5th January 2012

To Our Stakeholders:

I am pleased to confirm that John While Group (S) Pte Ltd reaffirms its suppport of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our Stakeholders using our primary channels of communications.

Sincerely yours,

Elizabeth Rhonda Willson
Executive Chair

John While Group operates in Singapore, Shanghai China and Chonburi Thailand. The legal requirements ensuring the health and safety of staff members are high in each of these cities.

In dealing with the specifics of the questions raised in the Self Assessment there are a few areas where we have answered NO. This is particularly related to the number of days of paid holiday leave, impact on the local communities and interactions with suppliers.

With regard to paid holiday leave all the companies pay per the local employment laws. As such we will not be amending our policies to reflect those of the UNGC.

With regard to the Community Impacts the company rents all its premises from Government or Quasi-government owners. It is out of our resources to follow up how previous land owners - if any - were dealt with when their land was purchased to establish the manufacturing complexes.

We have no progress to report as all companies comply with the legal requirements in each country with regard to employment matters. Wages, leave and working hours are set at law in the countries in which we operate and we pay and grant benefits above the legal requirements.

As we are very small - a total of 133 staff in 3 countries - we will not be following up with our multi-national suppliers in Japan, Germany and Korea with regard to their human rights standards.

Our Employee Handbook includes sections on Employee rights and responsibilities, their compensation and benefits.

Our handbook also states staff's freedom of association, collective bargaining and anti-discrimination.

We have amended the wording to more clearly state our policy on freedom of association and collective bargaining with effect from October 2011.

This was done after a multi-national customer highlighted their policy to us during their audit and so we modified our policy to more closely mirror theirs.

No difference has been noted with this change.

In essence the intent of our policy is the same as theirs but our customer preferred the more global 'legalese', and left happier after their audit.

All companies are ISO 14000 certified.

We adhere to the 3 'R's - Reduce, Re-use, Recycle.

Given the small size of the companies we do not have the resources to do an assessement of our enviromental footprint.
In general our raw material is spring steel wire. Downstream from us are the wire drawing mills, the steel mills and mining.

In line with the ISO requirements monthly staff meetings highlight efforts that can be made by individual staff as well as the company to reduce our impact.

Part of the 'Reduce' phase is reduction in scrap material which is "Re-cycled". We hope to have zero scrap but this is not possible as scrap is a function of proto-typing, factory efficiency, tolerances in specifications and material used. As there will always some scrap this is recycled.

Scrap material is monitored on a monthly basis.

John While Group (S) Pte Ltd and its subsiduaries in China and Thailand have had an Employee Handbook since 1st September 2001. Section 9.3 specifically mentions Business Ethics and our expectattion that staff will conduct themselves in a fair and honest manner.

Staff are given a copy of the Handbook on joining the company and sections of the handbook are scheduled for awareness raising at our monthly briefings.

Two separate incidents have occurred in the past year.
a. An ex-staff member was prepared to continue to work on a part-time basis but wanted to be able to set their own prices for products sold on our behalf. We did not agree to this as it could allow abuse of the end customer. We were prepared to pay the person concerned our normal representation commission at the prices set by the company to the customer.

b. A now ex-staff member was conducting his own business using company property [company time, resources and customer base] to receive personal commissions on products sold to third parties.

In both instances we have not received any more orders from the end customer. It appears they are willing to pay inflated prices to a middle man rather than dealing directly with us.

In the second case the staff member was fired.

Comment : It appears there is an actual cost to the business when dealing in an ethical manner ie. no further business; no orders. The end customers and intermediaries were happy to pay inflated prices as long as they could do their 'deals' rather than deal directly with the company at a lower price.