification as an inducement or reward for a person to do a favour with a corrupt intent.  There are many kinds of gratification or bribes, including money, sexual acts, properties, promises and services. In return, a person may ask for favours which can include unfair business advantages, confidential information and other special privileges.


Fraud refers to any illegal act characterized by deceit, concealment, or violation of trust. They are perpetrated to obtain money, property or services; to avoid payment or loss of services; or to secure personal or business advantage. Common examples of fraud include asset misappropriations, forgery and misuse of information acquired in the course of employment. 


Unlawful Conduct refers to all forms of illegal behaviour such as breach of applicable labour laws, drug sale or use, violence or threatened violence, criminal damage against property, sexual harassment, money laundering, and terrorism financing.


To report a concern, please email our Investigative Committee at Whistleblow@strategicmarine.com.


To enable us to effectively investigate your concerns, the following information should be provided:

  • Your contact information;
  • Name(s) of person(s)/company(ies) involved;
  • Your relationship with the reported person(s)/company(ies);
  • Detailed description of the incident/impropriety (including date, time, location, methods and action/behaviour);
  • Period of time the impropriety had been perpetuated;
  • Has the Company’s Management been informed? (if yes, please provide the notification date and contact information of the person notified);
  • Physical evidence and any other information that may substantiate the incident.


We encourage whistleblowers to provide their names and contact numbers to facilitate investigations.