CODE OF ETHICS POLICY STATEMENT
Dar Al khaleej Engineering Consultancy (DKEC) maintains certain policies to guide its employees with respect to standards of conduct expected in areas where improper activities could damage the firms’ reputation and otherwise result in serious adverse consequences to the firm and to employees involved. The purpose of this policy is to affirm, in a comprehensive statement, required standards of conduct and practices with respect to certain types of payments and political contributions.
An employee’s actions under this policy are significant indications of the individual’s judgment and competence. Accordingly, those actions constitute an important element in the evaluation of the employee for position assignments and promotion. Correspondingly, insensitivity to or disregard of the principles of this policy will be grounds for appropriate management disciplinary action.
Employees
We are committed to honesty, fairness, and providing a safe and healthy working environment that respects the dignity due everyone.
Customers
We are committed to providing complete confidentiality, attention to detail, reliable product delivery, and uncompromising service at a fair price.
Suppliers and partners
We are committed to fair competition and the sense of responsibility required of a good customer and teammate.
Obeying the Law
We will conduct our business in accordance with all applicable laws and regulations. Compliance with the law does not comprise our entire ethical responsibility; rather, it defines our minimum, absolutely essential performance of our duties.
Promoting a Positive Workplace
All employees want and deserve a workplace in which they feel respected, satisfied and appreciated. The firm will not tolerate harassment or discrimination of any kind ‐ especially involving race, color, religion, gender, age, national origin, sexual orientation or disability.
Our goal is excellence in the workplace and an environment that supports honesty, integrity, respect, trust and responsibility. In addition, citizenship is everyone’s responsibility. While everyone who works for the firm must contribute to the creation and maintenance of this environment, our executives and management personnel are charged with special responsibilities for fostering a work environment that is free from the fear of retribution.
Managers and team leaders must be careful in words and conduct to avoid placing, or seeming to place, pressure on subordinates that could cause them to deviate from acceptable ethical behavior.
Keeping Accurate and Complete Records
We must maintain accurate and complete firm records. Transactions between the firm and outside individuals and organizations must be promptly and accurately entered in our books in accordance with generally accepted accounting practices and principles. No one should rationalize or even consider misrepresenting facts or falsifying records. It will not be tolerated and will result in disciplinary action, including the possibility of immediate termination of employment.
Recording Costs Properly
Employees and their supervisors are responsible for ensuring that labor costs are accurately recorded. No one should time‐in or ‐out for another employee, and managers should ensure that all normal work, work related to independent research and development, and general activities are charged appropriately.
Bidding, Negotiating and Performing Contracts
We will compete fairly and ethically for all business opportunities. If an employee is involved in the preparation of proposals or contract negotiations, he or she must be certain that all statements, communications and representations to prospective customers are accurate and truthful. Once executed, all contracts must be performed in compliance with specifications, requirements, and clauses. It is the employee’s responsibility to ensure that all business opportunities are transacted honestly and in the best interest of the firm and our partners.
Prohibition of Improper Payments
The firm expects all employees to use only legitimate practices in commercial operations and in promoting the firm position on issues before governmental authorities. As stated below, “kickbacks” or “bribes” intended to induce or reward favorable buying decisions and governmental actions are unacceptable and prohibited.
No employee of the firm or any controlled affiliate acting on the firms’ behalf shall, in violation of any applicable law, offer or make directly or indirectly through any other person or firm, any payment of anything of value (in the form of compensation, gift, contribution or otherwise) to:
In utilizing consultants, engineers, architects, draftsmen, foremen, marketing and administrative personnel, sales representatives or others, the firm will employ only reputable, qualified individuals or firms under compensation arrangements which are reasonable in relation to the services performed. All employees must agree to comply with all laws, regulations and firm policies governing employee conduct.
Reports and Periodic Reviews
Any employee who is requested to make, authorize, or agree to any offer or payment which is, or may be, contrary to this policy will promptly report such information to the employee’s manager, to assigned firm legal counsel or to the manager in the component having responsibility for financial activity.
Any employee who acquires information (for example, newspaper reports, reports from customers, or statements of individuals involved) that gives the employee reason to believe that any employee is engaged in conduct forbidden by this policy, or that any sales representative, distributor or other person or firm representing the firm in any transaction is engaged in the type of conduct (whether or not in connection with a transaction involving the firm or its products) which, if engaged in by an employee of the firm, would violate this policy, will promptly report such information to the employee’s manager, to assigned firm legal counsel, or to the manager in the component having responsibility for financial activity.
Any manager receiving a report as cited above will promptly consult with assigned firm legal counsel and thereafter will, after appropriate investigation, take timely remedial or other action as warranted under the provisions of this policy. Such manager will also promptly report the matter to higher management.
Discussions and Exchange of Information with Competitors
Communication with a competitor on subjects as to which an understanding with the competitor would be illegal is, in antitrust litigation, likely to serve as important evidence of the existence of an understanding, particularly if the communication is accompanied or followed by similarity of action. The prohibitions set forth below are thus intended to avoid antitrust prosecutions which, though based on merely circumstantial evidence, may nevertheless be difficult to defend successfully. Accordingly, no employee shall discuss with a competitor or any third party acting for a competitor, or otherwise furnish to or accept from a competitor or any third party acting for a competitor, information on any subject as to which an understanding with the competitor is prohibited.
Conduct with Vendors and Subcontractors
Relationships with vendors, subcontractors and suppliers are handled in a fair and reasonable manner, consistent with all applicable laws and good business practices. Vendors, subcontractors and suppliers are selected on the basis of objective criteria, including standards of quality, service, price, delivery capability and technical excellence. Human Arc actively pursues competitive bidding through available resources including national group purchasing affiliations, regional and local alliances. All purchasing decisions are based on price and the supplier’s abilities to meet our needs. Under no circumstances are decisions based on personal relationships, whether the relationship involves the employee, an officer or director of DKEC, a family member or a friend. We employ the highest ethical standards in business practice sin source selection, negotiation, determination of contract awards and the administration of all purchasing activities. DKEC does not knowingly enter into contracts or do business with vendors convicted of a criminal offense related to health care or have been excluded from, or is otherwise ineligible to participate, in federal or state healthcare programs.
DKEC does business with only those vendors, subcontractors and suppliers that comply with applicable laws and whose business conduct is consistent with our Code of Ethics Policy and compliance program.
Business Courtesies to Our Employees
Meals, Refreshments, and Entertainment
Although an employee may not use his or her position at our firm to obtain business courtesies, it is permissible to accept unsolicited meals, refreshments, entertainment, and other business courtesies on an occasional basis, provided:
Receiving Gifts
Our employees are not permitted to accept compensation, honoraria, funds or monetary instruments in any form or amount, or any tangible gift (including tickets to sporting, recreational, or other events) from any entity, representatives of any entity, or any person that does or seeks to do business with the firm, unless approved by his or her supervisor and the firm’s Ethics Officer. Solicitation of gifts is prohibited. If you have any questions about the propriety of a gift, gratuities or item of value, contact your supervisor.
Gifts to Our Employees Who Procure Goods or Services
If you buy goods or services for our firm or are involved in the procurement process, you must treat all suppliers uniformly and fairly. In deciding among competing suppliers, you must objectively and impartially weigh all facts and avoid even the appearance of favoritism.
For this reason, gifts from suppliers or vendors must not be accepted, except advertising or promotional items of nominal value such as a pen, key chain, water bottle, visor cup or glass, or similar item displaying a firm’s logo. Established routines and procedures should be followed in the procurement of all goods and services.
Maintain the Integrity of all Employees
Business integrity is a key standard for the selection and retention of those who represent our firm. Paying bribes or kickbacks, engaging in industrial espionage, obtaining the proprietary data of a third party without authority, or gaining inside information or influence are just a few examples of what could give us an unfair competitive advantage and could result in violations of law.
Protect Confidential and Proprietary Information
Confidential client or alliance partner information, confidential information provided by reporters, and proprietary firm information may not be disclosed to anyone without proper authorization. It is absolutely imperative that proprietary and confidential documents be kept in a protected and secure manner. In the course of normal business activities suppliers, clients and competitors may sometimes divulge to your information that is proprietary to their business. Respect these confidences.
Obtain and Use Firm Assets Wisely
Proper use of firm property, electronic communication systems, information resources, material, facilities and equipment is your responsibility. Use and maintain these assets with the utmost care and respect, guarding against waste and abuse, and never borrow or remove them from firm property without management’s permission. Be cost‐conscious and alert to opportunities for improving performance while reducing costs. While these assets are intended to be used for the conduct of our business, it is recognized that occasional personal use by employees may occur without adversely affecting the interests of the firm. Personal use of firm assets must always be in accordance with corporate and firm policy. Consult your supervisor for appropriate guidance and permission.
All employees are responsible for complying with requirements of software copyright licenses related to software packages used in fulfilling job requirements.
Violations of the Policy
A. Violations of the policy are grounds for discharge or other disciplinary action, adapted to the circumstances of the particular violation and having as a primary objective furtherance of the firm’s interest in preventing violations and making clear that violations are neither tolerated nor condoned.
B. Disciplinary action will be taken, not only against individuals who authorize or participate directly in a violation of the Policy, but also against:
1. Any employee who may have deliberately failed to report a violation of the policy;
2. Any employee who may have deliberately withheld relevant and material information concerning a violation of this policy; and the violator’s managerial superiors, to the extent that the circumstances of the violation reflect inadequate leadership and lack of diligence.
C. Where an employee is accused of violating the antitrust laws, and the employee has relied in good faith on the advice of firm legal counsel after full disclosure of the material facts, no disciplinary action may be taken against the employee under this policy; the firm may, within the limits permitted by law, assist in the employee’s defense.
Reports and Periodic Reviews
A. Any employee who is requested to engage in any activity which is or may be contrary to this policy will promptly report such information to the manager to whom the individual reports.
B. Any employee who acquires information that gives the employee reason to believe that any other employee is engaged in conduct forbidden by the policy will promptly report such information to the manager to whom the employee reports.
Health, Safety, and Environment
Dar Alkhaleej Engineering Consultancy (DKEC) recognizes and accepts its responsibility to provide a safe and healthy working environment for all its clients, employees, and visitors who use its premises in order to prevent injury and ill health.
DKEC recognizes the need to focus on continual improvement of its OH&S management and performance. Our aim is to encourage a positive health and safety culture. To ensure this is achieved occupational health and safety is actively promoted throughout the organization through the provision of information, training, instruction and supervision. The General Manager takes overall responsibility for Health and Safety including the formulation, development and implementation of the Health and Safety policy within DKEC and requires the co-operation and support of all managers, employees, tenants, contractors and visitors in its implementation. The management will ensure that the Policy is reviewed periodically, at least every two years, to ensure that it remains relevant and appropriate to the organization.
This Policy will be communicated to all persons working under the control of the organization and will be made available to interested parties on request. DKEC operates a ‘low blame’ culture whereby employees are openly encouraged to report hazards, including near misses, without fear of reprisal to ensure the root causes of accidents are identified thus enabling measures to be put in place to eliminate recurrence.
Emphasis is placed on effective management ensuring a systematic approach to the identification of risks and the allocation of financial and physical resources to control them. In order to deliver these responsibilities DKEC undertakes to:
Maintain a safe and healthy place of work with safe access and egress;