Code of Ethics

KCG Emirates shares the same code of ethics of the IKK group which are mentioned here below:

I. Purpose:
Isam Kabbani & Partners Group requires maintaining the highest ethical standards of the work performed. Therefore, this code of ethics is considered as an essential element of performance at KCG Emirates. Compliance with the requirements of this code is deemed an employment precondition, as the Group expects its employees to take their responsibilities to the highest ethical and professional levels.
The importance of announcing the Code of Professional Ethics is to provide a general instructions guideline that assists employees in performing their tasks and achieving the highest level of required personal honesty and professionalism.
Code of Ethics is considered the essential element of employee's guidance policy, and it also facilitates adaptation with the main honesty principles. In addition, it defines KCG Emirates's commitment to impartiality and achieving tasks professionally.

II. Applicability:
Code of Professional Ethics is applicable to all employees in local and external departments, including management level, administration officials, technicians and employees.
Any employee shall not accept or contribute in any work that violates or contradicts with the policies stated in the Code of Ethics. Accordingly, any violation to or contradiction with the policies of this Code shall be reported to the Human Resources department, and necessary disciplinary actions shall be taken, which may consequently lead to employment termination.

III. Violations:
Any employee, who violates any professional ethic, will be subjected to disciplinary actions that may escalate to employment termination. Examples of behaviors that may result in further disciplinary actions are:
Inciting others to violate the Code of Ethics.
Negligence to submit complaints regarding confirmed or potential violation to the Code of Ethics (cheating or stealing).
Refusal to take show up to investigations regarding breaches to the Code of Ethics.
To misbehave with an employee when he submits a complaint regarding a breach to the Code of Ethics.

1. Values and Ethics:
An employee has to act with honesty, integrity and fair dealing with others and shall not make any inaccurate or misleading claims about any matters related to the activities of KCG Emirates, which may lead to conflict of interests.
The employee is required to characterize with values of forgiveness and humbleness.
KCG Emirates expects its employees to maintain honesty, integrity and good conduct along with complying with applied rules, regulations and policies, in a manner that does not affect the position and reputation of the Group or reflects negatively upon employees' performance.
An employee of KCG Emirates shall persistently provide the highest level quality of services to customers, make sure that they are satisfied with the provided services and show the positive image of the Group.

2. Principle of Equal Employment Opportunities:
Equal Employment Opportunity policy of KCG Emirates affirms the right of every employee to participate in all aspects of employment regardless to race, color, nationality, sex, age, marital status, national origin or disability (provided it is not affecting performance). The Group depends upon qualifications (experience, education, abilities and skills) and all other standards that are adopted as a base for selecting and evaluating employees and applicants.
This principle shall be applied to several employment fields, such as: attraction, recruitment & selection, promotion, demotion or salary decrease, transfers, training and employment termination in addition to payroll system.

3. Management Responsibilities:
A. To ensure a work environment that ensures complying with the Code of Professional Ethics, as follow:
To directly supervise implementation of policies through holding periodical meetings, studying submitted reports and continuous monitoring of all programs and commitment-related issues.
Leadership shall be an example for employees through its ethics and behaviors.
Employees shall realize that obtaining results is not more important than complying with the Code of Professional Ethics.
Encourage employees to ask any questions related to honesty or to raise a complaint, in situations where staying quiet may lead to harming the Group.

B. To prevent problems of breaching the Code of Professional Ethics:
Ensure identifying problems of breaching the Code of Professional Ethics that may affect performance.
It is essential to ensure communicating policies and procedures related to solving problems of breaching the Code of Professional Ethics.
To disclose problems of breaching the Code of Professional Ethics through:
Providing an efficient system that encourages employees to raise complaints without fear from any reaction.
To respond to problems of breaching the Code of Professional Ethics as follows:
Instant remedial response to solve problems breaching the Code of Professional Ethics.
Taking necessary disciplinary actions.

4. Responsibilities of Employees:
4.1 Complying with systems & regulations:
Employees shall comply with systems and regulations applied at KCG Emirates, including those related to discipline, security, protection and policies and procedures of human resources applied in the Group.
Employees are expected to fully perform their work, tasks and responsibilities in a manner that does not contradict with the interests of KCG Emirates.

4.2 Complying with the Code of Professional Ethics:
Upon joining the Group?s team, employees shall comply with the following:
Read the Code of Professional Ethics and make sure that they fully comprehend all points.
Make sure that the Code of Professional Ethics is applied on all subordinates.
Comply with all policies related to the Code of Professional Ethics.
Not to hide any information related to breaching Code of Professional Ethics by other employees.
Sign the message of adhering to the Code of Professional Ethics by the employee and maintain the signed message at the Human Resources Department.

4.3 Professionalism:
Every employee shall perform his duties and tasks to the highest level of quality, honesty and competence.

4.4 Receiving Gifts and Tips:
Any employee is not permitted to receive gifts, tips or services either given to him or to any member of his family or friends, which is granted as a result of employment with KCG Emirates, with the exception of moral gifts granted during work.
Employees shall not receive bribes or any financial payments that may affect work decisions.
Employees shall not receive any amount or financial compensation related to their job.

5. Employees behavior:
5.1 Work performance:
Employees are expected to fully perform their responsibilities and duties including supervisory tasks, professional treatment with others, working as part of the team and maintaining work quality and quantity.

5.2 Appearance:
Employees are expected to attend at workplace in an appropriate and elegant appearance that matches the work?s nature.
If the Group supplies an official uniform for the employees, then they are expected to comply and apply during official working hours and it is not allowed to use it outside KCG Emirates.

5.3 Attendance:
Employees have to come to work on time and not to exceed times given to lunch and rest breaks. Employees are also expected to remain at their workplace to the end of the working day. Departure times shall be specified before a certain period in coordination with the immediate superior.

5.4 Safety:
Employees shall perform their work in a safely manner that does not jeopardize other employees. Employees are also expected to maintain safety and health regulations and to immediately report accidents.

5.5 Smoking:
Smoking is prohibited on all premises and facilities of KCG Emirates, except in designated areas.

5.6 Behaviors with colleagues:
Employees shall encourage their colleagues to comply with the requirements and policies of the Code of Professional Ethics.
Employees shall be characterized with justice and support to all their colleagues.
Employees shall attribute any achievement to the employee who made such an achievement and not to themselves.
Employees shall support their colleagues for professional progress.
Upon examining accuracy of another employee's work, this shall be done in a logical way.
Employees shall not unnecessarily interfere in the work of others.
Employees shall not discriminate between employees or annoy any employee, job applicant, customer or visitor.
Employees are not permitted to refuse working or cooperating with any other employee due to racial discrimination or any other reason.

5.7 Children:
Employees are not permitted to bring their children and relatives to the workplace or leave them unsupervised on KCG Emirates premises and facilities during working hours.

5.8 Visitors:
Unless for any reason related to business, employees are required to inform their friends and relatives not to visit them during workings.

6. Sexual Harassment Policy:
KCG Emirates is responsible to provide a sexual harassment-free environment. This policy does not include common compliments accepted by the society, but includes undesired behavior that may lead to personal injury for another employee and
weakening morale, and accordingly, negatively affecting the performance efficiency of the employee and his colleagues.
When an employee realizes that a sexual harassment behavior has occurred, he shall raise a complaint to the Human Resources Department without fear from any reaction by any other person.
The Group encourages reporting misbehavior as a preliminary step for running an investigation and removing any kind of sexual harassment.

7. Nepotism:
The basic criterion of selecting, employing and promoting any employee shall depend on qualifications and performance assessment. Family, marriage or partnership relation shall not grant any preference to or obstruction against employment, which shall depend only upon employment standards set by the Group.
The purpose of this policy is not to discourage employing relatives, but to affirm that selection and assessment criteria are qualifications and efficiencies.

If a family member is competent for a certain job, it is possible to employ him. However, there shall be no family relationship between him and his direct superior, as this may affect employment and assessment decisions, as well as salaries and benefits.
Employees are not allowed to start a business activity or work with any member of their family or any Group directly connected with any member of their family.

8. KCG Emirates Properties:
Employees are deemed responsible for the properties of KCG Emirates under their responsibilities such as keys, employees? identification cards and any other devices or equipment given to employees while performing their duties and responsibilities. Computers, faxes and photocopy machines are not restricted to personal usage.
It is restricted to sell or exploit any goods or services owned by KCG Emirates for personal benefit unless agreed by the Group?s management.

9. Conflict of Interests
Employees of KCG Emirates are responsible towards the Group, and they are committed not to take any action that may lead to contradiction between their personal interests and the Group?s interests.

Conflict of interest may arise in any of the following forms:
Any employee shall not to have any direct or indirect financial benefit from any supplier or client of the Group.
Any employee shall not gain any discounts or personal benefits not granted to other employees.
Any employee shall not be engaged in any outside work, either directly or indirectly, where he may compete or jeopardize the Group's interests and his responsibilities and duties.
Any employee shall not be engaged in any part-time job during regular working hours of the Group.
Any employee shall not practice any personal works or take advantage of KCG Emirates properties for personal purposes.
Any employee shall not exploit his position in the Group to gain any privileges or personal advantages.
Any employee shall not exploit his authority to gain any advantage, profit or personal benefit for himself or for any member of his family or for a friend.

10. Confidentiality
10.1 Maintaining Secrecy:
The employee is responsible to maintain secrecy and integrity of all works, activities, business secrets, files and documents related to KCG Emirates and avoid illegal disclosure to any other parties.
The employee shall not disclose any information related to security or any financial information that has not yet been made public. The said information shall not be disclosed to any other party.
The employee shall keep confidential the Group's relationships and trading transactions with suppliers and brokers and any other parties.

10.2 Documents' Secrecy
The employee shall not make copies of business letters, documents, files or any other documents related to the business and activities of KCG Emirates. The employee shall submit all documents related to the Group's works upon his employment termination.

10.3 Client Privacy
The employee shall use any information related to clients that he maintains or has access to for work purposes only.
The employee shall maintain documents related to clients and shall not disclose such information in a way that violates KCG Emirates?s instructions.

11. Customer Satisfactory:
11.1 Accuracy:
Quotations shall be clear and obvious so that the client can recognize the nature of the work to be done and obligations involved in it.

11.2 Response:
All clients? enquiries and all precautions shall be taken into account in order to guarantee maximum customer satisfaction. KCG Emirates shall set a proper and efficient technique to deal with customers? complaints.

11.3 Fairness:
All sales activities shall be characterized with fairness towards all clients and activities shall be specifically designed to avoid any kind of complaints.

11.4 Guarantees:
The contracting activities shall not include any warranties that provide the customer extra privileges not provided by KCG Emirates.

12. Relationships with Suppliers:
12.1 Ethics of dealing with Suppliers
Transactions with suppliers shall be characterized with honesty, fairness and legal integrity.
Suppliers shall be selected according to efficiency and quality in supplying service, technology and reasonable price.
Provisions and obligations shall be exchanged between KCG Emirates and suppliers and shall be agreed upon during the suppliers' selection process before starting the business. Such provisions shall include payment and secrecy policies adopted by the Group.
Certain provisions in dealing with suppliers:
Employees of KCG Emirates shall not take advantage of suppliers? errors.
Employees of KCG Emirates shall not disclose secret information of the suppliers.
Employees of KCG Emirates shall maintain secrecy of important information related to prices, technology or any other information, and they shall not disclose such information without a written approval.
Employees of KCG Emirates shall solve all conflicts, disputes and claims based upon facts.

12.2 Requirements:
KCG Emirates shall follow approved purchasing systems when buying services and goods for the Group.
KCG Emirates shall undertake maximum precautions to guarantee that the supplier is supplying his goods according to highest quality and at ideal cost and delivery conditions.
KCG Emirates shall deal with the supplier who observes legal and local requirements and any other standards related to labor, environment, health and security.
KCG Emirates procurement employees shall avoid the following:
Selecting a supplier not from the approved list of suppliers.
Conflict of interests when selecting suppliers. This includes accepting gifts.
Selecting a supplier and cooperating with him just because his company is owned by a relative or a friend.
The supplier who does not provide sound or unfair work conditions.

13. Procedures of financial control
All accounting data entries shall be documented either by contracts or by invoices.
It is prohibited to falsify financial data or input false and misleading data. Any funds shall not be maintained without registering it in the approved financial records.
Employees of KCG Emirates shall pay attention to any forgery in financial documents or recording exaggerated fees, such as travel and accommodation fees or invoices, or any forgery in attendance record.
Separate procedures shall be provided related to fees, obligations and personal financial compensations.
The following actions will require stringent punishments:
Purchasing materials unnecessary for operations of KCG Emirates.
Expenses registered against purchases that have not been made.
Exaggerated prices for materials that could have been obtained at lower prices from another supplier.

14. Information Technology:
14.1 Usage of information technology and the Internet:
KCG Emirates makes the Internet available for its employees to enhance efficiency and effectiveness. However, although this tool aims at assisting employees to complete their duties, they may misuse it.
The Group is allowed to monitor the Internet and e-mails and to examine existing files.
Employees are permitted to use the Internet to communicate with clients, suppliers, colleagues, other companies, governmental authorities and any work-related authority for research and information exchange purposes for the interest of the Group, and not for personal interest.
Computer services of the Group shall not be used in a way that violates systems and regulations applied in any country.
Upon using the Internet, the employee shall identify himself and his Group when sending e-mail messages, and shall not send spam messages.
It is prohibited to distribute and store any kind of improper or offensive images on the premises of KCG Emirates. Such a behavior is deemed a violation to the sexual harassment policy.

14.2 Internet Security:
KCG Emirates is allowed to prevent any employee from visiting any website or any server.
Employees are not allowed to use the Internet for spreading any virus or software that may breakdown the computer software or the network. They are also not allowed to stop any antivirus program that protects other users.

15. Environment, Health and Safety Policy:
KCG Emirates is dedicated to secure and apply sound environmental, health and safety conditions. This obligation is applicable to all employees.
KCG Emirates is working hard to provide healthy work environment and to prevent work injuries or damages to the environment and society.
KCG Emirates is required to maintain safe operations that fulfill regulations of environment, health, safety and security applied in the country.
Herein under are some requirements for maintaining a healthy and safe work environment:
KCG Emirates shall alleviate harmful environment emissions, reduce usage of harmful materials and minimize risks upon providing various services.
KCG Emirates shall maintain a safe and harm-free work environment.
KCG Emirates shall pay attention to local and international environmental regulations.
KCG Emirates shall prevent the following conditions:
Not using personal protection equipment such as shoes, eyeglasses, headphones, etc...
Exposure to uncovered and unsafe electrical wires.
Working on electrical equipment without following the relevant instructions.