CODE OF ETHICS
PURPOSE AND OBJECTIVERESPONSIBILITIESDEFINITIONSPOLICY
APPENDICES / ATTACHMENTS / FORMS
INTRODUCTION AND PHILOSOPHY
The purpose of this policy is to ensure that all Q-Chem employees, contractors and business associates abide by applicable laws and conduct Company business according to the highest ethical standard; and to provide direction for business conduct, which sustains and promotes a culture of ethical integrity and cultivates strong teamwork and productivity. Attention to ethics in the workplace enhances the Company's reputation for honesty, integrity and reliability as well as assists in the management of values associated with quality management and strategic planning.
Q-Chem is committed to the highest level of ethical conduct in our dealings with people, organizations and governments wherever we conduct business. Our reputation is fundamental to our business and the core values from which our industry prevails. Q-Chem cares about how it conducts business; therefore it will not compromise its ethics and integrity for any reason, including the achievement of business results.
This policy and its related procedures pertain to the implementation and control of Code of Ethics, Our Company Values and Responsibilities. This policy and related procedures apply to and are to be understood and adhered to by all Q-Chem Direct Hire employees, general contractors and secondees. This policy and its procedures, including related procedural updates and documentation shall be developed, trained, communicated and administered by the Human Resources Department with advice from Q-Chem's Auditor and Legal Manager. This policy and its procedures will replace and supersede all previous policies and procedures on Code of Ethics. Top
PURPOSE AND OBJECTIVE
Q-Chem Human Resources will:
- Establish clear vision and picture of integrity with respect to ethical conduct throughout the organization.
- Minimize the possibility of unethical conduct by providing objectives and documented fair resolution of situations that are aligned with the vision of integrity.
- Reinforce ethical behavior to employees which is embodied by management.
- Require mandatory annual Computer Based Training and test on the Code of Ethics Policy of all employees.
- Ensure the Materials Department revises all standard contracts to include ethics reporting procedures. Top
Employees and management are expected to comply with all aspects of the Code of Ethics policy and recognize that managing ethics is a process. Senior Management has the responsibility to ensure that the policy is understood, enforced and implemented by all Q-Chem employees and general contractors. Managers and Supervisors have a responsibility to set an example of the highest standard of ethical conduct and to monitor compliance with the Policies of all employees who report to them. Managers and Supervisors are responsible to direct any questions or concerns submitted by any employee directly to Senior Management or Human Resources for action or investigation.
Employees are responsible to:
- Seek guidance of their manager, supervisor or any member of Senior Management when any issue arises in respect to this policy.
- Report any violation of this policy, illegal act or unethical behavior immediately to their Supervisor, Manager or Senior Management using the Code of Ethics. Non-Compliance Form procedure as outlined in this policy.
- Familiarize themselves with the policy.
- Exhibit loyalty in all matters pertaining to the affairs of Q-Chem and shall not knowingly be a part of any illegal, unethical or improper activity.
- Take reasonable care when making business decisions and recommendations and shall reveal all facts to approving authorities of Q-Chem.
- Complete a Code of Ethics mandatory Computer Based course annually.
Senior Management shall be responsible to ensure that the ethics policy is reviewed annually Human Resources shall identify and monitor ethical issues prior to occurrence of an incident.
The Training Department is responsible to provide the General Manager with an annual report identifying the status of the completed mandatory Computer Based course. Top
- Company - shall refer to Qatar Chemical Company
- Family - all persons employed and sponsored by the Company on indefinite contracts, definite contracts, secondment, consultancy assignments, acting as a worker or official of the Company including spouses, children, parents, parents-in-law, brothers or sisters.
- Material Interest - refers to a financial interest of any kind, which in view of all the circumstances, is substantial enough that it would affect a person's judgment or decision making with respect to Q-Chem business dealings with Entities. An ownership or interest is substantial if an ordinary prudent person in a like position would reasonably conclude that such an interest would affect judgment with respect to Q-Chem business dealings.
- A direct or indirect material or financial interest through ownership of the shares or equity, and/or other interest held by an employee or his/her Family in an Entity doing business with the Company.
- A position held by the employee acting in a capacity as sponsor, director, officer, partner, consultant, employee, distributor, agent, trustee or the like for suppliers, contractors, subcontractors, customers or other Entities doing business with the Company.
- Intellectual Property - all of the propriety, intangible assets of the company such as patents, inventions, trademarks, copyrights, trade secrets or propriety information.
- Conflict of Interest - Any situation that can cast doubt upon commitment to the best interests of the Company, including but not limited to the following:
- The existence of an Interest for an Employee in an Entity, having a business relationship with the Company, irrespective of the department wherein the employee may be working.
- The existence of an Interest for an Employee in any commercial activity of the Company.
- Where an Employee's position or authority may be used to influence or make decisions in respect of Q-Chem transactions or activities that may lead to any form of financial or personal gain for that Employee or for his or her Family.
- Situations in which financial or other personal considerations may compromise impartiality and/or judgment in the performance of duties for the Q-Chem.
- Privacy of Information - The process of how information about individuals is collected, maintained and disclosed.
- Senior Management - For purposes of this policy, Senior Management includes the GM, DGM or any of their direct reports. Top
Q-Chem's strength is based on more than financial performance. Our values stem from honesty, trust, responsibility and integrity. Employees shall strive to obey the law and company policies at all times and make this code our personal standard for excellence and ensure that a high standard of quality is always maintained.
Q-Chem is subject to laws not only in Qatar but in the country in which we do business and our employees are our best ambassadors. Changes in laws and our industry constantly present new ethical and legal issues. With this in mind, no set of guidelines should be considered the absolute last word.
The success of our business depends upon the quality of relationships between Q-Chem, employees, customers, suppliers and the general public. There will be no exception to this.
Employees should avoid situations where the end result is the accomplishment of something that the Company could not legally or ethically do directly.
This policy is not just about compliance with the law and general standards of ethics. By establishing this policy, employees acknowledge that our choices and actions help define Q-Chem for others. Our Code of Ethics is a tangible example of our values and an expression of each Q-Chem employee's personal responsibility to uphold those values and ethics.
Employees who do not comply with the Ethics Policy may be in violation of their employment contract and will be subject to appropriate action disciplinary action as described in the company Discipline Policy. Violation of the Ethics Policy shall be considered an act of Gross Misconduct as defined in the Discipline Policy.
Such actions or behaviors include but shall not be limited to any of the following:
- Willful violation of any Q-Chem policy
- Deliberate action that is extreme in nature and is detrimental to Q-Chem's efforts to operate safely and profitably.
- Willful violation of security or safety rules or failure to observe safety rules or Q-Chem safety practices; failure to wear required safety equipment; tampering with Q-Chem equipment or safety equipment
- Negligence or any careless action which endangers the life or safety of another employee or Q-Chem property
- Insubordination or refusing to obey instructions properly issued by a direct, responsible supervisor.
- Falsification of Q-Chem records
- Threat of, or the act of doing bodily harm
- Willful or negligent destruction of property
- Revealing of or failing to maintain confidential information
Senior Management shall have the authority to investigate incidents that question any of the ethics as outlined in this policy should they occur.
Should Management find through their investigations that a violation of the Code of Ethics Policy has taken place, they shall immediately refer this incident to Human Resources for follow-up and appropriate action under the company Discipline Policy.
Our responsibility as employees falls under the following categories: Top
Governments and their laws, agencies and employees are linked to Q-Chem's business. Q-Chem's employees perform functions that may require government oversight or involvement. Therefore, maintaining productive relationship with governments in the areas where we operate is essential to business success.
Our customers and suppliers entrust Q-Chem with important information relating to their business. The nature of this relationship requires maintenance of confidentiality. In safeguarding the information received, Q-Chem earns the respect and further trust of our customers and suppliers.
Any violation of confidentiality seriously injures Q-Chem's reputation and effectiveness. With this in mind, employees shall not disclose confidential information gained in the course of their employment except as necessary to perform their duties and only then with individuals who have a direct association with the transaction on a 'Need to Know' basis.
Confidential information should neither be used for personal gain nor should it be used as a detriment to the welfare, interest or image of Q-Chem.
If a question exists or you are concerned about the appropriateness of releasing information to a vendor or customer, remember that you are not required to answer and we do not encourage you to do so. Instead search for the answer through your business unit's management. In looking for an answer, provide all the facts so the best course of action can be determined. Top
WORLDWIDE BUSINESS LAWS
Q-Chem is subject to laws, not only in Qatar but also around the world. It is the company's policy to comply with all applicable laws and regulations. Employees, including management must understand the laws affecting their business activities and take responsibility for compliance. Q-Chem's interests are not served by unethical practices, even though these practices may not violate the law.
Employees who may be called upon to deal with government officials either in Qatar or other countries around the world shall provide truthful information and treat officials with courtesy and respect. Without exception, all laws and regulations shall be strictly followed with regard to payments, gifts or entertainment, business courtesies and conflicts of interest. In all aspects, our relationship with public officials must reflect the highest integrity and concern for reputation.
The country of Qatar and other countries have enacted a variety of laws relating to competition, and international trade. These laws are designed to preserve fair competition in the marketplace and stimulate economic growth worldwide. Q-Chem supports these laws and is committed to comply with them. Among the more significant are the types of laws described below.
- Laws that prohibit companies from unfairly competing in the marketplace and encourage free enterprise. These laws are vital to our economic system and even verbal agreements and nonverbal gestures like winks and nods between two parties shall be considered a violation. These laws address price-fixing, monopolies, boycotts, trade restraints and other methods of restraining competition and trade practices.
- International operations may be regulated both by domestic and foreign laws. International transactions frequently are complex and foreign laws have many distinctions. Employees engaged in international business must first be aware of these laws in order to ensure compliance.
- Laws that prohibit bribery of foreign officials, require the Company to keep records that properly reflect transactions, and call for an internal auditing system that monitors accounting and other business activities.
- Other laws address export controls and transactions with restricted countries. These laws occasionally may change and may apply to the export of certain commodities, software and technology.
It is essential that employees involved in such activities familiarize themselves with the applicable laws and regulations and shall conform with them. Top
OUR RESPONSIBILITY TO PARENT SHAREHOLDERS
Q-Chem is required to maintain records that provide accurate and timely information about the Company and its activities. This is our obligation to our parent companies as well as management, creditors, government agencies and others. It is essential that employees follow established reporting procedures, provide accurate information and maintain confidentiality when required.
PROPER RECORDING OF ASSETS, LIABILITIES AND TRANSACTIONS
It is Q-Chem' s policy to maintain appropriate books and records of assets, liabilities and business transactions. Financial and other business information shall be maintained under procedures and practices that accurately reflect the true nature of the transactions and accurately incorporate the relevant data.
Accuracy of the Company's entire financial system depends upon individual entries. With this in mind, employees are expected to properly record business transactions in a timely manner regardless of whether the transaction is large or small including but not limited to the following:
- Report accounts and financial transactions in the appropriate financial accounting system. There shall be no 'off the record' accounting transactions or accounts.
- Prohibit making false or misleading entries in the accounts, records or reports.
- Make all Q-Chem business transactions and accounts available to all external and internal audit authorities.
- Properly authorize and accurately describe expenses and reimbursements which shall be business-related.
- Prevent over or under invoicing of customers and vendors for any reason.
- Ensure fees and commissions to consultants, agents and other third parties are legal, proper and consistent with industry practice.
- Approve payment of finders, promoters or consultant fees shall be according to the Board of Director's Delegation of Authorities prior to payments being committed or paid.
- Prevent secret or unrecorded funds from existing. Top
HEALTH, SAFETY AND ENVIRONMENT
Q-Chem is committed to protecting the safety and health of our employees and to ensuring good environmental stewardship in Qatar. We are striving for continuous improvement in these areas and are committed to achieving compliance with safety, health and environmental regulations.
Employees are expected to understand the laws and regulations affecting their business activities. The failure to comply with these laws and regulations can result in risks for fellow workers, the Company, and others. Additionally, Q-Chem may establish additional safety policies that go beyond environmental regulations established by the State of Qatar.
Any employee who intentionally violates legal requirements related to health, environment and safety, or who intentionally fails to take reasonable steps to correct such violations, shall be subject to immediate disciplinary action as outlined in the Discipline Policy.
Intentional violations can result in penalties, fines or imprisonment of the employee who commits the violation. Employees are also responsible for knowing the corporate and operating unit policies regarding health, safety and environmental matters that apply to their jobs. If you have any questions, ask your supervisor or a safety or environmental professional. Top
OUR RESPONSIBILITY TO FELLOW EMPLOYEES
Q-Chem strives to maintain a work environment that is pleasant, healthful, comfortable and free from intimidation, hostility, discrimination, harassment or other offences that might interfere with productivity. Working together productively is vital to business success. Treating one another professionally and with respect is good business.
Q-Chem believes in treating people with dignity, and providing fair employment opportunity for its employees in our development practices, including recruiting, compensation, professional development, and promotion.
We believe in respecting human rights, providing safe and healthy working conditions, and in respecting employees' rights. We recognize that integrating the unique attributes and talents of our diverse work force contributes to more creativity and offers broader solutions to problems. These values extend throughout our organization. Top
Violations of the policies contained in this policy harm all employees and shareholders in the long run. They can cost money, cause injuries and damage assets. For these reasons, suspected violations shall be reported via the Code of Ethics Non-Compliance Form to your immediate supervisor, Department Manager or Senior Management as defined in this policy. Every effort will be made to safeguard confidentiality when requested. Reporting is considered confidential and no employee will suffer retaliation because of a report made in good faith. All reported violations shall be investigated by Senior Management. Many Q-Chem employees are responsible for administering or overseeing the work of contractors, agents or individuals associated with other organizations. When activities are handled by third parties on behalf of the Company, it is Q-Chem's policy that those activities will be performed in full compliance with the law and in accordance with this code. It is the responsibility of Q-Chem employees overseeing these individuals to communicate the Company's policies and to monitor their work to ensure compliance. Top
It is Company policy that no employee will suffer retaliation in any form for reporting suspected problems in good faith. Disciplinary action will be taken against anyone who retaliates directly or indirectly against an employee who reports a suspected violation of Q-Chem policies. Disciplinary action will also be taken against an employee who maliciously accuses another employee without proof.
PRIVACY OF INFORMATION
Q-Chem collects and maintains personal information which relates to your employment, including compensation, medical and benefit information. Q-Chem shall protect employee personal information wherever it is stored or processed. Employees who have access to personal information shall not disclose or distribute personal information without permission from the affected employee. Top
CONFLICT OF INTEREST
The principle of conflicting interests is simple. Q-Chem employees shall neither compete with the Company nor shall they work for competitors. The best interest of the Company shall remain first priority. Conflict of interests occur in situations where a choice must be made between an employee's personal best interest and the best interest of Q-Chem. Every employee has an obligation to avoid financial or other outside relationships that could be adverse to the interests of the Company. This includes activities that might produce conflicting loyalties or interests and those interfering with effective job performance. Preventing situations in which a conflict of interest can occur include but are not limited to the following:
- Establishing clear rules of conduct with respect to Conflict of Interest
- Minimizing the possibility of Conflict of Interest arising between the private interests of employee and Company interest related to official duties of Employees and providing for the objective and fair resolution of such conflicts should they arise.
It is impractical to list every activity or interest that might constitute a conflict of interest. Therefore, it is imperative that employees understand their obligation not to use or appear to use one's position for personal gain and should refrain from becoming involved or place themselves in situations that may be perceived as conflicts. There are also many borderline situations that need evaluation based on all relevant information. Therefore, it is important that every employee be encouraged to disclose to his or her supervisor any situation that might involve a potential conflict of interest or the appearance of one. In many cases, full disclosure to the Company is all that is necessary to protect the Company's interest. In other cases, prompt elimination of the activity may be required. However, if an employee has knowingly failed to report a significant conflict, more drastic action, such as termination, could occur. Conflicts of interest include but are not limited to the following:
Company management approval is required if an employee holds an interest in a company in the same business lines as Q-Chem. This includes holding financial interests, either directly or indirectly as well as interests in enterprises that conduct substantial business with the Company. It may also be detrimental to the Company's interests for employees to do any work for a competitor or to accept any commission, fee or other form of compensation that is related to or influenced by the employee's job within the Company.
Relatives, Customers, Contractors and Suppliers
Situations may arise in which an employee's spouse, child or close relative is employed or has a financial interest with a customer, contractor or supplier to Q-Chem. Frequently this is not a problem, but the potential for conflicts of interest or the perception of impropriety may exist. Therefore, it is important that the employee disclose these situations in writing to management. Employees may have job duties with direct responsibility over a customer, contractor or supplier where a relative is employed. In addition to written disclosure and receiving approval from management, steps may be taken to minimize or eliminate the potential for a conflict of interest to occur. This may include reassignment of approval authority for the specific customer, contractor or supplier; more direct supervisor involvement; or reassignment to another job.
Misuse of Company Assets
Taking care of Q-Chem resources is every employee's responsibility. It is inappropriate for employees to take or use such resources to further personal interests without approval. Taking possession of Q-Chem equipment or materials without prior approval shall constitute theft and shall result in immediate disciplinary action, including but not limited to termination.
Entertainment, Gifts and Bribes
Conducting business with the expectation of obtaining something from a customer is unacceptable. Employees are prohibited from accepting any personal payments, bribes, loans or services from customers, contractors, suppliers, vendors or competitors unless that interest is declared by the employee in advance and approved by Senior Management. Each can be construed as a form of coercion or a part of a sum received often because of release or acceptance of confidential information. Employees may be required to dispose of the interest and must be removed or disqualified from any activity involved in the award or administration of contracts or purchases. Normal business courtesies may permit the acceptance of entertainment and gifts for employees or their families when such favors are customary in the business and are nominal. Any entertainment, gift, or favor that is too repetitive or carries a perception of influence or which imposes an obligation on the receiver or giver is inappropriate. Employees may be authorized to extend entertainment, gifts or favors to business associates under the following conditions:
- Prior approval is received from Senior Management
- They are legal
- They are not offered for a specific gain or specific action
- They follow the generally accepted ethical standards of the country where the activity occurs
- The value is modest and cannot be construed as illegal or improper
- Public disclosure would not embarrass the Company
USE OF COMPANY NAME OR PROPERTY
Employees shall not use the Company's name, property or purchasing power for their own personal gain including but not limited to the following:
- Diverting business opportunities form the Company for personal gain
- Recommending an acquisition of an item that is owned by the employee, a relative or associate without proper disclosure
- Use of Q-Chem telephone number, job title, address or business card to promote or carry on a personal business
- Operate equipment in a Company shop after hours to repair or construct personal articles
- Solicit donations form local merchants, contractors and suppliers in the name of Q-Chem
- Use of Q-Chem property for personal interests Top
USE OF INTERNET AND E-MAIL
Q-Chem's information and communication system, including connections to the Internet and E-Mail system, are vital to our business and shall strictly be used for conducting Q-Chem business or for other incidental purposes. Inappropriate use as outlined in the Q-Chem Computer Systems Policy shall be considered misuse of Q-Chem assets and is a violation of the Ethics policy and shall be subject to disciplinary action.
All intellectual property, inventions, technology developed or conceived by employees during or as a result of their employment with Q-Chem, which are known, or could reasonably be anticipated to be of direct benefit to Q-Chem shall be reported and will become the property of Q-Chem.
Q-Chem also recognizes and respects the legal rights of other Companies and employees on ownership and use of intellectual property. With this in mind, Q-Chem will:
- Comply with copyright laws and respect the rights of owners of films, videos, books, written materials and computer software.
- Prohibit infringement or illegal use of any trademark, patent, trade secret or proprietary technology or information belonging to a third party.
- Take appropriate measures to ensure Q-Chem's intellectual or proprietary assets are not infringed upon or misappropriated by others. Top
TENDERING, CONTRACTING AND PROCUREMENT
Q-Chem's policies and procedures for the procurement of goods and services, tendering and awarding contracts must be adhered to strictly, including but not limited to the following:
- Award all contracts on the basis of competitive bids, except in circumstances where a negotiated bid is expressly authorized or a bid waiver is obtained.
- Ensure Q-Chem's actions with respect to bidders or potential bidders shall be fair, ethical and beyond reproach.
- Proper review and approval of all contracts shall occur within the authorities delegated.
- Protect Q-Chem's business, operational, financial and legal interests
- Ensure technical and commercial evaluations of all proposals are thorough and objective.
- Avoid disclosure of information either directly or indirectly to a potential bidder to enhance competitive advantage or reciprocal dealing which would result in personal gain or be detrimental to the welfare, interest or image of Q-Chem. Top
1. Thoroughly read this policy.
2. Complete the TRACS Mandatory Training assigned by Training Department
1. Assign mandatory training class to all Q-Chem employees, contractors and secondees.
2. Provide a report of employees who do not complete the mandatory training class and provide to Human Resources Manager, employee's supervisor and Senior Management.
Human Resources Manager
1. Enforce Discipline Policy for employees who fail to complete mandatory computer based training and test. Top
- Computer Systems Policy
- Safety Policies and Procedures
- Discipline Policy
APPENDICES / ATTACHMENTS / FORMS
- Code of Ethics Non-Compliance Form Top