DAN General Trading

Code Of Conduct

1. INTRODUCTION

In any work environment, irrespective of its nature, it is important for the employers to determine a set of rules that will regulate the relationship between the employees and the employer in the form of Employee Conduct & disciplinary procedure should be observed in order to function successfully.

DAN General Trading & Contracting Company W.L.L has formulated this Employee Conduct & Disciplinary Code based on the following principles:-

The objective of the procedure is to primarily regulate employee conduct & discipline in the workplace.
The right of management to take appropriate disciplinary steps against any worker, who acts in a manner conflicting with the interests of the Company.
At the same time the code also recognizes the right of a worker to a fair hearing, applicable and just disciplinary action.
The emphasis of the disciplinary code is on prevention, justice and rehabilitation.

The disciplinary code and procedures have been broadly explained in the following sections:

2. PROTECTION OF CONFIDENTIAL INFORMATION

"Confidential Information" means the Company's confidential, secret or property information, trade secrets or business know how or information not generally known to public, including but not limited to the Company's Management & Financial Reports, Budgets, Business Plans, Corporate Strategies and unannounced potential mergers and acquisitions, information related to trademarks, ideas and processes, products and service specifications, market information, customer links and contacts, prices paid or received for goods or services and similar information.

Confidential information consists of any trade secrets or technical information which is not generally known. All employees of the Company, must not at anytime, whether during or subsequent to their employment with the Company, to disclose, communicate or transmit in any form to a third party, any confidential information acquired by the employee in the course of his/her employment. Examples of what are considered to be confidential information in our business would be results of business development activities, mergers & acquisitions, financial analysis, computer programs, new products, etc.

Employees must comply with relevant procedures of the Company to ensure that confidentiality is maintained. Such procedures are as follows:

Ensuring that information which is considered to be confidential is not copied without permission of the original issuer of the information
Employees should properly protect and secure such information while in their possession. (i.e. don�t leave the information sitting on your desk and when the information is stored electronically, make sure it is protected by a password, etc.)
Not disclosing such information to anyone who is not an employee of the Company.

In the event of a breach of this policy by any employee, the employee will be subject to disciplinary action, up to and including termination.

3. CONFLICT OF INTEREST

It is the Company's policy to ensure that all employees avoid transactions, commitments and other activities that are not in the Company's best interest or that could involve a conflict between that individual�s personal interest and those of the Company.

All employees of the Company occupy, in varying degrees, positions of trust and confidence and should operate within their capacities with absolute honesty and loyalty.

It is the duty of all employees not to engage in activities for personal gain in conflict with the interest of the Company. Examples of such activities consist of the following:

Anti- Bribery Policy

DAN prohibits bribery without any exception. It Prohibits:
- The objective of the procedure is to primarily regulate employee conduct & discipline in the workplace.
- The right of management to take appropriate disciplinary steps against any worker, who acts in a manner conflicting with the interests of the Company.
- At the same time the code also recognizes the right of a worker to a fair hearing, applicable and just disciplinary action.
- The emphasis of the disciplinary code is on prevention, justice and rehabilitation.
This prohibition is not limited to cash payments, and includes corrupt:
- gifts of high value (Gift Policy indicates the type of gifts that can be accepted),
- entertainment, meals and travel, in-kind contributions, such as sponsorships,
- business, employment or investment opportunities,
- insider information that could be used to trade in regulated securities or commodities,
- personal discounts or credits, Facilitation Payments,
- assistance to or support of family members, and other benefits or advantages
Gifts Policy
DAN prohibits exchange of gifts with people with whom we do business.
Gifts of any value received for any reason, shall not be accepted by employee
Transactions with Affiliates:
The policy of the Company is to select vendors and contractors on the basis of merit, without favoritism, and whenever practical, on a competitive basis. This policy requires that employees do not engage in any activities that might impair their independence of judgment in selecting a vendor or a contractor. In transacting such business, it is against the Company's policy for an employee in a position that involves buying or selling goods or services, or negotiating with vendors or contractors, to have any substantial economic interest, either directly or indirectly, in any private or publicly-held business organization that transacts business with the Company or is in competition with the Company. Further, no employee, or any member of his/her immediate family or any "affiliate", may lease or rent any kind of facilities or equipment to the Company or individual dealing with the Company. Violation of the above policy can be grounds to terminate the services of the employee as per local labour laws.

4. HARASSMENT

It is and will continue to be the policy of the Company to strictly prohibit any conduct which constitutes any type of harassment and to discipline (up to and including termination) any employee who engages in such prohibited conduct.

Unlawful agreements not need be written or even consist of express commitments. Agreement can be inferred based upon "loose talk", informal discussion or the mere exchange of certain information. If you believe that a conversation with a competitor enters and inappropriate area, end the conversation at one and contact your supervisor or the Compliance Officer.

The purpose of this policy is to ensure the following:

Ensure compliance with local labor laws
Provide a working environment that is free of hostility and offensive behavior
Provide employees with the tools needed to report any type of harassment

Harassment consists of unwelcome conduct, whether verbal, physical, or visual, that is based upon a persons protected status, such as sex, colour, race, ancestry, religion, national origin, age or disability.

One of the most frequent forms of harassment that occurs among employees is sexual harassment. Sexual harassment exists where an employee exercises or threatens to exercise the authority and power of his/her position to control, influence, direct or affect the job, duties, earnings or career of another employee or prospective employee in order to obtain a sexual favour. It also exists when the conduct in question would tend to create an intimidating work environment or to interfere with an employee's work.

Sexual harassment may take many forms, including, but not limited to:

Subtle pressure or requests for sexual activity
Unnecessary touching of an individual, e.g. patting, pinching, hugging, repeated brushing against another employee's body
Requesting or demanding sexual favors accompanied by implied or overt threats concerning an individual's employment status
Requesting or demanding sexual favors accompanied by implied or overt promise of preferential treatment with regard to an individual's employment status.

Any employee who feels he/she has been subjected to any type of harassment by anyone must bring the problem to the attention of the Human Resources Manager & the employee's own Director/Manager.

Allegations of any type of harassment will be promptly and thoroughly investigated and appropriate corrective or disciplinary action, up to and including termination, will be taken to remedy violations of this policy.

The Company will retain in confidence, information and documentation of all allegations and investigations, except when disclosure is necessary in connection with legal or other administrative proceedings.

Each Director, Manager or Supervisor of the Company is accountable, as part of his/her responsibility in directing the work of others, for taking action or prevent the occurrence of any type of harassment in his or her area. It is also the responsibility of each Supervisor to immediately report any complaint to the Director of Security and Director of Human Resources.

5. SMOKING

Tobacco smoking and chewing is not permitted inside any of the Company's open office areas and camp facilities. Receptacles will be placed at designated locations for tobacco users who wish to smoke on their breaks. Managers/Supervisors should ensure that their employees understand and comply with this policy.

6. ELECTRONIC COMMUNICATION

All computer users of the Company have the responsibility to use computers, data, and telecommunications sources in a safe, ethical, lawful, and efficient manner.

All Company employees have a responsibility to use computer, data and telecommunication resources in a safe ethical, lawful, and efficient manner. Computer, data, and telecommunication resources are to be used for business purposes only in the performance of Company approved activities. Inappropriate or unlawful use, and relocation or transfer of Company's computer, data, and telecommunication assets without proper authorization will subject associates to disciplinary, and possibly legal, action.

Users shall not move, relocate, reassign or otherwise modify hardware or software configurations without notifying the appropriate Information Technology Department. This will ensure that the Company's assets are being managed and tracked effectively.

TUsers shall safeguard their accounts/passwords on all systems. Individual passwords should not be printed, stored on-line, or given to others. Users are accountable for all transactions made using their accounts/passwords.

The Company's computer and telecommunication resources may not be used for the transmission or storage of commercial or personal advertisements, solicitations, promotions, destructive programs (viruses and/or self-replicating code), political material, or any other unauthorized or personal use.

Users should not alter or copy a file belonging to another user without obtaining prior permission from the owner of the file. The ability to read, alter or copy a file belonging to another user does not imply permission to read, alter or copy that file. The Company is not responsible for the actions of individual users. Users must agree to indemnify and hold harmless the Company, its subsidiaries, and operating units from all claims and expenses which are a result of usage that violates any laws, patent, or copyright protections

Users must agree to cooperate in any investigations conducted by and/or on behalf of the Company into inappropriate or illegal activities related to computer and telecommunications usage. Programs developed by employees in the course of their employment with the Company are the property of the Company.

Managers/Supervisors are responsible for monitoring the use of computers and telecommunications assets, systems, networks, and services by their association and correcting or reporting in appropriate behaviour. Users are responsible for adhering to this policy and related procedures.

7. INDIVIDUAL GRIEVANCE

To ensure that all employee grievances are managed in a fair and consistent manner, however, the Company preferred option is to resolve these issues in an informal manner through a process of dialogue between the relevant parties involved.

TIf, during the course of their employment with the Company, an employee should have a genuine grievance relating to their employment or conditions, they should, in the first instance, discuss it with their immediate Supervisor. If the matter is not resolved then they may raise it in writing with their Manager.

If, during the course of their employment with the Company, an employee should have a genuine grievance relating to their employment or conditions, they should, in the first instance, discuss it with their immediate Supervisor. If the matter is not resolved then they may raise it in writing with their Manager.

If the matter is still not resolved then they may raise it with their Senior Manager who will make a final and binding decision regarding the matter.

An employee with a grievance involving their immediate Supervisor/Manager should take the grievance to the next level of management with their immediate Supervisor's/Manager's knowledge. Any employee using the foregoing procedure may choose to be accompanied by one other employee.

It is the responsibility of every Manager, Supervisor and employee to ensure compliance with this policy. The Human Resources & Legal Departments are responsible for any updates or maintenance of this policy.

8. DISCIPLINARY CODE & PROCEDURE

The disciplinary code is regarded as a guideline and its interpretation must be adequately flexible in order to adjust to various circumstances.

Objective
- 1.1 The objective of this Disciplinary Code and Procedure is to regulate discipline in the workplace with the key principle that DAN and the employees should treat each other with mutual respect.
- 1.2 The code is designed taking into account on both employment justice and the efficient operation of the business.
- 1.3 While this procedure protects employees from indiscriminate action, DAN is entitled to satisfactory conduct and work performance from its employees
- 1.4 Although discipline in general will be applied according to these provisions, it should be noted that change from these norms may be justified in proper circumstances.
- 1.5 A schedule of corrective and progressive disciplinary steps is attached hereto
Principles
- 2.1 DAN has the right and the responsibility to manage its business and direct its employees in doing so.
- 2.2 DAN reserves the right to implement rules or to establish standards of performance and behavior and the measurement thereof.
- 2.3 Disciplinary action taken by DAN will at all times conform to the Kuwait Labor Laws.
- 2.4 An employee has the right to be represented by a fellow employee at any stage of a disciplinary procedure.
- 2.5 In the first instance the purpose of disciplinary action is to correct behavior rather than to terminate services.
- 2.6 No incident or offence can be considered in isolation and the total impact of the offence in a disciplinary action shall be considered.
Procedure
- 3.1 Rules and standards in the workplace are so well established that it is not necessary to communicate them in this procedure.
- 3.2 Before a problem becomes a disciplinary issue, a supervisor may guide, inform or remind the employee informally on the applicable rule or performance situation. Such counseling is not viewed to form part of formal disciplinary action but is rather part of a day-to-day communication within the company. It is not obligatory on the part of the Supervisor to guide, inform or remind the employees at each time.
- 3.3 Formal procedures do not have to be invoked every time a rule is broken or standard is not met. Informal advice and correction is accepted as the best and most effective way for the company to deal with minor violations of work discipline
- 3.4 Repeated misconduct will warrant warnings, which themselves may be graded according to degree of severity. More serious' infringements or repeated misconduct may call for final warning or other action short of termination. Termination would be reserved for cases of serious misconduct or repeated offences.
- 3.5 The seriousness of the offence will determine the action to be taken and not necessarily, the number of occasions the Offenses was committed.

Step -1 : Verbal Warning
1. Step 1 will not apply in cases of serious misconduct.
2. This will normally be the first formal action instituted against an employee for failure to meet performance requirements, breach of the terms of employment of the company or other work rules.
These warnings will normally be given by the employee's immediate supervisor. Warnings of this nature must be given as soon as possible after the offence became known.

Step -2 : Written Warnings
1. These written warnings may be used when the verbal warning(s) fail(s) to produce the required results or where stronger action than a verbal warning is required.
2. The supervisor will record, in writing, the incident that gave rise to the issuing of such written warning.
3. A copy of the warning shall be handed to the employee for whom the employee shall be required to sign acknowledgement of receipt. If refusing to sign, a witness should sign in the presence of the accused, confirming that the warning was issued.
4. A copy of such warning will be included in the employee's personnel file
5. Written warnings should be issued as soon as possible after the incident came to management's attention.
6. Written warnings shall remain valid for a period of six (6) months.

Step -3 : Final written Warnings
1. This step may be used where previous verbal and written warnings had failed to produce required results and/or where stronger action than the above mentioned is required
2. The relevant supervisor will record in writing the incident which gave rise to the issuing of the final written warning.
3. A copy of the warning shall be handed to the employee for which the employee shall be required to sign acknowledgement of receipt.
4. A copy of such final warning will be included in the employee's personnel file.
5. Final Written Warnings should be issued as soon as possible after the incident came to management's attention.
6. Final Written Warnings shall remain valid for a period of six (6) months.

Step -4 : Termination
1. This step may be used where previous written warnings have failed to produce required results or stronger action than either First or final warnings are necessary due to the seriousness of the offence.
2. Following a pre investigation, the relevant supervisor will record in writing the incident, in the form of a notification to attend a disciplinary hearing.
3. The employee shall be issued with a copy of such notice and the hearing shall be set down in accordance to this procedure.
4. The employee is entitled to reasonable time to prepare for the hearing.
5. If possible, an impartial chairperson will be appointed; alternatively, the designated manager will act as chairperson of the said disciplinary hearing.
6. The employee will be afforded an opportunity to state his case in response to any allegation.
7. After having listened to the evidence presented by the supervisor or any other initiator, the chairperson will consider whether the employee is guilty or not of the charges.
8. In the event of the chairperson determining that the employee is guilty of the charges, the employee will be requested to offer mitigating circumstances prior to a decision with regard to the penalty being taken.
9. After considering all the evidence and documents placed before the hearing and after having given due consideration to any mitigation offered by the employee, the chairperson may decide to terminate the services of the employee, or any other appropriate action.
10. If the employee is terminated, the employee will be given the reasons for the termination in writing and will be reminded of any rights in terms of the Kuwait Labor Laws.

9. DISCIPLINARY PENALTIES

*S.No*	*Reason*	*Warning 1*	*Warning 2*	*Warning 3*	*Action*
1	Coming Late or leaving early without permission	Verbal warning	Warning Letter	Final warning Letter	Termination
2	Leaving the workplace during working hours without permission	Verbal warning	Warning Letter	Final warning Letter	Termination
3	Absent 1-2 Days continuously without permission	Verbal warning	Warning Letter	Final warning Letter	Termination
4	Absent 3-6 Days continuously without permission	Not Applicable	Not Applicable	Not Applicable	Termination
5	Absent 7 Days & more continuously without permission	Not Applicable	Not Applicable	Final warning Letter	Termination
6	Poor work Performance or Unacceptable behavior	Verbal warning	Warning Letter	Final warning Letter	Termination
7	Sleeping during work hour	Verbal warning	Warning Letter	Final warning Letter	Termination
8	Negligence/failure to wear protective clothing or equipment where supplied or where necessary	Not Applicable	Warning Letter	Final warning Letter	Termination
9	Smoking or inducing fire in a "non-smoking" or flammable gas area	Not Applicable	Warning Letter	Final warning Letter	Termination
10	Assault by word, deed or by Correspondence to a colleague at work	Not Applicable	Warning Letter	Final warning Letter	Termination
11	Assault by word, deed or by Correspondence to a superior or an employer	Not Applicable	Not Applicable	Final warning Letter	Termination
12	Engaging in activities for personal gain in conflict with the interest of the Company.	Not Applicable	Not Applicable	Final warning Letter	Termination
13	Misuse of authority by Superior/Manager	Not Applicable	Not Applicable	Final warning Letter	Termination
14	Failure/Refusal to perform work & instructions	Not Applicable	Not Applicable	Final warning Letter	Termination
15	Deliberately encouraging co-workers to refuse or to perform work & instructions	Not Applicable	Not Applicable	Final warning Letter	Not Applicable
16	Neglecting or Misusing company's asset or property	Not Applicable	Not Applicable	Final warning Letter	Termination
17	Racism in all different types	Not Applicable	Not Applicable	Not Applicable	Termination
18	Committing Indecent behavior (harassment, unruly behavior)	Not Applicable	Not Applicable	Not Applicable	Termination
19	Revealing or selling any work related information (including software) internally or externally to competitors / third parties	Not Applicable	Not Applicable	Not Applicable	Termination
20	Deliberate mistake or mistake jeopardizing the Safety instructions causing heavy losses for the company	Not Applicable	Not Applicable	Not Applicable	Termination
21	Providing False reports, information or documents to obtain a job or other privileges within the company	Not Applicable	Not Applicable	Not Applicable	Termination
22	Final judgment condemns the employee in Crimes involving honor and honesty	Not Applicable	Not Applicable	Not Applicable	Termination
23	Willful damage to Company property or property of other employees	Not Applicable	Not Applicable	Not Applicable	Termination
24	Being in possession of or under the influence of drugs/liquor.	Not Applicable	Not Applicable	Not Applicable	Termination
25	Possession of a dangerous weapon / materials without written permission or use of dangerous weapons in the workplace.	Not Applicable	Not Applicable	Not Applicable	Termination
26	Requesting or Accepting gifts (more than value KD 25/-) bribes, personal benefits or stealing company assets, money or material.	Not Applicable	Not Applicable	Not Applicable	Termination
27	Acting against the Laws of Kuwait	Not Applicable	Not Applicable	Not Applicable	Termination

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