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     Comprehensive Compliance Management

Compliance Responsibilities

Following the law, both in letter and in spirit, is the foundation on which our company’s ethical standards are built. All employees, officers, executives and directors shall respect and follow the laws, rules and regulations. We do business in a highly regulated trade and business; compliance with legal and regulatory requirements is a prerequisite for our license to operate.

Compliance means our behavior is in adherence with applicable laws, regulations, trade codes and Safwan’s integrity standards.

Safwan has established a Compliance Management System (CMS), which we are committed to implement and enforce. The CMS focuses on preventing, detecting and responding to non-compliance behavior by comprehensively involving people, purpose, principles, policies and processes.

Safwan believes that the sense of responsibility of each and every employee is the basis of compliance. Thus we must constantly and adequately identify, assess and manage the compliance risks that fall within the sphere of our business responsibilities. Performance is not only measured by the results achieved, but also how these results were achieved and which impact they created.

We at Safwan understand compliance as a key Line Management responsibility. As a matter of fact, in many cases non-compliance is the consequence of bad and/or no leadership. Hence, as part of our leadership task, Safwan Line Managers are obliged to carefully select, instruct and monitor the employees for whom they are responsible. They are expected to involve compliance aspects in the performance assessment of their employees. Safwan is committed to providing adequate training for Line Managers which enables them to meet their responsibility.

Compliance functions are responsible for supporting employees and Line Management in many ways in our comprehensive compliance management.


We are all expected to:


Be aware of our responsibility in the comprehensive compliance management.

Continuously and adequately identify, assess and manage compliance risks that fall within the sphere of our business responsibilities.

 

Example:


I am considering granting an improper advantage to a business partner in order to achieve my business target. Is a business target a valid justification for the granting an improper advantage?

No, Stretched business targets are never an excuse or justification for violating our integrity standards. Always remember, you are responsible and will be held accountable for your behavior.

 

I am a Line Manager. What is my role in the comprehensive compliance management?

Compliance is a key Line Management responsibility. As part of your leadership function you are obliged, including but not limited to, carefully select, instruct and monitor the employees for whom you are responsible.

 

 

 

                 Compliance Procedures (Help & Advice)


Questioning is part of preventing. In our daily work we may face situations from time to time which are not explicitly covered by Safwan’s Code of Conduct and Ethics or the documents it refers to (e.g. directives, policies, and guidelines). If we are unsure about the correct behavior, we should ask ourselves the following questions:

Is my behavior legal?

Is it in line with Safwan’s Values?

Does it comply with Safwan’s Code of Conduct and Ethics?

Could it have negative consequences for Safwan or myself?

Would I be comfortable if it was reported in a newspaper?

 

Often this will provide all the guidance we need. However, in case of doubts or uncertainties about the correct behavior, seeking help and advice is the right thing to do.

By fostering a culture of openness to ask questions, Safwan, first and foremost, aims to prevent non-compliant behavior. Safwan Line Managers are responsible for ensuring that all employees reporting to them receive the help and advice they need to comply with the Safwan Code of Conduct and Ethics.

Discuss the problem with employee’s Line Manager. This is the basic guidance for all situations. In many cases, employee’s Line Manager will be more knowledgeable about the question, and will appreciate being brought into the decision-making process. It is employee Line Manager’s responsibility to help solve problems. If the employees are uncomfortable discussing the problem with the Line Manager, the employees can talk to the Compliance Officer.

 Employee may report violations in confidence and without fear of retaliation. If employee situation requires that their identity be kept secret, their anonymity shall be protected. The company does not permit retaliation of any kind against employees or officers for good faith reports of suspected violations, as outlined in Safwan’s Whistleblowing Policy. All employees are expected to cooperate in internal investigations of misconduct.

 

 

We are all expected to:

Always ask first, act later, if you are unsure of what to do in any situation, seek help and advice if we have doubts about the correct business behavior.

Provide help and advice to employees who report to us.

 

Example:

What can I do if I am unsure about a correct business behavior?

Ask yourself specific questions such as “Would I be comfortable if my behavior was reported in a newspaper”? In case of doubt, seek help and advice.

 

Where can I seek help and advice?

You can contact your Line Manager or Compliance Officer.

 

               Speak up


Speaking up is the right thing to do. Safwan employees who speak up when they believe in good faith that Safwan’s Code of Conduct and Ethics has been breached are doing the right thing and are acting in line with our values.

Safwan’s Management needs to be aware of integrity issues so that it can address them quickly and in a trustworthy way. By raising compliance concerns, Safwan’s employees help to protect themselves, their colleagues and Safwan’s interests and rights.

If we have a compliance concern, we primarily talk to our Line Manager. If we are uncomfortable doing so, we should contact the Compliance Officer, Legal, HR Manager. Alternatively, you can use Whistleblowing Channels.

Subject to Safwan’s Whistleblowing Policy, whistleblowing channels allows Safwan employees to report a compliance concern anywhere and anytime in English/Arabic language, either by website and/or by phone. The system is operated to provide the option to speak up in anonymity.

 Access to the free phone line (00965-22276871) and for Safwan’s whistleblowing Line web service can be on Safwan website under the following URL .

Or/and user-friendly tools, such as scan QR Code.  .

Any employee who raises a compliance concern in good faith acts in the interest of Safwan and deserves acknowledgement. Safwan does not tolerate any retaliation against an employee who raises a compliance concern in good faith. Line Managers and/or employees who retaliate will be held accountable. In case any employee deems that this principle is not adhered to, a complaint can and should be raised to either to HR Manager, Compliance Officer, Chief Operating Officer or Chief Executive Officer.

Equally, Safwan does not tolerate any abuse of Safwan Speake up/Whistleblowing Channels.

 

We are all expected to:

Speak up when you believe in good faith that someone has done, is doing, or may be about to do something that violates Safwan Code of Conduct and Ethics.

 

Example:

When should I speak up?

If you believe in good faith that someone has done, is doing, or may be about to do something that violates Safwan’s Code of Conduct and Ethics, you are expected to speak up.

 

Which are the available speak up channels?

Your Line Manager is generally your first point of contact. If you feel uncomfortable discussing your concern with him/her, you can contact HR, Legal or Compliance Officer.

 

When using Whistleblowing Line, can I remain anonymous?

Yes, as Safwan Whistleblowing Line is operated to provide a system offers the option to speak up anonymously.

*Refer to Safwan’s Whistleblowing Policy for more information and details.

 

               Compliance Officers


Compliance Officers support us. Compliance Officer is committed to ensuring that the Safwan Code of Conduct and Ethics is consistently complied with throughout the Company. The Compliance Officer also serves as a contact for employees, shareholders, business partners, customers and the general public on issues relating to the implementation of and compliance with Safwan Code of Conduct and Ethics.

Compliance Officer has been appointed with the following responsibilities, in particular, but not limited to:

Ensuring that employees know where they can ask for help and advice if they have doubts about the correct business behavior;

Coordinating local compliance endeavors, initiatives and training programs;

Supporting and conducting compliance monitoring, compliance controls and compliance audits;

Supporting Line Management in the local integrity risk-management processes;

Supporting Line Management in the adequate handling of local non-compliance cases, including submitting an immediate report in case of any business ethics incident;

Encouraging employees to speak up if they have a compliance concern;

Compliance Officer coordinates the network of Compliance Officers with other business partner and makes sure that best practice examples are regularly exchanged and shared within the network and that Compliance tools are continuously reviewed and updated.

 

We are all expected to:

If you do not feel comfortable for contacting your Line Manager, contact Compliance Officer to seek help and advice or to report a compliance concern.

 

 

Example:

A stakeholder wants to make a complaint against Safwan alleging that somebody within Safwan has violated the Company Code of Conduct and Ethics. To whom can the stakeholder address the complaint?

The Compliance Officer serves as a contact person for employees, shareholders, business partners, customers and the general public on issues relating to the implementation of and compliance with the Company Code of Conduct and Ethics.

 

I work as a sales manager in Safwan and keeping in mind Safwan’s business integrity expectations I do not feel comfortable with an instruction that I received from my Line Manager. What should I do?

Speak up and address your concerns directly to your Line Manager. If you are not satisfied with the answer that you received from your Line Manager, contact with the Compliance Officer who will take and treat your compliance concerns seriously and in a confidential way.

 

               Addressing Non-compliance


Adequate handling of non-compliance cases is a key part of our comprehensive compliance management. Safwan does not tolerate non-compliant behavior. Employees and Line Managers who violate the Company Code of Conduct and Ethics will be held accountable.

Safwan is fully committed to handling non-compliance cases adequately by:

Taking all allegations seriously;

Investigating allegations efficiently and in a timely manner;

Assessing the facts objectively and impartially; and

Taking adequate corrective measures and sanctions, in case an allegation is substantiated.

 

Any accused employee has the right to be heard as well as the presumption of having acted in accordance with the Company Code of Conduct and Ethics, unless the evidence gathered from the investigation reasonably indicates non-compliance. We fully collaborate with the investigators and make sure that we have compliance evidence at hand, which demonstrates that our behavior was compliant.

Chief Operating Officer with the support of Human Resources and Compliance Officer is responsible for determining adequate corrective measures and sanctions.

Non-compliance cases have to be reported under the responsibility of specified Line Managers in the Business Ethics Incident Report as soon as they become aware of them.

The report enables Top Management, Chief Operating Officer and Audit to capture, track and monitor alleged violations, from initial reports through to resolution. The number and related characteristics of non-compliance cases which occurred during a reporting year will be published in the Annual Report of Safwan Trading and Contracting Company K.S.C.C.

We are all expected to:

Make every effort to prevent non-compliance cases.

Fully collaborate with the investigator and ensure we have compliance evidence at hand.

Take adequate corrective measures and sanctions if we have to handle non-compliance cases as a Line Manager.

 

 

Example:

What is meant by “compliance ­evidence”?

Compliance evidence is any form of proof demonstrating that your behavior was correct, e.g. written evidence of the consent of your Line Manager in a possible conflict of interest situation.

 

What shall I do if my Line Manager insists that I undertake something which I consider not in line with Safwan Code of Conduct and Ethics? Is it sufficient compliance evidence if I make a note stating that the Line Manager has insisted on my acting accordingly?

No, if your Line Manager is insisting on incorrect behavior you should speak up by using the available Whistleblowing Channels.

 

               Compliance Training


All Safwan employees, contractors, consultants and agents will be asked to sign a statement certifying that they have received, read, understood, and shall abide by Safwan Code of Conduct and Ethics. In addition, each business may mandate training on more comprehensive Compliance topics.

Employees, contractors, consultants and agents must certify their completion of all training.

Additional Guidance on Compliance Training. Training is provided about topics related to laws, regulations and guidelines applicable to the business, and risks and other identified issues related to Compliance. Training requirements are critical to the success of Safwan’s Compliance Program. Therefore, any employee, contractor, consultant or agent who fails to complete the Code of Conduct and Ethics certification and/or assigned Compliance Training will face disciplinary action.

This Code of Conduct and Ethics may be updated or amended at Safwan discretion from time to time to reflect changes in laws and company policies and practices. You may contact the Compliance Officer for the most current version of this document.

 

 

 

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