Compliance & Ethics

CEO's Message

At the AlJammaz Technologies (“AlJammaz”) we are committed to operating a compliant and ethical business, working at all times with honesty and integrity. We expect the highest standards of integrity and professionalism from all of our staff and from any business partner and other persons that act on our behalf.

There is no place for illegal or unethical behaviour of any kind in our business and we take a 'zero-tolerance' approach to the breach of anti-bribery, anti-money laundering and sanctions laws. We expect you and all of our business partners to understand and operate to this standard at all times and in all places. Failure to do this can lead to criminal liability for you and Al Jammaz and also damage our relationship with vendors and business partners.

I encourage you to come forward to report breaches of this Code, whether it is your own breach or you discover or suspect another person has breached. We value transparency and integrity and reporting breaches and other misconduct is an important foundation of those values.

We do this not just because it is right but because it makes a positive impact on the communities in which we work and the people we deal with. We recognise that, corruption is a bad influence, distorting markets and making the societies it affects poorer.

I hope and expect that this Code and the principles described within it always guide your decisions and actions when acting for or on behalf of Al Jammaz.

This Code sets out the Al Jammaz way of conducting business. It provides not just a basic understanding of our regulatory and ethical obligations but sets out what it means to work for and be part of Al Jammaz. It sets out how we expect our staff and business partners to conduct business and behave at all times. You can think of it as a roadmap for how to work for and with Al Jammaz.

Behaving ethically, honestly and in compliance with applicable legal obligations is a fundamental part of our business. It is who we are and underlies everything we do.

To comply with this Code you need to understand your regulatory and ethical obligations wherever you are based, particularly regarding anti-bribery and international financial sanctions laws. We have summarised these below.

This Code applies to all of us : every director, employee, agent and consultant who works for Al Jammaz. It also applies to anyone we do business with, as we recognise that our business partners are every bit as important to our reputation and achieving our aims and goals as our own people.

• Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

• A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.

• An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.

• Corruption is the abuse of entrusted power or position for private gain.

It is not acceptable for you (or someone on your behalf) to :

• Give or accept a gift or hospitality during any commercial negotiations or tender process. In all circumstances, you must avoid lavish or extravagant gifts or hospitality.

• Make facilitation payments to influence someone to do what they should already be doing, even if the payment is small or common to make in that country.

• Pay in cash.

• Pay unless the recipient has signed a formal contract with Al Jammaz, or provides us with an invoice or receipt.

• Threaten Al Jammaz's staff or business partners because they refuse to commit a bribery offence or because they raise concerns about a potential instance of bribery.

• Offer gifts or hospitality if you are aware that it would put the recipient in breach of their own policies or procedures to accept it.

• Permit or facilitate the payment of bribes to customs and port officials. Turning a blind eye is the same as engaging in bribery in many places.

• You must ensure that you read, understand and comply with this policy.

• The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

It is the responsibility of our business partner to comply with the export control regulations enacted by U.S., or any local government law.

You may not, without an appropriate license or individual permission export or re-export AlJammaz Technologies Ltd. products to destinations that are put under an embargo by the local or the U.S. government and to any terrorists- supporting countries identified as Cuba, Iran, North Korea, and Syria.

We need to keep financial records and have appropriate internal controls in place to evidence the business reason for making payments to third parties. This not only complies with our legal obligations under US law but also enables us to defend any suggestion that our staff have behaved inappropriately.

You should declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review. You also need to submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

All accounts, invoices and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" as these could be used to facilitate or conceal improper payments.

It is your right as well as your obligation to raise concerns about any issue or suspicion of bribery and/or any issue or suspicion concerning a breach of sanctions at the earliest possible stage. Ignoring such issues or deliberately concealing them is taken very seriously and is likely to result in your dismissal or the termination of your contract.

If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery or other breach of this policy has occurred or may occur, you must email our Compliance email address compliance@aljammaz.com

If you are unsure about whether a particular act constitutes bribery or whether there could be an actual or potential breach of sanctions, raise it by sending an email to compliance@aljammaz.com.

Anyone who refuses to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We encourage openness and will support anyone who raises genuine concerns in good faith under this Code, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery, or because of reporting in good faith their suspicion that an actual or potential bribery offence has taken place, or may take place in the future. We are also committed to ensuring no one suffers any detrimental treatment as a result of raising good faith concerns regarding potential or actual breaches of sanctions.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should send an email to compliance@aljammaz.com.

There are numerous anti-bribery laws applicable to our different offices, operations and staff members. These often apply globally depending on the place of incorporation or operation of our businesses and the nationality of our staff. Most of these laws are based on the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

Our approach to anti-bribery is driven largely by the US Foreign Corrupt Practices Act 1974 (the “FCPA”) and the UK's Bribery Act 2010 (the “UKBA”), and guidance. We also ensure compliance with the Saudi criminal law.

For information on these laws, see:

• http://www.oecd.org/corruption/oecdantibriberyconvention.htm;

• https://www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance.pdf;
• https://www.documentcloud.org/documents/515229-a-resource-guide-to-the-u-s-foreign-corrupt.html.

For more information or for detail Code of business conduct and ethics ABC policy please contact us at compliance@aljammaz.com.