Code of Ethics

QCTC code of ethics are as follows;

I. Purpose:
QCTC requires maintaining the highest ethical standards of the work performed. Therefore, this code of ethics is considered as an essential element of performance at Isam Kabbani & Partners Company. Compliance with the requirements of this code is deemed an employment precondition, as the Company 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 to perform their tasks and achieve 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 QCTC’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, and technicians. 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:
- Violation of the Code of Ethics.
- Inciting others to violate Code of Ethics.
- Negligence to submit complaints regarding confirmed or potential violation to Code of Ethics.
- Refusal to take part in investigating complaints 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:
- Employee should act with honesty, integrity and fair dealing with others and must not make any inaccurate or misleading claims about any matters related to activities of QCTC, which may lead to conflict of interests.
- The employee is required to characterize with values of equality, forgiveness and respect to all values, customs and behaviors of colleagues.
- QCTC 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 Company or reflects negatively upon employees’ performance. - The employee of QCTC must 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 Company

2. Principle of Equal Employment Opportunities:
Equal Employment Opportunity policy of QCTC affirms the right of every employee to participate in all aspects of employment regardless to race, color, religion, nationality, sex, age, marital status, national origin or disability (provided it is not affecting performance). The Company 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,

2.1 Complying with systems & regulations:
Employees should comply with systems and regulations applied at QCTC, including this system, especially those relate to discipline, security, protection and policies and procedures of human resources applied in the Company.
Employees are expected to fully perform their works, tasks and responsibilities in a manner that does not contradict with the interests of QCTC.

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 create 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 for all programs and commitment-related issues.
- Leadership should be an example for employees through its ethics and behaviors.
- Employees should realize that obtaining results is not more important than complying with the Code of Professional Ethics.
- Encouraging employees to ask any questions related to honesty or to raise a complaint.

B. To prevent problems of breaching Code of Professional Ethics:
- To ensure identifying problems of breaching Code of Professional Ethics that may affect performance.
- It is essential to ensure communicating policies and procedures related to solving problems of breaching Code of Professional Ethics.

C. To disclose problems of breaching Code of Professional Ethics through:
- Providing efficient system that encourages employees to raise complaints without fear from any reaction.

D. To respond to problems of breaching Code of Professional Ethics as follows:
- Instant remedial response to solve problems breaching Code of Professional Ethics.
- Taking the necessary disciplinary action.

4. Responsibilities of Employees:
4.1 Complying with systems & regulations:
Employees should comply with systems and regulations applied at QCTC, including this system, especially those relate to discipline, security, protection and policies and procedures of human resources applied in the Company.
Employees are expected to fully perform their works, tasks and responsibilities in a manner that does not contradict with the interests of QCTC.

4.2 Complying with the Code of Professional Ethics:
Upon joining the Company team, employees shall comply with the following:
- To read the Code of Professional Ethics and make sure that they fully comprehend all points.
- To make sure that Code of Professional Ethics is applied for all subordinates.
- To comply with all policies related Code of Professional Ethics.
- Not to hide any information related to breaching Code of Professional Ethics by other employees.
- To sign the message of adhering to Code of Professional Ethics by the employee and to 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 QCTC, 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 QCTC.

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 QCTC, except in designated areas.

5.6 Behaviors with colleagues:
Employees should encourage their colleagues to comply with the requirements and policies of the Code of Professional Ethics.
- Employee must be characterized with justice and support to all their colleagues.
- Employee must attribute any achievement to the employee who made such an achievement and not to attribute it to himself.
- Employee should support his colleague for professional progress.
- Upon examining accuracy of other employee’s work, this should be done in a logical way.
- Employee should not unnecessarily interfere in the work of others.
- Employee shall not discriminate between employees or annoy any employee, job applicant, customer or visitor.
- Employee is not permitted to refuse working or cooperating with any other employee due to racial or religious 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 QCTC 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:
QCTC 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. QCTC Properties:
- Employees are deemed responsible for the properties of QCTC under their responsibilities such as keys, employee’s identification card and any other devices or equipment given to employees while performing their duties and responsibilities. Computers, fax and photocopy machines are not restricted to personal usage.
It is prohibited to sell or exploit any goods or services owned by QCTC for personal benefit unless agreed by the Group's management.

9. Conflict of Interests
Employees of QCTC 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 company interests.

Conflict of interest may arise in any of the following forms:
- The employee should not to have any direct or indirect financial benefit from any supplier or client of the Company.
- The employee should not gain any discounts or personal benefits not granted to other employees.
- The employee should not be engaged in any outside work, either directly or indirectly, where he may compete or jeopardize the Company’s interests and his responsibility and duties.
- The employee should not be engaged in any part time job during the regular working hours of the Company.
- The employee should not practice any personal works or take advantage of Isam Kabbani & Partners Company properties for personal purposes.
- The employee should not exploit his position in the Company to gain any privileges or personal advantages.
- The employee should 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 QCTC 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 Company’s relationships and trading transactions with suppliers and brokers and any other parties.

10.2 Documents Secrecy
- The employee should not make copies of business letters, documents, files or any other documents related to the business and activities of QCTC.
- The employee should submit all documents related to the Company’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 QCTC'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. QCTC 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 QCTC.

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

12.2 Requirements:
- QCTC should follow approved purchasing systems when buying services and goods for the Company.
- QCTC should undertake maximum precautions to guarantee that the supplier is supplying his goods according to highest quality and at ideal cost and delivery conditions.
- QCTC should deal with the supplier who observes legal and local requirements and any other standards related to labors, environment, health and Security.

QCTC procurement employees should 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 should be documented either by contracts or by invoices. - It is prohibited to falsify financial data or input false and misleading data. Any funds should not be maintained without registering it in the approved financial records. - Employees of QCTC should 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 should be provided related to fees, obligations and personal financial compensations. - The following actions will require stringent punishments: - Purchasing materials unnecessary for operations of QCTC. - 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:
- QCTC makes the Internet available for its employees to enhance efficiency and effectiveness. However, although this tool aims at assisting employee to complete their duties, they may misuse it.
- The Company has the right to monitor the Internet and email 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 Company, and not for personal interest.
- Computer services of the Company should not be used in a way that violates systems and regulations applied in any country.
- Upon using the Internet, the employee should identify himself and his company when sending email message, and should not send spam messages.
- It is prohibited to distribute and store any kind of improper or offensive images in the premises of QCTC. Such a behavior is deemed a violation to the sexual harassment policy.

14.2 Internet Security:
QCTC 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:
QCTC is dedicated to secure and apply sound environmental, health and safety conditions. This obligation is applicable to all employees.
QCTC is working hard to provide healthy work environment and to prevent work injuries or damages to the environment and society.
QCTC 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:
QCTC should alleviate harmful environment emissions, reduce usage of harmful materials and minimize risks upon providing various services.
QCTC should maintain a safe and harm-free work environment.
QCTC should pay attention to local and international environmental regulations.
QCTC should 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.

16. Rights of Intellectual Property
- Among policies of QCTC is to maintain and protect rights of intellectual property. Employees are required to protect rights of intellectual property of the Company (Trade secrets and copyrights)
- QCTC should protect intellectual property of other companies.
- QCTC should not accept any information from any employee about his previous employer.

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Bilal Yamak

General Manager, QCTC