The Company requires its employees to maintain the highest ethical standards in the process of conducting Company business. This Code is a guide and resource to provide information on business conduct issues. While this Code does not address every circumstance that may arise in the workplace, employees are expected to use their common sense and best judgment when addressing business conduct issues. When the course of action is not clear, employees are expected to seek guidance from management and senior leadership.
We expect our managers and supervisors to set an example for the workplace by adhering to the Code of Business Ethics. They are responsible for instructing subordinates, reporting any suspected violations, and issuing discipline to violators.
We expect employees to abide by the Code, not assist anyone in violating the Code, and reporting any perceived violation.
All contracts with customers and partners must be fairly negotiated and concluded, with no hidden deals or unspoken agreements, and fully recorded in writing.
Selection of suppliers and sub-contractors must be made on the basis of strictly objective criteria. Such criteria include quality, technical excellence, cost/price, schedule/delivery, services and maintenance of adequate sources of supply and safety record where appropriate.
Employees must avoid any situation that involves or may involve a conflict between their personal interest and the interest of the Company. As in all other facets of their duties, employees dealing with customers, suppliers, vendors, contractors, sub-contractors, competitors or any person seeking to do business with the Company are required to act in the best interest of the Company.
Each employee must make prompt and full disclose in writing to his/her manager of any potential situation that may involve a conflict of interest. Such conflicts include, but are not limited, to the following:
Honest and accurate recording and reporting of Company information is extremely important. The Company must be able to provide accurate information about its business, and to make informed business decisions based on reliable records.
Business transactions of all kinds are to be executed only by employees who are authorized to do so.
No unrecorded funds may be established or maintained for any purpose.
Records shall not be falsified in any manner.
No entry may be made that intentionally hides or disguises the true nature of any transaction.
Employees with supervisory duties are responsible for establishing and maintaining an effective system of administrative and accounting controls in their areas of responsibility.
Employees must not destroy or alter any documents in anticipation of a request for those documents from any government agency or a court.
Employees must not lie or make any misleading statements to any government investigator.
Employees must not attempt to cause any other Company employee, or any other person to fail to provide information to any government investigator or to provide any false or misleading information.
The revelation or use of any confidential service information, data on decisions, plans or any other information that might be contrary to the interest of the Company or the customer without prior authorization is prohibited. The misuse, unauthorized access to, or mishandling of confidential information, particularly personnel and financial information, is strictly prohibited and will subject an employee to the appropriate penalties under the Disciplinary Procedure. Employees may also have access to sensitive customer information, and this must also be held in the strictest confidence.
The Foreign Corrupt Practices Act prohibits giving, offering or promising anything of value, directly or through the use of an intermediary, to foreign officials or foreign political parties, officials or candidates, for the purpose of influencing them to misuse their official capacity to obtain, keep or direct business or to gain any improper advantage. It also prohibits knowingly falsifying a company’s books and records or knowingly circumventing or failing to implement accounting controls.
The giving or receiving of bribes or kickbacks are illegal and prohibited.
No funds or assets of the Company will be paid, loaned or otherwise disbursed as bribes, kickbacks or other payments designed to influence or compromise the conduct of the recipient.
Illegal contributions are prohibited.
“Favorable treatment” examples include the following:
Employees may NOT offer or exchange gifts, gratuities or favors with any public sector employee.
Employees may NOT pay for any meals, entertainment, travel or other expenses for any public sector employee.
Employees may NOT render any other items or services of value to any public sector employee.
Any exception must be approved by General Counsel.
Gifts, Favors and Payments by the Company
Gifts, favors and payments may be given to others at Company expense, if they meet all of the following criteria:
Gifts, Favors and Payments Received by a Company Employee
Employees shall not seek or accept for themselves or others any gifts, favors, entertainment, payments without a legitimate business purpose nor shall they seek or accept personal loans from any persons or business organizations (other than conventional loans at market rates from lending institutions) that do or seek to do business with the Company, or who is a competitor of the Company.
In the application of this policy, employees may accept for themselves common courtesies usually associated with customary business practices.
These include, but are not necessarily limited to: meals, gifts of small value, such as calendars, pens, pads, and office accessories, perishable items such as nuts, candy, and fruit. Receipt of alcoholic beverages is prohibited in Kuwait.
Each employee has a responsibility to ensure that his/her weekly time report accurately sets for the actual hours worked on a specific work order or project.
Time worked on a project must be charge to that project and to no other.
Employees are required to record time worked in accordance with established procedures.
Each supervisor has a responsibility to ensure that the timesheets that are approved are accurate and reflect actual hours worked by the individual employee.
Computer resources must be used for business purposes, and in accordance with all laws, regulations, and policies. The Company does allow incidental, occasional personal use of its E-mail and Internet system.
E-mail is NOT private, and it is monitored.
All computer records and email are the property of the Company.
No electronic “snooping” is permitted, and no “hacking” into others’ computers is permitted. Misuse of the computer systems will subject the offender to discipline.
The Company is committed to providing a fair process in all of its employment processes, and to make a good faith effort to provide reasonable accommodations to employees with disabilities.
The Company does not tolerate any form of harassment, and works diligently to maintain a work environment free of hostility. The Company expects its employees to conduct themselves with proper respect and humility.
All employees are expected to come to work free from the influence of illegal drugs or alcohol.
It is expected that all employees comply with this policy.
Report any violation to a member of management, the Manager of Human Resources, the Director, or the Chairman of ASMACS.