Ethics and Integrity Code
Ahmed Al Hosani Computer Programs Trading LLC
(As adopted on March 1, 2010)
Customer Satisfaction - Our future depends on our quality of services to our customers and increasing our customers’ success. We are proactive, hard-driving and easy to work with. We offer expert knowledge and practical solutions. We deliver on our promises.
Integrity - We act with honesty, fairness, respect, furthering a culture of unquestioned integrity.
Employee Engagement - As we grow, so will our people. We foster a culture that promotes excellent performance, teamwork, inclusion, leadership and growth. Our employee and leader diversity will mirror our regional markets and population.
Innovation - We believe there is always a better way. We encourage change and seek the opportunities it brings.
Confidentiality - We are committed to maintaining the highest degree of integrity in all our dealings with potential, current and past clients, both in terms of normal commercial confidentiality, and the protection of all business and personal information received in the course of providing the business services concerned. We extend the same standards to all our customers, suppliers and associates.
Ethics - Employees are expected to act and perform their Company duties ethically and honestly and with the utmost integrity. Honest conduct is considered to be conduct that is free from fraud or deception. Ethical conduct is considered to be conduct conforming to accepted professional standards of conduct. Ethical conduct includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships as discussed below.
Compliance - It is the Company's policy to comply with all applicable laws, rules and regulations. It is the personal responsibility of each Employee in executing his or her Company duties to adhere to the standards and restrictions imposed by those laws, rules and regulations, and in particular, those relating to Copyright matters. Any Employee who is unsure whether a situation violates any applicable law, rule, regulation or Company policy should discuss the situation with the General Manager.
Intellectual property - We retain the ownership of all intellectual property that we create unless agreed otherwise in advance with our clients. We respect and protect the intellectual property rights of our clients and vendors and abide by the Copyright Laws of the UAE and other countries where we operate.
Quality assurance - We maintain the quality of what we do through constant ongoing review with our clients, of all products, services, outcomes and the cost-effectiveness of every activity. We encourage regular training and professional certification of our employees.
Professional conduct - We conduct all of our services professionally and with integrity. We take great care to be sure that our products and services are never influenced by anything other than the best and proper interests of our clients.
Conflicts of interests - Employees should seek to avoid any action or interest that conflict with the Company's interests. A conflict of interest exists where the interests or benefits of one person or entity conflict or appear to conflict with the interests or benefits of the Company. While it is not possible to describe every situation in which a conflict of interest may arise, Employees must never use or attempt to use their position with the Company to obtain improper personal benefits. Any Employee who is aware of a conflict of interest, or is concerned that a conflict might develop, is required to discuss the matter with a higher level of management or the CEO promptly
Accountability, Reporting and Disciplinary Actions - The matters covered in this Policy and Code are of the utmost importance to the Company, its shareholders and its business partners, and are essential to the Company's ability to conduct its business in accordance with its stated values. The Company expects all Employees to adhere to these rules in carrying out their responsibilities for the Company.
Situations that may involve a violation of this Code may not always be obvious and may require difficult judgments to be made. Employees should report any concerns or questions about violations of laws, rules, regulations or this Code to the Company's CEO.
Any concerns about violations of laws, rules, regulations or this Code by the CEO, senior financial officer, any executive officer or director should be reported promptly to the Partners of the Company. The Company encourages all Employees to report any suspected violations promptly and intends to investigate thoroughly any good faith reports of violations. The Company will not tolerate any kind of retaliation for reports or complaints regarding misconduct that were made in good faith. Open communication of issues and concerns by all Employees without fear of retribution or retaliation is vital to the successful implementation of this Code. Employees are required to cooperate in internal investigations of misconduct and unethical behavior.
The Company will take appropriate action against any employee whose actions are found to violate these policies or any other policies of the Company. Disciplinary actions may include immediate termination of employment or business relationship at the Company's sole discretion. Determinations of the type of disciplinary action to be taken will be made by the chief Executive Officer, or in the case of disciplinary action to be taken against a CEO, by the Partners. Where the Company has suffered a loss, it may pursue its remedies against the individuals or entities responsible. Where laws have been violated, the Company will cooperate fully with the appropriate authorities.
Where violation of this Code is disputed by an employee, such alleged violation will be investigated by the CEO, who shall make a determination following such investigation as to whether or not such a violation has occurred. Where a violation of this Code is disputed by a CEO, such alleged violation will be investigated by the Partners , which shall make a determination following such investigation as to whether or not such a violation has occurred. Such a determination by the Company will be final.
Viacheslav Raevskiy, Ph.D.
March 1, 2010
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