REDACTED -IC Petrojam Investigation - Donations October 2019 final

Page 194 of 215 Petrojam Limited Integrity Commission October 2019 CONCLUSIONS 1. The Director of Investigation (DI) concludes that the grant of donations in excess of J$320,000.00 was irregular and unusual based upon the trend observed by the DI for donations made during the financial years 2016/2017 and 2017/2018. Based on the DI’s review, donations in excess of J$320,000.00 were made in fifteen (15) instances referenced at Table 4 of this Report. In point of fact, the subject fifteen (15) donations were between J$1,200,000.00 and J$10,024,531.00. The donations which were made by Petrojam Limited for the period 2017 to 2018, resulted in a 50.72% decrease in the number of donations issued by the refinery for the financial periods under review, however, for the same period, the company experienced a significant increase of 127.05% in the amount expended for donations. 2. The DI concludes that the imprudent management of the donations budget by Petrojam Limited resulted in the premature depletion of the 2017/2018 budget. 3. Mr. Floyd Grindley improperly inserted himself into the process by his unauthorized recommendation of the amount of $2,000,000.00 as a donation to the Munro College Old Boys Association. It is the Director of Investigation’s considered opinion that, Mr. Floyd Grindley in determining the amount of $2,000,000.00 to be donated to the Munro Old Boys Association, breached of Clause 4.1 (c) of Petrojam Limited’s Donations Policy which mandates that the Human Resource Development and Administration Manager shall determine the amount to be donated. Further consideration must be given to whether Mr. Grindley’s involvement in this particular donation gave rise to a conflict of interest, given his admission that Munro College is his alma mater.

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