The Sahara International Petrochemical Company (Sipchem) is proud of its commitment to always conduct business with the highest degree of integrity and in full compliance with applicable laws and regulations. This commitment to integrity and high ethical standards extends to Sipchem’s dealings with all of its vendors, suppliers, and contractors (collectively, “Suppliers”). It is through this commitment we seek to ensure that we conduct our business in a responsible manner. We expect our Suppliers to have a similar commitment. It is the Supplier’s responsibility to achieve and maintain the minimum standards outlined in this Supplier Code of Conduct (Code), and train employees and contracted parties on their consequential rights and responsibilities.
Sipchem will assess its Suppliers’ compliance with this Code, and any violations of this Code may jeopardize the Supplier’s business relationships with Sipchem, up to and including termination. This Code applies to Sipchem suppliers and their subsidiaries, affiliates, and subcontractors (each a “Supplier”) providing goods or services to Sipchem.
COMPLIANCE WITH LAWS, CODES, AND REGULATIONS
Sipchem suppliers must abide by this Code and its principles, and comply with the laws, rules, and regulations of the Kingdom of Saudi Arabia and the locations in which they operate as well as all applicable treaties and international standards. They are expected to be familiar with the business practices of their suppliers and subcontractors, and ensure they also cooperate in accordance with the standards found in this Code.
ENVIRONMENT, HEALTH, AND SAFETY
It is the responsibility of the supplier to ensure that its facilities are designed and safely operated in compliance with the established government and industry environmental protection policies and that they do not present unnecessary risks to the environment or public. Sipchem suppliers shall provide safe, sanitary, and healthy living quarters with reasonable personal space for all their employees.
Such compliance shall include, among other things:
- Obtaining, maintaining, keeping current, and complying with all required environmental permits and registrations.
- Supplier shall comply with the reporting requirements of applicable environmental permits and regulations.
- Proper handling and disposition of hazardous materials and refuse.
- Monitoring, controlling, and responsibly treating discharges generated from operations.
- Having written safety and health policies and procedures.
- Conducting appropriate employee safety training and providing adequate safety equipment.
- Providing training required to promote sound public health and hygiene practices.
- Maintaining records of safety training and monitoring safety performance.
- Ensuring Suppliers’ employees comply with applicable health and safety rules and regulations and perform their duties and work in a manner which will not endanger themselves or others.
ETHICAL BUSINESS PRACTICES
Sipchem and its suppliers shall conduct their businesses in accordance with the highest standards of ethical behavior. This includes complying with the US Foreign Corrupt Practices Act (FCPA) and other applicable international anti-corruption conventions. Suppliers are expected to conform to these requirements in each of the following areas:
FAIR TRADE PRACTICES
TSuppliers shall not engage in collusive bidding, price discrimination, anti-competitive, antitrust, or other unfair trade practices.
Suppliers shall source goods or services from third parties that meet, as a minimum, country of origin standards for health and safety, working hours, pay, employment conditions and environment protection.
RELATIONSHIPS AND COMMUNICATIONS
Sipchem Business Ethics Policy requires that all transactions are to be conducted fairly, honestly, and with integrity, according to the highest ethical standards. Suppliers and their personnel shall avoid even the appearance of unethical or compromising practices in relationships, actions, or communications with regard to existing or proposed business relationships with Sipchem.
Sipchem views it as conflict of interest and improper business practice for current or former Sipchem employees to utilize any confidential or proprietary business, technical, or other information obtained while in the service in Sipchem to influence Sipchem’s existing or proposed commercial transactions for the purpose of gaining a personal commercial advantage, or benefitting any third party, or to otherwise damage Sipchem, whether during or after leaving employment by Sipchem.
Suppliers shall not encourage or utilize current or former Sipchem employees in any manner which would cause them to disclose or provide any confidential, proprietary, or other restricted information obtained while employed by Sipchem to influence Sipchem’s existing or proposed commercial transactions for the purpose of gaining a commercial advantage
Suppliers shall not hire, employ, engage as a consultant, procure the service, or allow acquisition of any ownership interest of the Supplier, except through a permitted passive investment, by any current Sipchem employee. The restriction shall also apply to any former employee who has held a position within Sipchem at the level of “department head” or higher. The restriction pertaining to former employees shall be valid for a period of two (2) years following the time that such individual is no longer an employee of Sipchem.
Suppliers may seek exceptions to these restrictions from Sipchem. Request for such exceptions should be submitted to the Chief Compliance Officer. Sipchem will take appropriate measures to detect any such improper business practices and will take appropriate action against current or former employees and Suppliers who violate these restrictions. Suppliers are expected to cooperate with Sipchem investigations and to provide assistance as requested.
BRIBERY, KICKBACK AND FRAUD
No funds, assets, services, privileges, or benefits shall be paid, rendered, loaned, or promised for payment or otherwise dispersed by Suppliers or their representatives as bribes, “kickback”, or other payments or inducements designed to influence or compromise the judgment or conduct of Sipchem or its representatives.
GIFTS, GRATUITIES AND HOSPITALITY
Suppliers and their personnel shall not offer or provide Sipchem or its personnel with gifts, gratuities, or hospitality unless it is unsolicited, involves nominal value and is in line with customary business practices. Nominal gifts are described as a gift of a general nature having a low value, including such items as logo inscribed pens, caps, shirts, and coffee mugs. Customary business practice in terms of hospitality would include the acceptance of reasonable business entertainment and business meals.
Gifts, gratuities, and hospitality offered or extended by Suppliers to Sipchem personnel which exceed nominal value or reasonable hospitality are reportable under Sipchem policies and regulations. Items which are made available to the general public do not fall under this Policy.
MONITORING AND COMPLIANCE
Suppliers shall be responsible for complying with the standards and requirements of this Supplier Code of Conduct and to monitor their own business activities. Suppliers shall conduct periodic internal review, inspections, and audits to ensure their compliance with this Supplier Code of Conduct and it applicable requirements. Additionally, Suppliers are responsible for ensuring that the standards and requirements of this Code are communicated, and understood by their personnel working or in support of Sipchem projects, jobs, contracts, agreements, and orders. Suppliers will be held responsible for the conduct and action of their employees.
The implementation of this Policy is a shared responsibility between Sipchem and its Suppliers. Suppliers are to promptly disclose to Sipchem, on a confidential basis, all current and potential incidents which give rise to the appearance of conflicts of interest and instances of unethical or fraudulent behavior by any party including Supplier employees or Sipchem employees, related to any Sipchem procurement and contracts business. Suppliers are to cooperate with Sipchem in any inquiries or investigations pertaining to past, current, or potential instances of unethical or fraudulent behavior or conflicts of interest related to any Sipchem business activity.
Suppliers are to promptly notify Sipchem when they become aware of any actual, or potential violation of this Code of Conduct and to communicate plans to correct and remedy such violation. Additionally, Supplier employees that become aware of violations of this Code are to notify Sipchem.
Potential or actual violations of this Code of Conduct and other ethical irregularities are to be reported directly to Sipchem Chief Auditor, and Chief Compliance Officer by email, letter, or telephone as follows:
Email: [email protected]
Phone: +966 13 8019309
Address: Chief Auditor & Chief Compliance Officer, P. O. Box 130, Khobar 31952, Kingdom of Saudi Arabia
All matters raised in good faith through these reporting lines will be handled in confidential, non- retaliatory manner
Suppliers shall maintain appropriate records to substantiate compliance with the terms and conditions of this Code of Conduct and provide evidence to Sipchem upon request. Sipchem or it designated representatives may engage in periodic monitoring activities to confirm Suppliers’ compliance with this Code of Conduct. These monitoring activities may include on-site inspections of facilities, use of questionnaires, review of publicly available information, or other measures necessary to assess Supplier compliance with this code of conduct. Such monitoring activities may be performed in addition to any audit rights which may be set forth in an agreement with Sipchem. A Supplier performance assessment will be used by Sipchem as a factor in the selection of bidders, the administration of contracts and procurement or possibly restrict Supplier access to new Sipchem business opportunities.
Based on the assessment of information made available to Sipchem, Sipchem reserves the right (in addition to all legal and contractual rights) to disqualify any potential Supplier or terminate any relationship with a current Supplier which Sipchem has found to be in violation of this Supplier Code of Conduct, without liability.
As part of the process of seeking to provide goods, services, or personnel (including consultants) to Sipchem or in providing such goods, services, or personnel under the terms of an applicable Agreement, Suppliers may gain access to information or material which Sipchem deems to be proprietary or confidential. Suppliers, in all instances, shall comply with the obligations of confidentiality which are set forth in the applicable request for proposal, invitation to bid, other solicitation document, or agreement by and between Sipchem and the Supplier.
Sipchem views breaches of confidentiality and unauthorized disclosure or use of proprietary or confidential information very seriously and reserves the right (in addition to all other legal and contractual rights) to disqualify any potential Supplier or to terminate any relationship with a current Supplier Sipchem has found to have violated its obligations of confidentiality.
All advertising, press releases, or printed matter that references Sipchem or a Supplier’s relationship with Sipchem must be approved by the Sipchem Corporate Communication Department prior to publication or other use.
The Supplier Code of Conduct is a general statement of Sipchem’s expectations and requirements with respect to its Suppliers. The Code of Conduct should not be read in lieu of, but in addition to, any Supplier obligations set forth in a) requests for proposals, invitation to bid, or other solicitation documents, or b) agreements by and between Sipchem and the Supplier. In the event of a conflict between this Code of Conduct and any Sipchem solicitation documents or applicable agreements, the terms of the applicable solicitation documents or agreements shall prevail. The requirements of this Code of Conduct are not subject to waiver. Neither Sipchem, nor their personnel or representatives are authorized to propose or approve conduct inconsistent with this Code of Conduct.
I, on behalf of (Name of Vendor/Manufacturer/Contractor/Sub-contractor), hereby acknowledge and agree to abide by the policies and principles of Sipchem’s Supplier Code of Conduct and to ensure that the employees, officers, directors, agents, and representatives of (Name of Vendor/Manufacturer/Contractor/Sub-contractor) are aware and shall abide by such policies and principles in the process of preparing and submitting bids, proposals, or other business communications for Sipchem, for provision of goods and services to Sipchem, and during the performance and administration of all agreements entered into with Sipchem for such purposes.