Code of Conduct

To meet social responsibilities, Gulf Engineering Services Limited aims to conduct business in an ethical manner and to act with integrity. Ethical requirements include the following aspects:

1.1       Business Integrity and conduct

Gulf Engineering Services Limited has zero-tolerance for bribery and corrupt activities and expects that our employees, suppliers or customers will not offer or accept bribes or other unlawful incentives or offer to Gulf Engineering Services Limited employees’ gifts or any other kind of personal benefit.

 1.2       Fair Competition

It is expected that our stakeholders shall conduct their business in line with fair competition and in accordance with all applicable laws.

 1.3       Confidentiality, Privacy & Intellectual Property

Gulf Engineering Services Limited provides products that are under licensed agreements. It is the duty of Gulf Engineering Services Limited to safeguard and make only appropriate use of confidential information and ensure that all employees’ and business partners’ privacy and valid intellectual property rights are protected.

 1.4       Identification of Concerns – ‘whistleblowing’

It is necessary that Gulf Engineering Services Limited provides a means for their employees to report concerns or potentially unlawful activities in the workplace. Any report should be treated in a confidential manner. Gulf Engineering Services Limited shall investigate such reports and take corrective action if needed.

 1.5       Statutory and Regulatory

Gulf Engineering Services Limited is expected to conduct business and operations in accordance with the international guidelines, the current national and local laws and regulations and the strictest business conduct and ethical principles. Gulf Engineering Services Limited prohibits unlawful wage deductions or payments by worker in return for employment, transportation, accommodation, food and other living costs and prohibits the withholding of both money or identification documents belonging to workers by the company.

 1.6       Conflict Minerals

Gulf Engineering Services Limited will, to the best of our capability avoids the use of supplies containing metals derived from minerals or their derivatives originated from conflict regions that directly or indirectly finance or benefit armed groups.

Gulf Engineering Services Limited expects that all stakeholders will protect the human rights of employees and treat them with dignity and respect. This includes the following aspects:

2.1       Non-acceptance of Child Labour

Gulf Engineering Services Limited does not tolerate child labour in our supply chain. Stakeholders shall avoid any sort of child labour in their business operations.

2.2       Forced Employment

Gulf Engineering Services Limited does not tolerate slavery, servitude and forced or compulsory labour and human trafficking in our supply chain. Bonded, indentured or involuntary prison labour is not accepted as well.

 2.3       Diversity, Inclusion and non-discrimination

Gulf Engineering Services Limited promotes equal treatment of all employees and expects this to be a fundamental principle of the supplier’s corporate policy. Gulf Engineering Services Limited will ensure that their employees are not harassed or ‘bullied’ in any way. Gulf Engineering Services Limited encourages suppliers to provide an inclusive and supportive working environment and to exercise diversity when it comes to their employees as well as in their decisions to select subcontractors.

2.4       Fair Treatment

Gulf Engineering Services Limited shall provide their employees with a workplace free of harsh and inhumane treatment, sexual harassment, sexual abuse, corporal punishment or torture, mental or physical coercion or verbal abuse of employees, or the threat of any such treatment.

2.5       Working Hours, Wages and Benefits

Working hours for employees will not exceed the maximum set by the applicable national law. Compensation paid to employees shall comply with applicable national wage laws and ensure an adequate standard of living. Suppliers are expected to provide their employees with fair and competitive compensation and benefits. Compensation and benefits should aim at providing an adequate standard of living for employees and their families. Employees shall be paid in a timely manner. It is recommended that employees are offered ample training and educational opportunities.

2.6       Freedom of Association

Gulf Engineering Services Limited is committed to an open and constructive dialogue with their employees and workers’ representatives. In accordance with local laws, the rights of employees to associate freely, join labour unions, seek representation, join works councils and engage in collective bargaining will be respected. Employees who act as workers’ representatives will not be discriminated against.

Gulf Engineering Services Limited expects strives to provide a safe and healthy working environment and, if applicable, safe and healthy company living quarters, and to operate in an environmentally responsible and efficient manner. Gulf Engineering Services Limited should integrate quality into their business processes. This comprises the following aspects:

3.1       Health, Safety, Environmental and Quality Requirements and Regulations

Gulf Engineering Services Limited should meet and comply with all applicable quality, health, safety and environmental regulations and the generally recognized or contractually agreed quality requirements in order to provide goods and services that consistently meet Gulf Engineering Services Limited’s needs, perform as warranted and are safe for their intended use. Gulf Engineering Services Limited expects all suppliers to maintain the required permits, licenses and registrations that are required to fulfil their operations and the required reporting obligations.

 3.2       Product Safety

Gulf Engineering Services Limited expects all suppliers to provide the necessary Safety data sheets (SDS) containing all necessary safety-relevant information for all hazardous substances prior to delivery of products.

 3.3       Occupational Health and Process Safety

In keeping with good practices, Gulf Engineering Services Limited strives to always protect their employees from any chemical, biological and physical hazards and physically demanding tasks in the workplace as well as from risks associated with any infrastructures used by their employees and expects all suppliers to follow this initiative.  A safe and healthy working environment also includes as a minimum potable drinking water, adequate lighting, temperature, ventilation and sanitation and, if applicable, safe and healthy company living quarters. The workplace shall be managed according to appropriate controls, safe work procedures, preventative maintenance and necessary technical protective measures to mitigate health and safety risks in the workplace. In hazardous conditions employees will be provided with the necessary safety information relating to hazardous materials via education and training and be provided with appropriate personal protective equipment where engineering controls may not be sufficient. In production related environments, safety programs will be in place for managing and maintaining all production processes in accordance with the applicable safety standards.

 3.4       Emergency Preparedness, Risk Information and Training

Gulf Engineering Services Limited recognises good safety practices one of which is the management of emergency preparedness, risk information and training of individuals to identify workplace risks, assess likely and potential emergency situations in the workplace and minimize their impact by implementing emergency plans and response procedures.

 3.5       Waste and Emissions

Gulf Engineering Services Limited shall have systems in place to prevent or mitigate accidental spills and releases into the environment by having adequate systems in place to ensure the safe handling, movement, storage, recycling, reuse and management of waste, air emissions and wastewater discharges. Any of these activities that have the potential to adversely impact human or environmental health will be appropriately managed, measured, controlled and handled prior to release of any substance into the environment.

3.6       Resource Conservation and Climate Protection

Gulf Engineering Services Limited is expected to use natural resources (e.g. water, sources of energy, raw materials) in an economical way. Stakeholders should engage in the development and use of climate-friendly products and processes to reduce power consumption and greenhouse gas emissions.

 3.7       Security

Gulf Engineering Services Limited shall have good security practices for business processes. In addition, the necessary and appropriate measures will be to ensure that the products, their workable components or raw materials as well as the corresponding proprietary intellectual information do not end up in the hands of counterfeiters or third parties and do not leave the legal supply chain.

Gulf Engineering Services Limited implements management systems to facilitate compliance with the applicable laws and to promote continuous improvement with respect to the expectations set forth in this Code of Conduct. This includes the following aspects:

 4.1       Legal and Other Requirements

Gulf Engineering Services Limited shall comply with all applicable laws, regulations, contractual agreements and generally recognized standards.

4.2       Communication

Gulf Engineering Services Limited should communicate the principles set forth in this Code of Conduct.

 4.3       Commitment and Accountability

Gulf Engineering Services Limited are encouraged to fulfill the expectations set forth in this Code of Conduct by allocating appropriate resources.

4.4       Risk Management

Gulf Engineering Services Limited are expected to implement mechanisms to identify, determine and manage risks in all areas addressed by this Code of Conduct and with respect to all applicable legal requirements.

4.5       Documentation

Adequate documentation demonstrates that Gulf Engineering Services Limited shares the principles and values expressed in this Code of Conduct.

This documentation may be reviewed by Gulf Engineering Services Limited .

4.6       Training and Competency

Gulf Engineering Services Limited should establish appropriate training measures to allow their managers and employees to gain an appropriate level of knowledge and understanding of the contents of this Code of Conduct, the applicable laws and regulations and generally recognized standards.

4.7       Continuous Improvement

Gulf Engineering Services Limited is expected to continuously improve their performance by implementing appropriate measures.