Code of Business Conduct

1. Introduction

Our Code establishes the ethical standards and expectations for all employees, contractors, and third parties associated with our company. It fosters a culture where high performance aligns with ethical behavior, focusing on compliance with laws, human rights, environmental responsibility, and continuous improvement.

2. Compliance with Laws and Regulations

  • Adhere strictly to all applicable local, national, and international laws, including anti-bribery, anti-corruption, competition, and trade compliance laws.
  • Maintain clear procedures for trade controls, customs, and sanctions compliance.

3. Integrity and Ethical Behavior

  • Integrity is the foundation of our reputation; all actions must be guided by ethical considerations and the pursuit of IHSAN, doing what is right with sincerity and excellence.
  • Live our values every day, taking pride in working with integrity and in service of the broader good.
  • Never engage in actions unless you are certain they align with our ethical standards.

4. Anti-Bribery and Corruption

  • Maintain a strict zero-tolerance policy on bribery and corruption.
  • Prohibit any form of bribe, kickback, or facilitation payment, whether direct or indirect.
  • Ensure that gifts, entertainment, donations, and sponsorships are reasonable, infrequent, and compliant with all laws and company policies.
  • Vet all business partners, vendors, agents, and consultants to ensure alignment with our ethical standards.

5. Conflicts of Interest

  • Avoid conflicts between personal interests and company responsibilities.
  • Disclose potential conflicts of interest to management.
  • Avoid situations that could compromise personal integrity or the company’s reputation.

6. Human Rights and Labor Practices

  • Foster a workplace free from harassment and discrimination.

7. Health, Safety, and Environment (HSE)

  • Prioritize the health, safety, and well-being of all employees and stakeholders, applying the principle of IHSAN to care for people, the environment, and future generations.
  • Empower employees to stop unsafe work and embed safety into all planning and decision-making.
  • Continuously improve HSE practices and transparently report performance.

8. Confidentiality, Data Privacy, and Cybersecurity

  • Safeguard all confidential and proprietary information, including client and business partner data.
  • Protect personal data in compliance with data privacy laws.
  • Stay vigilant against cyber threats and report breaches promptly.

9. Financial Integrity and Recordkeeping

  • Maintain accurate, complete, and transparent financial records.
  • Prohibit falsification of records or misrepresentation of results.
  • Cooperate fully with audits and investigations.

10. Speak Up Culture and Reporting

  • Foster an environment where employees are encouraged to raise concerns with moral courage and integrity.
  • Provide multiple, confidential channels to report unethical behavior or ask questions:
    • To your direct manager or another manager at your location
    • To the Human Resources representative
    • To a member of the Legal or Compliance team

11. Implementation and Continuous Improvement

  • Train all employees and third parties on this Code, ensuring understanding and commitment.
  • Regularly review and update the Code to reflect evolving legal and ethical standards.
  • Enforce disciplinary actions where necessary, aligned with principles of fairness and integrity.

12. Brand, Reputation, and Communication

  • Protect the company’s brand and reputation by ensuring all public and internal communications reflect integrity and excellence.
  • Never speak on behalf of the company without proper authorization, and avoid sharing confidential or sensitive information in public forums.