Introduction

The Code consist of 5 important sections :

  1. Awareness
  2. Protection
  3. Accountability
  4. Dealing Fairly
  5. Community

Please take your time and read through them all, the policies and rules are key to working effectively and professionally in NBK

1. AWARENESS

1.1 Why we need The NBK Code of Conduct?

The Code of Conduct is one of the ways NBK puts our values into practice. It is centered around the understanding that we are all accountable to ensure all work-related activities, practices, behaviors, and decision making is measured against the highest possible ethical standards; in doing so builds trust and confidence among stakeholders and ensures customer loyalty and mutual prosperity.

Integrity, professionalism, and loyalty to NBK are the core principles within the Code of Conduct. Our reputable standing in the local community and with our international stakeholders is a key pillar in the legacy of NBK and underpins the trust afforded to the business by our customers. It is vitally important that every person takes individual responsibility to ensure we consistently act with integrity and the highest ethical standards possible.

1.2 Who must follow The NBK Code of Conduct?

The Code of Conduct applies to Everyone, inclusive of the Board, staff, related parties, and independent third parties appointed by NBK. All NBK employees are required to read, understand, and comply with the Code of Conduct.

1.3 What are the consequences of breaching this Code of Conduct?

NBK expects all employees to comply with the relevant policies and regulations that govern (but are not limited to) attendance, professional competence, cooperation, respect, and teamwork. NBK takes its commitment to this Code of Conduct very seriously. It must be noted and understood by everyone that failure to comply with The NBK Code of Conduct may result in disciplinary action up to and including dismissal. In addition, any violation of the Law can also result in personal liability for the individual responsible.

Disciplinary action may also be taken against those where lack of supervision, diligence, or awareness of the provisions within the Code of Conduct directly or indirectly contributed to a violation.

1.4 If I have a Code of Conduct concern

For information, and guidance about the Code of Conduct, business ethics or general information about expectations captured within the Code of Conduct, advice is available from ethics@nbks.com Disciplinary action may also be taken against those where lack of supervision, diligence, or awareness of the provisions within the Code of Conduct directly or indirectly contributed to a violation.

To report a concern regarding business ethics and compliance write to ethics@nbks.com. Ideally, you are encouraged to provide your name and contact information with a view to ensuring that the matter can be reviewed in depth, through discussion, with all information readily available. However, should you wish to remain anonymous, you can also write to the ethics@nbks.com without identifying yourself.

1.5 Whistleblowing

NBK is committed to achieving and maintaining the highest standards of openness, probity, and accountability. Employees at all levels are expected to conduct themselves with integrity, professionalism, impartiality, and honesty. It is everyone’s responsibility to ensure that any inappropriate behavior that compromise the interest of shareholders, customers and other stakeholders does not occur. “Whistleblowing” refers to a situation where an employee decides to report serious concerns about any suspected misconduct, malpractice, or irregularity which has come to their attention. Employees are encouraged to raise these serious concerns internally, in a responsible and effective manner, rather than overlooking a problem. All such concerns can be sent to ethics@nbks.com.

1.6 No Retaliation

NBK prohibits retaliations against any person or entity who reports or participates in an investigation of a possible violation of the Code of Conduct, policies and/or the law.

1.7 No False Accusations

NBK encourages honest reporting of all ethical concerns. False accusations, however, divert attention from credible complaints and damage morale. Knowingly reporting false information is against the very essence of the Code of Conduct and malicious reports are subject to the Disciplinary policy.

2. PROTECTION

2.1 Maintain Confidential Information

You are expected to maintain the confidentiality of all business information entrusted to you by the Company. Examples of confidential information include contact details of customers and suppliers, contractual details (commercial or legal terms), personnel information, business plans, P&Ps, marketing strategies, sales reports and/or any document marked confidential (or similar). This list is illustrative but not exhaustive.

You are expected to carefully consider the sensitive nature of company related information, specifically where this might be of use to competitors or may constitute information harmful to the Company, customers and/or associated stakeholders if disclosed. You shall not divulge any company information even after the end of service, without prior written approval from the CEO.

2.2 Privacy Law Breaches

You must never use your position in the Company to make any unauthorized intrusion into the privacy of another employee or associated stakeholder.

2.3 Intellectual Property (IP)

Intellectual property (IP) refers to intangible legal rights that give the IP owner certain exclusive rights with respect to IP. IP rights can include confidential information, original written works and technology and business processes. Any intellectual property that is created during your employment with NBK belongs to the Company, and the salary received during such employment shall be deemed to be fair reimbursement for any such IP you create.

2.4 Safeguarding Assets & Recording Transactions Accurately

Information is essential to the Company’s ability to meet legal and regulatory obligations and to compete effectively. It is essential that the Company and associated parties, manage records and recorded information consistently and effectively. As a rule, you must:

  • Use good judgement and common sense when preparing any financial or other business record.
  • Ensure that the financial or their business information is accurate, complete, honest,objective, and timely.
  • Not knowingly make a false misleading or unsupported financial or business entry.
  • Only sign off accurate and complete records
  • Not knowingly suppress relevant information in a business record
  • Disclose financial or business records only as authorized by the Company or as mandated under law in response to a legal process
  • Follow the laws, external accounting requirements and the groups policies and procedures for reporting retaining storing and disposing and other business records.

2.5 Respectful Workplace

NBK enjoys a diverse workforce from 30+ countries and recognizes that those specifically recruited for their industry expertise and/or technical skills set, also bring diverse cultural norms. Diversity of this nature can generate creativity and insights that may benefit decision making and problem solving.

In the interest of clarity regarding acceptable style of leadership and/or how peers or colleagues are interacted with, there is a clear expectation that dignity & respect is an absolute prerequisite in terms of professional behavior afforded to all at NBK.

NBK considers all harassment and violence as a breach of the Code of Conduct. Harassment in the workplace is unacceptable and will not be tolerated. Subject to an investigation could result in disciplinary action, up to and including dismissal.

Typical harassment and bullying behaviors range from unwelcome remarks and persistent unwarranted criticism to unwanted physical contact and shouting. Recipients of these inappropriate behaviors may experience issues that result in diminished productivity and performance, impacting them, the business and the services provided to our customers.

Everyone is expected to conduct themselves in a professional manner in and outside of business hours, either in person and/or in written communications. The attitude, clothing, anecdotal comments, humor, and other aspects of the presentation especially in the written correspondences, shall adhere to the highest social standards. Sexist, racist or otherwise degrading comments will not be tolerated and are grounds for disciplinary action up to and including termination.

Should you witness or become aware others being harassed, mistreated, or inappropriately addressed, you must in the best interest of the business, brand and employees are required to report this matter to hr@nbks.com as it constitutes a violation of acceptable behavior and the Code of Conduct.

2.6 Equal Opportunities

Employment is based solely upon merit and qualifications directly related to the professional competence of the candidates. The recruitment policy should be referred to for further guidance on the recruitment process which is designed to ensure open competition internally and externally for available opportunities. Unlawful discrimination or failure to follow internal recruitment policy will be considered a violation of the Code of Conduct.

2.7 Nepotism

All relationships are expected to be declared when applying as part of the standard Recruitment process. Existing employees are not permitted to advocate for family members/relatives and in all cases, where this occurs the application will be disqualified from the recruitment process. No direct referrals in person will be accepted by HR and/or any other member of the Company. All applications must be received via the E-recruitment portal or directly from the applicant to jobs@nbks.com once the position has been opened.

As noted in our equal opportunity statement above. Recruitment and selection decisions are based on merit and suitability to the role. The process is fair and transparent. Family, marriage, or partnership relations must be declared and shall not be given preferential treatment, nor will they be obstructed from employment within NBK provided they apply through the appropriate channels.

Selection decisions for new staff, promotion or any other change in role decisions if already employed by the Company will depend purely on merit and suitability. Hiring or the promotion of a relative is permissible only when the application has been received independently of the family member as outlined above, the selection team/panel is impartial and the decision makers have no personal conflict of interest, the planned appointment and the organizational structure shall not be comprised by a
direct supervisory or management reporting line of one relative to another.

Think About This! Prevent Money Laundering

1-Process a transaction outside the normal process.

2-Exchange many small-denomination bills for a large one.

3-Make payments in cash

These are red flags that signal you may need to ask more questions to better understand the transaction. If it sounds suspicious, ask the question. You can find help at ethics@nbks.com>

2.8 Dress Code

The dress code for all employees is in accordance with their work environment. For example, those provided with a uniform are required to wear it, typically in the interest of health & safety and/or professional branding.

Those in an office-based environment are required to be dressed professionally and appropriately depending on the needs of the role.

In all cases work attire must be respectful to local customs.

3. ACCOUNTABILITY

3.1 Conflict of Interest

A conflict of interest occurs if a situation arises where your personal affairs or private interests interfere or appear to interfere with the business interests of NBK.

You are free to make personal investments, engage in community, charitable and professional organizations, provided there is no actual or perceived conflict of interest. In all cases of affiliations you are required to report in advance in writing these arrangements to both your Line Manager and hr@nbks.com.

Where relationships are with a customer, supplier, or competitor you are required to have written permission in advance from the CEO to engage in such activities. You must not have any financial interest, either investment or debt with a supplier if you are involved in any aspect of our relationship with them, either directly or indirectly through hierarchical reporting lines.

An unaddressed conflict of interest may infringe ethical trading standards, be unlawful and potentially damage our brand and reputation. Therefore, non-declaration of such a conflict or perceived conflict will constitute a breach of the Code of Conduct.

3.2 Non-Competition & Outside Interests

As an employee of NBK you are expected to ensure that your pursuits and efforts are always in the best interest of the Company. On that basis, you are required to consistently devote your full attention and best endeavors to the proper discharge of your duties and at no time (unless with prior written consent from the CEO) carry on in any other business or activity in competition with NBK or affiliated entities.

You must undertake not to receive any discount, rebate, commission, or other inducement in respect of an sale or purchase of goods/services either directly or indirectly on behalf of the Company.

Everyone is expected to perform job-related duties assigned, faithfully and diligently; obeying all reasonable instructions from the Board and/or the CEO; while complying with all statutory, regulatory, constitutional obligations, and adhering to relevant internal policies, rules, and procedures.

You must commit to taking every available opportunity to ensure that you positively promote the best interests of the Company and at no time do anything that may bring the Company into disrepute or harm the Company in any way

3.3 Gifts & Hospitality

The region is world renowned for its hospitality, generosity and charitable nature in both family and business circles. Therefore, it is imperative to have a clear understanding of where lines should be drawn when exposed to the offer of gifts, meals and entertainment in the professional capacity.

We value our relationships with our customers, supplies and other business associates and partners. These relationships require consistent, positive and ethical nurturing. Influencing business decisions with the expectation that something will be received by you as a result is unacceptable and is a serious violation of the expected Code of Conduct.

Normal business etiquette in Qatar would afford business partners to exchange gifts and entertainment from time to time. However, these must be declared in advance and clear consideration of the gift or entertainment should be given in terms of value/excess and frequency. Excessive gifts of significant value or frequent repetitive gifts can impose an actual or perceived obligation on the receiver or giver.

In accordance with Company Policy, employees may be authorized in advance to extend entertainment, gifts, or favors to business associates under the following conditions:

  • Prior approval is received from the CEO
  • They are legal
  • They are not offered for a specific action required by either party
  • They follow the accepted ethical standards of the Country in which the business is conducted
  • The value is modest and cannot be construed as illegal or improper (value may be
    determined differently from one company to the next (when seeking CEO approval, the value
    appropriateness can be clarified as required)
  • Public disclosure would not damage or embarrass the Company

3.4 Transparency of Relationships

It is considered unacceptable to engage in improper business practices or to give the impression of engaging in unethical practices.

NBK seeks its competitive edge from consistently delivering on its business commitments through superior relationship management across our stakeholder network. Suppliers, customers, and communities alike are to be treated with honesty and respect and responded to in a timely manner. All efforts must be made to protect our business relationships and our reputation through transparent ethical business practices. Should you require further clarity you can seek advice from ethics@nbks.com.

3.5 Use of NBK’S Resources

NBK’s assets should be used for the benefit of the Company in the conduct of its business. You are required to safeguard and use of company property and resources. Assets include, but not limited to, company funds, information resources, such as company hardware, software, and data. Financial and operational records, internet access, email and telephone services.

Not everyone has the right to make purchases on behalf NBK. Only those as defined in the Charter of Authority (COA) can do so. Subject to the necessary authority mandate you are required to behave responsibly when accessing NBK resources and/or funds. The spend must be justified and in the best interest of the Company. In accordance with the relevant Finance policies and procedures, proper records and timely reconciliations must be made when spend occurs using NBK’s resources.
For further guidance on the authority afforded to you in your specific role please seek advice from hr@nbks.com.

3.6 Cyber Security

You must comply with telecommunications laws and regulations and Company policy related to cyber security and shall not participate in any activities that disturb, interfere with, damage, and access to (without authority) products and services of any terminal equipment, server, network, or any third party (including Users, social media, and any mobile network operator).

3.7 Social Media

Refrain from using social media during business hours or on equipment NBK provides unless it is work related and authorized by Management. Do not use your NBK’s email addresses to register on social networks, blogs or other online tools utilized for personal use.

Maintain the confidentiality of NBK company information. Do not post internal reports, policies, procedures, or other internal business-related confidential communications.

As an ambassador for NBK you are required to refrain from posting about controversial subjects, such as politics, religion, and other potentially divisive topics. Post only appropriate and respectful content; do not post anything that may be construed as offensive or would potentially bring the company into
disrepute.

3.8 Media contacts

Only authorized personnel are permitted to speak to the Media on behalf of the Company. Employees and/or all other stakeholders should not speak to the media on NBK’s behalf without prior written approval from the CEO. All media inquiries should be directed to corporatecommunications@nbks.com.

4. FAIR DEALINGS

4.1 The Law

NBK takes its responsibility to comply with the law very seriously. You are required to be aware of the legal frameworks and regulations that impact your role and responsibilities.

Ignorance of the Law or Company policies does not excuse you from the obligation to comply with the law or this Code of Conduct. In the case of question or doubt, you are expected to consult with the Legal department at legal@nbks.com.

4.2 Competing Fairly & Anti-Trust

NBK expects that representatives of the Company will always adhere to the laws and principles of fair competition. In general, fair competition laws are designed to prohibit agreements or actions that reduce competition and harm consumers. No one is permitted to enter into an agreement or discussion with competitors that have the effect of fixing or controlling prices, dividing and allocating market territories or boycotting supplies or customers.

Antitrust laws prohibit agreements and concerted practices between companies that are set out with the aim of restricting competition. NBK embrace a healthy competitive environment and do not accept anyone operating on their behalf to engage in prohibitive agreements or practices that detract from this.

4.3 Bribery & Corruption

Bribery is defined as giving or receiving unearned reward to influence behavior or decision-making. Sometimes referred to as a kickback. For the purposes of our Code of Conduct, NBK makes no distinction between these, they are equally unacceptable and illegal. Other forms of corruption include abuse of power, extortion, fraud, deception, collusion, embezzlement, and money laundering.

The Company will not compensate any person or entity, approve, or condone the imbursement of irregular payments, financially or in-kind to win business. If you are approached regarding a bribery, extortion, or any other type of corrupt behavior you must contact your General Manager immediately to report the incident to ethics@nbks.com. All steps will be taken to fully support you through this event. Equally so, if you sense imminent threat to your liberty and/or safety, you are not given time to respond or report the matter, payment is permitted. This must be followed immediately by a full report outlining the incident details and identifying those involved and your support will be required to file a criminal report.

4.4 Legitimate Payments

In some legitimate cases, valid and authenticated fast tracking processes do apply. In all such cases, whether it be government or private entity related, the payment/transaction should be recorded, with a detailed account of the rationale for the payment, date, and expressed/written approval from the appropriate Manager in accordance with the Charter of Authority. Also, where necessary a reconciliation of all payments must be processed in accordance with the internal Finance policy and procedures.

5. COMMUNITY

5.1 Human Rights

Respect for Human Rights is of utmost importance to NBK. Human Rights are the basic rights and freedoms that belong to us all. Our internal actions and practices must be aligned with the permanent constitution of the State of Qatar, applicable Qatari Law and Human Rights regulations.

5.2 Wellbeing & Safety

Protect your health and safety at work and that of co-workers and the public by following the NBK Health & Safety policy.
Show you care by highlighting health and safety concerns to hr@nbks.com.

5.3 Substance Abuse

The possession, consumption and/or distribution of alcohol or drugs at work is incompatible with the health & safety of our organization and those employed, it contravenes our business philosophy and breaches the law of the Country. The use of illegal drugs is a criminal offence in the State of Qatar and the consumption of Alcohol is tightly regulated by Qatar Customs authorities.

If you have reasonable suspicion that a colleague may be under the influence of drugs or alcohol while at work or they are in breach of the above Code in anyway, for their safety and that of colleagues and members of the public you are required to report your concern to your Line Manager and hr@nbks.com immediately.

5.4 Smoking

We care about you and those around you therefore, NBK is a Non-Smoking company, smoking in the workplace is a violation of the Code of Conduct. Smoking is extremely hazardous to your health and wellbeing and in addition, it poses a fire risk to our staff and premises. Smoking is only permitted in designated smoking areas outside of our buildings and away from customer and visitor areas.

5.5 Environmental Sustainability

You must use resources responsibly and lead by example to do your part to ensure where possible, you do no harm by controlling waste and energy that is within your remit. You are expected to actively participate in NBK’s sustainability agenda by recycling and replenishment efforts. Further advice is available regarding possible sustainability opportunities from hr@nbks.com.

5.6 Community Development

Community development is important to NBK; the Company has a long history of proudly investing in our local communities, we are committed to supporting charitable causes and are dedicated to sponsoring events that are important to the community and the Country. As ambassadors for NBK, living in the communities we serve, you are also encouraged to participate in activities and events that enrich the lives of your family and those around you.

The information and terms outlined in this document are subject to change, including amending, adding, or removing items from time to time. All changes will be communicated to you either when changed or on an annualized basis to ensure that you are completely familiar and understand the expectation outlined in the NBK Code of Conduct.

Questionnaire