Audit Committee Complaint Handling Procedure

• Policy
  • It is the Audit Committee´s policy to have a process in place for the receipt, retention and treatment of complaints received by the company or from confidential, anonymous submission by employees of the company regarding accounting, internal accounting controls, or auditing matters.

• Objective
  • The Policy´s objective is to provide a vehicle for handling complaints regarding the company´s accounting, auditing and internal controls practices so that those complaints will receive a fair hearing at the SJI Audit Committee level and to comply with applicable federal and state laws.

• Responsibilities
  • The Audit Committee shall have overall responsibility for the Complaint Handling Policy. The Office of the Corporate Secretary and Corporate Counsel shall provide administrative support as directed by the Audit Committee.

• Complaint Receipt
  • Any complaint regarding accounting, auditing or internal accounting controls received by the company or from an employee, whether submitted confidentially and anonymously or not, shall be forwarded directly to the Chairman of the Audit Committee in a sealed envelope by the Office of Corporate Secretary and Corporate Counsel. Complaints may be sent directly to the Chairman of the Audit Committee. In addition to internal reporting mechanisms, SJI has contracted with a third party for employees to make reports of concerns. To make a report, log on to the Ethics Hotline or call (800) 461-9330. The confidential and anonymous report will instantly be forwarded for review and proper handling.

• Treatment of Complaints
  • The Chairman of the SJI Audit Committee shall immediately begin an investigation regarding the complaint. The Chairman shall contact the Chief Executive Officer and request information and support necessary to fairly investigate the complaint. If the complaint is of such a nature that the Chairman believes that other resources are necessary to investigate the complaint, the Chairman shall in consultation with the entire Audit Committee and CEO or Corporate Counsel determine what, if any, other resources are needed.

• Retention of Complaints
  • The Audit Committee minutes will document the Committee´s actions regarding the complaint handling. The Chairman of the Audit Committee will provide to the Corporate Secretary the completed investigation file to be stored and retained for six years in the corporate files.

• Distribution of the Policy
  • The Policy shall be distributed to Board of Director members, Officers and employees of SJI and its subsidiaries.