Code of Conduct

Al-Tijaria’s Career Charter is the code of values for all Al-Tijaria’s employees. It includes ethical and behavioral rules that all company employees are expected to adopt in accordance with the teachings and ethical guidelines of Islamic Sharia, which govern the company’s objectives, principles, standards and policies.

• To provide a cohesive framework to the ethical concepts and values of the company.
• To provide a guide to the corporate ethics and behavior affirmed by the company.
• To ensure that all employees comply with ethical and behavioral standards consistent with the company's policies and vision.
• To provide an appropriate and effective work environment within the framework of good governance
• To encourage Al-Tijaria employees to be committed to his or her duties, while being aware of his/her rights.
• To build a collaborative foundation, develop a unified team spirit and nurture staff loyalty.
• To respect the workplace and apply therein the teachings of Islamic law in all transactions between employees and customers.

• The members of the Board of Directors, the Executive Management and the employees of the company commit to adhere to all laws and instructions, moreover they commit to work for the benefit of the company, its shareholders and other stakeholders, and not in the interest of any other.
• No-one can use his/her position to influence members, or executive management, for personal gain, or for the gain of others.
• Employees should work to use the company’s assets and resources in the best way possible, in order to achieve the objectives of the company. It is not permitted to exploit these assets for personal interest or gain.
• There will be provision for the employees of the company to report any  complaints about any improper or suspicious practices, while ensuring an independent and fair investigation of such complaints. Suitable and appropriate mechanisms will ensure employee confidentiality to ensure that any whistleblower is protected against any adverse reaction, or any damage arising from reporting such practices.
• Both employee and company are accorded reciprocal employment rights and duties. The employee is expected to undertake his/her duties positively and sincerely, demonstrating loyalty, in addition to awareness and understanding of their responsibilities. In return, their rights will be guaranteed by the company in accordance with internal regulations and the Labor Law.
• It is quite normal to have differing opinions among colleagues; this is accepted as long as it does not interfere with the work and efficient functioning of the workplace and does not directly, or indirectly impede or obstruct the achievement of the company’s goals.
• Equality between all staff is fundamental.
• Respect, constructive dialogue, exchange of ideas and debate are the supreme means of dealing with all employees, regardless of their career levels, and one of the cornerstones of the business environment in Al-Tijaria.

• The company follows a clearly defined policy to carry out its activities with integrity and honesty, in accordance with the highest legal and ethical standards, in compliance to Islamic Sharia guidelines and principles. It encourages employees to adhere to, and act according to Al-Tijaria’s policies, and to motivate them by all material and moral means in order to perform to the best of their ability.
• company policies are guidelines to assist employees perform all functions according to best practice, and lead them to the right judgment and act in a way that reflects positively on the image of the company and its position. Employees should abide by the context and the essence of this policy and not carry out any prohibited or illegal activities that, directly or indirectly, affect the values ??and principles of the company. These policies should be set out clearly and accurately so all employees may adhere to them.

All executive heads, department directors and such like shall cooperate to ensure that:

• Employees have a full understanding of all policy items and how to apply them.
• All appropriate steps have been taken to inform each employee under their supervision of these policies.
• All members of their departments and groups are committed to these policies. It is their duty to ensure that they are not compromised, and that staff are informed how to report any violations and the procedures to be followed therein.

Compliance and commitment to this policy is essential. Any irregularities will result in disciplinary action, as provided for in the approved sanctions regulation, including dismissal, if necessary. The company is bound by laws and regulations, the violation of which may result in penalties against the company and/or the Employee. Each employee is responsible for complying with these laws and regulations. Employees who travel must also comply with the laws and regulations of the countries in which they undertake the company's business activities, including the currency exchange rules of each country.

In the event that the employee is party to any violation of law(s) or regulation(s), whosoever is aware of the matter —his/her direct manager, executive chairman or his co-worker–shall take the necessary procedures to disclose such violation(s) and shall immediately report the matter in accordance with those procedures laid out by the company. Any employee under company investigation must cooperate fully. The concealment of any information pertaining to the misdeed may be seen as a direct violation of the company rules or the law and will entail disciplinary action that could, in some cases, result in termination.

“Judge yourself before being judged” is the mantra adopted by Al-Tijaria to promote an environment of self-accountability. The company demands complete transparency; it encourages employees to self-evaluate their own personal performance, judge their own actions and deeds before judging others’, and acknowledge, moreover penalize their own wrongdoings.

• No employee may engage in any activities that may cause a conflict between his interest and the interests of the company. Furthermore, he/she should  do his/her utmost to avoid exposing the company to any possibility of conflict of interest.
• No employee whose remit involves issuing purchase orders (POs) for equipment, transport services, employment contracts and other services of the company, should have any stake in any company supplying equipment or services.
• No employee’s family member may hold an interest or “significant shares” in any company supplying equipment or services to the company. Here, "significant shares" means any financial interest that may affect the employee's decision to engage in fair and unbiased business transactions on behalf of Al-Tijaria. A potential or actual conflict of interest occurs when the employee is in a position whereby his/her decision that may result in personal gain for him or herself, or another employee, family member, friends or acquaintances.

• The employment of relatives is not strictly prohibited in Al-Tijaria, but at the same time, Al-Tijaria tends to discourage relationships that bind the staff to their relatives and co-workers. It is in the interest of the company to appoint those who are qualified and experienced, regardless of any relationships, therefore the company takes all precautions and procedures necessary to ensure that such situations do not occur. Employees may not directly take decisions concerning the appointment, retention, promotion or remuneration of any other staff members associated with them through close personal relations, without the supervision and consent of a neutral person, or by the competent committee.
• The company defines the term "close personal relationships" as including first and second-degree relationships and any other relationships that may affect the employee's ability to make impartial decisions while performing the functions assigned to him.

• With the exception of social or work invitations that are consistent with business ethics, no employees of the company are permitted to accept gifts, commissions, loans or promises of future benefits. In addition, it is prohibited to accept offers of hospitality, or services offered by any person or entity, related to his employment with the company. This is to assure full accountability and to avoid any employee putting himself in a position of doubt.
• In case of presentation of any gift, immediately a written and detailed report should be provided by the employee using the relevant forms, and handed directly to his/her direct manager. In turn this shall be submitted with a recommendation to the Human Resources and Administrative Affairs for their appropriate decision. A copy of the report must be send to the Head of the Risk Management and Compliance Unit, who shall report the incident to the Chairman.

Employees working in the company must adhere to the confidentiality policy which ensures all documents and information reached by virtue of the employees’ work or duties are kept private and confidential. Only the company's concerned parties shall be informed of them, unless a final judgment or legal order is issued by a judicial authority requiring disclosure. The company should be notified and a written approval should be obtained prior to the disclosure, to any entity, of information or documents. This provision shall apply to the employee during his/her term of employment in the company; and after the termination of his services. Whether in electronic form, or in the form of photocopies, scans or photographs, the employee is forbidden to keep any documents for personal use, or for use outside the company building.

Al-Tijaria’s employment contracts clearly stipulate that employees are prohibited from accepting jobs at any other company with, or without pay. The violation of this prohibition will submit the offending employee to strict disciplinary procedures, which may include termination.

Al-Tijaria respects all employees irrespective of gender, race or religious beliefs, and continuously endeavors to employ its staff in accordance with the relevant laws and regulations in the State of Kuwait. Employment decisions are based on qualifications, experience, personal abilities and relevant standards such as public and social relations, in a manner that does not conflict with the laws and regulations of the State of Kuwait.

The principle of "cooperation and respect" applies to dealings between employees at all levels. It is deemed important to always act in a decent and professional manner, both inside and outside the company. Any wilful conduct is unacceptable; the company does not tolerate insults or humiliation; nor disputes based on gender, race or religious belief.

All Al-Tijaria personnel must abide by the rules and regulations governing health, safety and those that protect their working environment. They should abide by the safety policies set out by the company to maintain a safe working environment in its premises. All employees are, without exception, responsible for the immediate reporting of any accident, injury or unsafe working conditions. The company firmly believes that the safety, health and well-being of its employees is the top priority as part of its ethical commitment to them.

Al-Tijaria’s communications systems, including telephones, mobile phones, Internet systems and e-mails, are for the benefit of the company, and to be used for work purposes, assisting employees in the performance of their work. Therefore, they may not be used to review, receive or broadcast any material or information that violates any laws, regulations, customs or traditions recognized in the State of Kuwait.

This includes any programs or sites deemed "pornographic", "political", "harmful" or "dangerous"; or sites that conflict with Islamic teachings and principles. This applies, of course, to any communications system for any client or supplier overseen by an employee or, to which the employee has access. Pirated, unlicensed and non-genuine computer software is not allowed in the company.

It is understood that there may be a need for the limited use of communication devices or systems for personal purposes, but employees must be aware that all messages sent or received through their communications and information systems may be monitored, accessed and stored by the company. They should not expect any privacy with respect to such information and communications. It is also prohibited to use personal computers inside the company or for carrying out any deal.

All payments, commissions and deductions must be made in accordance with sound accounting standards, written approval, invoices and correspondence, approved by the issuing authorities based on the approval of the concerned department, by cheque or wire transfer, not in cash–except for petty cash payments, which must be fully disclosed in the accounting records maintained by the company and audited by the company's auditors. All original documents, references, contracts and agreements must be kept in a safe place in accordance with the company's policy.

It is strictly prohibited to use any funds or assets of the company for any purpose that is illegal or contrary to the company's policies. Employees shall not accept any bribes, hidden commissions or any other kind of financial or in-kind benefits in return for taking any action or acting in their capacity in the company.

Regular hospitality is permitted in the course of business activities when they are seen as acceptable due to their nature, frequency and cost, and within the approved budget. Hospitality may also be deemed acceptable in the context of work or work-related activities, such as when handling advertising, or when the courtesies are due as a reward to the company. The company assets or property of the company are not for personal use, or use by employee relatives, this includes property on loan to the employee.

The company encourages and enables employees to report their concerns to the persons concerned about any company violations and breaches of rules, this should be done without speaking or disclosing such problems or irregularities outside the company.

Employees are often the first to notice or detect errors or signs of deviation in company practice, therefore a clear reporting policy is essential otherwise employees do not initiate, express or disclose their concerns; they may not raise their doubts and worries, due to the fear of charges of disloyalty, or being accused of betrayal or distrust by their colleagues, managers or company.

The Board of Directors is committed to the highest possible standards of integrity, transparency, accountability and fairness. In line with this principle, channels and mechanisms have been identified to assist the employees and the parties we deal with to express any serious concerns regarding the occurrence of any irregularities.

This policy applies to the Board of Directors, the Executive Management and all consultants, contractors, suppliers, customers and any others, in accordance with the company's policy, and in accordance with the provisions of the Executive Regulations of Kuwait’s Capital Markets Authority (CMA).

• To encourage a sense of trust; raise the level of care and commitment of employees; to promote loyalty in the workplace and the company.
• To provide the appropriate routes and channels and the best ways to express and disclose concerns or doubts in order to protect the company’s business and the company itself.
• To ensure that appropriate support and direct follow-up is  received and verified whether or not the misdemeanor is substantiated.
• To ensure that the whistleblower is protected from any reprisals or reactions resulting from reporting on any irregularities.
• To take necessary action against any infringement or violation of rules or the law so as not to repeat them and use the incident as a lesson and to avoid any malpractice in the future.

• Criminal conduct or conduct unbecoming under company rules.
• Non-compliance with / adherence to policies, procedures and rules.
• Cases of obstructing the implementation of company policies.
• Health and safety risks, including risks to employees or others.
• Damage to the working environment.
• Unauthorized use of company funds and assets.
• Fraud, racketeering and corruption.
• Physical, psychological, sexual or immoral behavior of any kind
• Non-professional and inappropriate actions, or actions that conflict with common sense, customs and traditions.

The Board of Directors understand that the decision to report any decision irregularities is difficult, so the Board has undertaken to encourage employees to make any doubts about any violation or violations of company policies or laws.

The Board of Directors will not allow any offense or assault to be made to the whistleblower, and that appropriate actions shall be taken for his/her protection.

All reporting will be confidentially handled, exerting all efforts to ensure that the identity of the whistleblower is not disclosed, unless he/she is required as a witness. All Employees must comply with the following:

• Disclosing of information in good faith.
• Acting justly and fairly and not to make any false claims.
• Ensuring all reporting is free from any personal gain or benefit.
• Maintaining information confidentiality without reporting to non-interested persons.

• Concerns are reported to the director, the direct manager or the Chairman.
• In the event that the director, or the person concerned, confirms the seriousness of the complaint, the relevant form shall be filled out and addressed to the Risk Management and Compliance Unit for verification.
• The Risk Management and Compliance Unit collects all necessary information to verify the importance and validity of the complaint and report on the latest developments.
• All complaints shall be submitted from the Risk Management and Compliance Unit directly to the Chairman and in turn to the competent committee by a written report handled in a confidential manner.
• In the case of confirmation of the complaint’s validity, a decision shall be taken by the Chairman or the committee.
• Procedures shall be taken by the executive management in accordance with the recommendations issued by the Chairman and / or the committee in accordance with the approved sanctions regulations and the applicable laws.