View standard of employee conduct

Our stakeholders such as customers, suppliers, banks, regulators, etc. expect that the dealings with GCE will be fair, professional, and confidential. To ensure a high standard of service and to improve the quality of service provided, it is essential to adopt a courteous, helpful and professional attitude in our dealings with stakeholders.

Conflict of interest refers to situations where an employee's personal or professional interests conflict with the best interests of the company. Employees should:

1. Not be involved directly or indirectly in any official decision which could affect the value of their own investments.
2. Not use any information obtained in the course of their duties to advance their private interests or those of others.
3. Not engage in other paid/unpaid employment. However, certain positions and activities may be allowed with prior written permission of the HRD and CEO, such as serving as board member, consultant, etc., but these must not conflict with the interests of the Group. The approval can be revoked if it is deemed that the position is of conflicting nature or impedes with the staff duties.
4. Not to abuse the power of his/her office for the sake of personal gains or to be involved in activities, projects, programs or influence or be involved in the decision-making process in favour of a close relative or a personal associate.
5. Inform Management in advance if either they or their relatives stand to benefit from a particular business arrangement.
6. Inform HRD if a relative is known to be working with a supplier, customer or competitor. Such information received by HRD should be immediately passed on to the concerned HOF, CEO and Group Business Excellence Department. This document cannot specify every scenario of conflict of interest. The employee should consult with the respective HRD if he/she is unsure whether a particular situation gives rise to conflict of interest. A relative is defined in section 15 below.

Any money accepted on behalf of GCE must be accounted for or deposited with the relevant authority within the company or in accordance with the applicable policy.
The following principles apply to handling of company's money:

1. Only authorized staff are allowed to collect cash or cheque from customers or other parties.
2. Company's money must be spent for legitimate business needs, after taking required approvals.
3. All transactions must be timely and accurately accounted for.
4. Cash collected from third parties should not use for a personal benefit and should be deposited in the Company's account as per the applicable policy/guidelines.
5. Use of personal money or credit cards for business needs is also prohibited, unless express, written permission is obtained from the CFO. If the CFO is the user, the CEO's approval is required.
6. Corporate credit cards, where issued, should be retained by authorized personnel and used as per the policy/guidelines.

The following principles apply to handling of company's money:

1. Only authorized staff are allowed to collect cash or cheque from customers or other parties.
2. Company's money must be spent for legitimate business needs, after taking required approvals.
3. All transactions must be timely and accurately accounted for.
4. Cash collected from third parties should not use for a personal benefit and should be deposited in the Company's account as per the applicable policy/guidelines.
5. Use of personal money or credit cards for business needs is also prohibited, unless express, written permission is obtained from the CFO. If the CFO is the user, the CEO's approval is required.
6. Corporate credit cards, where issued, should be retained by authorized personnel and used as per the policy/guidelines.

Bribery is offering, giving, receiving, or soliciting of any item of value to influence the actions of other person. Corruption is dishonest behaviour by those in positions of power.

Employees are strictly prohibited from accepting, soliciting, offering, or paying bribes, or indulging in any form of corrupt action.

Disciplinary/legal actions shall be taken against the employees as per the HR Policy and local laws and regulations if they are found to be involved in the acts of bribery or corruption.

Gifts and entertainment can be another form of bribery. Problems may arise when these gifts or entertainment occasions are being used to influence decision in the company. Consider the following guidelines in relation to gifts, meals, and entertainment (non-exhaustive):

1. Employees should not accept gifts, meals or entertainment, or any other favour, from customers or suppliers if doing so might compromise, or appear to compromise, their ability to make objective business decisions in the best interest of GCE.
2. Employees must not accept or permit any member of his or her immediate family to accept, any gifts or other favors from any customer, supplier or other person doing or seeking to do business with GCE, other than items of no commercial value. Any gifts that carry a commercial value should be reported to the Line Manager and HRD.
3. Employees should not ask for gifts, meals or entertainment from a customer or supplier.
4. Gifts of symbolic value, such as trophies, calendars, etc., that are given in recognition of a business relationship, may be accepted. Examples of acceptable gifts include a logo pen, diary, calendar, t-shirt, etc.
5. Employees may accept occasional meals and entertainment from customers and suppliers if the event is attended by the customer or supplier, and the costs involved are reasonable and in line with local custom for business-related meals and entertainment.

All employees have a duty not to disclose, without proper written authority, any non-public information that has been obtained in the course of official duties. This rule extends to all documents, records, and information stored electronically. Likewise, employees are required to protect the confidentiality of information relating to external parties which is obtained in course of official dealings. This includes information of customers and contractors/suppliers who have official dealings with GCE. Ways in which official information can be misused include:

1. Leaking information to third parties like competitors
2. Use of information for personal or private gain (financially or otherwise)
3. Taking advantage of a person based on information gained through confidential records
4. Removing, falsifying, not properly retaining or destroying official records, both electronic and hardcopy.
5. Unauthorized access to official Company's records, both electronic and hard copy.
6. Sharing of confidential information with other employees or external parties without authorization.

Non-Public information is any information that the Group has not disclosed or made generally available to the public. Examples include:

• Employees, their compensation and benefits and personal information
• Customers
• Suppliers
• Financial information
• Customers' orders
• Product costs
• Contracts/Proposals
• Bill of Materials
• Business plans

It is the responsibility of the HOD and the Line Manager / Supervisor to ensure that employees driving company vehicles are appropriately licensed and authorized to drive the vehicles with the following conditions:

1. License must remain valid
2. License must be appropriate to the vehicle being driven
3. Unauthorized passengers must not be carried
4. Employees must not drive company vehicles when under the influence of alcohol or any other intoxicant or drug.
5. Company vehicles must not be used to provide transport to and from employees' personal residences.
6. Any penalties, fines or damages that occur due to the negligence or fault of the driver will be borne by the driver.

Employees are responsible for proper use and safe keeping of company assets like mobile phones, laptops, etc. that have been issued to them for business use. As such, they will be held accountable for any costs towards loss or repair of the asset resulting due to their negligence. Necessary action i.e., decision to recover loss from employee or decision of company bearing the loss will be taken by the concerned HR department and the BUH. Employees must also endeavour to protect the Company's property (furniture, machines, etc.) and not cause any damage to them.

GCE expects all employees to act in a professional manner and with respect towards others. Diverse workforce is an asset, and we should actively strive to promote and embrace diversity in the workplace.

The principle of fair and equitable treatment means:

1. Treat others as you would like to be treated and be aware of the cultural sensitivities
2. Respect your colleagues (e.g. shouting, misbehaving, abusing, etc. is deemed as harassment)
3. Never use Group communication channels (email or other electronic devices) to transmit racist, derogatory, discriminatory, offensive, or inappropriate language or material.

Harassment and discrimination against employees is not tolerated in GCE.

Harassment of individuals or a group is regarded as any actions aimed at intimidating employees into acting in a certain manner, coercion to make decisions which they do not feel comfortable with, making degrading comments in front of others, shouting at employees in the presence of others and disrespecting individuals in any other way.

Discrimination is regarded as an act or decision based on any arbitrary grounds which may negatively affect any individual or group and be regarded as unfair (e.g., giving an increase to one group of employees and not another, basing the decision on ethnic origin and not performance criteria).

Continuous negative subtle behaviour expressed towards a person, whether in the presence of others or not, such as personal attacks, belittling, defamation of character, rankism. etc., that are not specifically covered under the category of discrimination and harassment, are also prohibited.

Please see 'Employee Grievance' in the HR manual for advice on recourse to be taken in any of these situations.

The Group has zero tolerance towards fraud, theft, and illegal activities. Appropriate disciplinary and/or legal actions are taken against the employees found to be involved in these activities.

An employee must always be alert and vigilant with respect to fraud, theft, or any illegal activity that threatens company interests. If any such activity comes to the attention of an employee, he/she must immediately report the matter to either his Line Manager, HOF or follow the Whistleblowing policy as provided on the intranet. The company also takes a very serious view of those staff who were aware and fail to report any such activity.

All cases of actual or suspected fraud are reported to Group Business Excellence Department for investigation.

Fraud is any intentional or deliberate act to deprive another (Company) of property or money by guile, deception, or other unfair means. Fraud includes the below three major categories :

1. Corruption, bribery, etc.
2. Theft/misuse of assets
3. Fraudulent financial reporting

All employees are expected to fully comply with the applicable laws, regulations, internal policies and procedures and delegation of authority at the workplace.

The dress and appearance of all employees should reflect a professional image and should also be in line with UAE's culture. At all times clothing should be appropriate to the duties and employees' appearance should be respectable, neat, clean and tidy. Employees are expected to use their good judgement to decide the appropriate wear for the business environment. Uniformed employees should ensure that their uniforms are well maintained.

GCE follows the policy of promptly notifying all employees of information that are of general company interest. GCE management encourages employees not to depend on rumours but to ask their supervisors/Line Managers or use other official channels if they need further information about the company or about activities that may affect their job.

Employees are expected to discourage the practice of starting or spreading rumours and to refrain from being party to such actions.

Only authorized GCE spokespersons may speak to media representatives on behalf of the Group. GCE spokespersons are to respond in a timely manner to requests for interviews and media enquiries. Refer any questions, approaches or interview requests from the media to authorized GCE spokespersons.

Transactions with governments may be covered by special legal rules and may not be the same as conducting business with private parties. Consult Group Legal Department to make yourself aware of the rules and comply with them.

Relatives may be employed in accordance with normal staffing requirements and subject to fulfilling the required employment criteria. However, no relatives will be allowed to work in a position that is considered a conflict of interest (e.g. direction supervision of a relative, etc.).

The employee must disclose to their respective HRD about his/her relatives working in the Group companies.

Relatives for the purpose of this document are defined as: parents, children, spouse, siblings, aunt/uncle of first degree, first cousin, stepchildren/parents and in laws.

The employees will sign a declaration annually or once every two years that they have read and understood this Standard and fully comply with it. Any non-conformance with these standards will need to be fully disclosed. The process is managed by the concerned HRDs.

Employees may request for salary certificates. Moreover, certain information about the company/products may be provided on the Company letterheads. Employees are expected to use them responsibly and should not forge or alter any information contained in these letters.

Possession, purchase, sale or use of alcohol or any illegal drug at work is strictly prohibited. Any non-compliance with the Standards of Employee Conduct may result in disciplinary and/or legal actions against the concerned staff.