EL Ameed Travel Egypt - Code of Conduct

Integrity is one of EL Ameed Travel Egypt five core values, which -- along with Respect, Innovation, Professionalism and Commitment -- are the pillars of our corporate culture. At Egypt Go Green Network, each individual is responsible for acting with integrity at all times.

Our commitment to act with integrity means complying with the highest professional and ethical standards, as well as the spirit and the letter of the laws that govern our industry, our company and our operations. Conducting ourselves in an ethical manner and with integrity helps us earn the trust and respect of the people we serve and those with whom we work.

This Code of Conduct, is an essential resource for all EL Ameed Travel Egyptemployees. This Code of Conduct outlines EL Ameed Travel Egyptpolicies on business conduct and identifies the people who can answer any questions you might have about compliance-related issues. Please use it as a guide to help you make the right decisions and resolve any issues that may arise in connection with your professional duties. It has been designed as a resource to be used at all times throughout the year, and I encourage you to consult it regularly.

Our Code of Conduct cannot exist without us, the EL Ameed Travel Egypt team. Continuous improvement and corrective action are an integral part of our Global Compliance Framework. If you have any questions or if you witness any inappropriate behavior, I strongly urge you to make use of the Ethics Hotline, our internal reporting system, to bring it to the attention of our Compliance Department.

Acting with integrity depends on each of us understanding and following the policies related to our standards for behavior. It is imperative that all of us at EL Ameed Travel Egyptabide by the highest standards. We owe this to our clients, our partners, our shareholders and ourselves. Let me thank all of you for your unfailing commitment to upholding the principles contained within this Code of Conduct and to promoting it both inside and outside the company.

1. Introduction

EL Ameed Travel Egypt adheres to the U.N. Global Compact, a United Nations initiative created to encourage companies to adopt a socially responsible attitude by committing to promote principles relating to human rights, international labor standards and anti-corruption, and to integrate those principles into their practices. It is a commitment that ensures that markets, business, technology and finance operate for the benefit of economies and societies worldwide.

This Code of Conduct contains the fundamental principles for assisting and guiding EL Ameed Travel Egypt employees in respecting the laws and regulations that govern their activity. It is appended to the Internal Regulations of each EL Ameed Travel Egyptsubsidiary, as applicable.

This Code of Conduct includes the Compliance policies regarding:

· Anti-corruption.

· Influence peddling.

· Anti-money laundering.

· Gifts, travel and entertainment.

· Donations, sponsorship and philanthropy.

· Political activities.

· Facilitation payments.

· Conflicts of interest.

EL Ameed Travel Egypt Compliance is a dedicated structure that stretches from senior management of the Group and the Audit and Compliance Committee of the EL Ameed Travel Egyptto every level of the Group.

Corruption is dishonest, unethical or fraudulent conduct to obtain a benefit or for other improper purposes. It includes criminally-sanctioned conduct in which an individual (the corrupted person) solicits, approves or accepts a donation, offer, promise, gifts or benefit of any kind in order to perform, delay or refrain from performing an act that directly or indirectly falls within the scope of his/her individual duties. The benefits may be financial, but need not be exclusively financial.

Corruption may take various forms, ranging from influence peddling to Facilitation Payments to Bribery. persons involved may be government officials or private individuals such as clients, suppliers or business partners. Acts of Corruption are sometimes facilitated by the use of commercial intermediaries in an attempt to hide them or conceal them from potential investigations.

Generally, there are two types of Corruption:

- Active Corruption, which consists of offering someone a benefit in order to influence a decision or decision-making mechanism or in exchange for a benefit (authorization, right, supply, business, contract, financial gain, etc.);

- Passive Corruption, which consists of accepting or receiving a benefit (usually money or service) in return for using one’s influence to affect a decision. Passive Corruption is not necessarily solicited, but it may be and it may include practices as serious as extortion.

Facilitation Payment is a form of Corruption in which money is paid, typically to a public or government official, to ensure the performance or acceleration of certain administrative formalities or processes.

Bribery is a common form of Corruption where cash or any other gift of value is offered to another person in return for a favorable decision or result, inaction or delayed action.

Extortion means demanding undue recompense in return for the grant of business or authorization, by exerting pressure that may range from occasional or daily demands for money to physical threats against individuals and their family.

Compliance with law

EL Ameed Travel Egypt employees must act in strict compliance with all laws applicable to them.In the event of employment or an assignment outside your country of residence, employees also must act in strict compliance with applicable domestic law in the location of their employment or assignment. In the event of confusion, lack of understanding or doubt about the applicable law and/or its content, employees must immediately inform their Local Contact.

Principles of the Code of Conduct

Anti-corruption

 all acts of Corruption, Bribery or Extortion in any form are strictly forbidden. EL Ameed Travel Egypt must comply with all applicable laws relating to Corruption, Bribery and illegal payments, including the US Foreign Corrupt Practices Act, the UK Bribery Act, the French anti-corruption law known as Sapin II, and other similar anti-corruption laws in the jurisdictions where we do business. These laws generally prohibit the bribery of government officials and private individuals in the conduct of their duties. They also require that EL Ameed Travel Egyptkeep appropriate books and records, and they establish criminal and civil penalties for violations. We must always conduct EL Ameed Travel Egyptbusiness in accordance with these laws.

EL Ameed Travel Egypt employees shall not offer or accept bribes or any other kind of improper payment, including Facilitation Payments. In addition, EL Ameed Travel Egypt employees shall not provide or accept other objects of value such as gifts, loans, discounts or excessive hospitality expenses, or use the company’s funds to influence a decision under any circumstances. This concerns, among others, suppliers, clients, competitors, public authority representatives, political parties, individuals with political exposure, etc.

EL Ameed Travel Egypt employees must refrain from offering, giving, promising or soliciting, either directly or through a third party, any payment or supply of services, gifts, entertainment or other benefits to obtain or retain business or a competitive advantage. In addition, EL Ameed Travel Egypt employees shall not perform any act through a third party that they are not authorized to perform directly. These rules apply to transactions and interactions with government officials, companies and private individuals.

How to behave?

Before entering into a relationship with a business partner, supplier or other third party, you must ensure that the appropriate financial and other due diligence has been conducted on that person or company. Before engaging with a business partner, supplier or other third party, please contact your local Legal Department or Regional Data Privacy Officer for guidance if you are unsure which due diligence and other procedures you must follow.

Examples:

- I have been told that hiring a local “consultant” could help us get all the necessary permits we need from a foreign government. This consultant requested a large retainer and said that he would use the money to “help move the process along”. Can I advance this retainer? Who should I contact?

No. You must not pay any retainer or any other sum until you have made sure that no improper payments are being made and you know exactly what services are being provided. You must consult with EL Ameed Travel Egypt senior management.

- I am responsible for setting up new offices and the local authorities have requested a payment before installing our phone lines. What should I do?

You must not make this payment unless it corresponds to legitimate fees relating to phone line installation.

Payments must not be made to intermediaries unless the payments are legal, comply with the terms of a written contract, and are made following delivery of a proper invoice. No payment may be made without appropriate documentation, including evidence of the work performed, and receipts must be provided for reimbursable expenses. 

- I am attending an international trade show where EL Ameed Travel Egypt is one of the exhibitors. We plan to give away branded promotional materials, and I may invite some of the visitors, who may be government officials, out for drinks. Will I be in violation of anti-corruption laws?

Providing promotional materials to our clients is a legitimate expense when the materials are designed to demonstrate or explain our products and services as part of a trade show. Some anti-corruption laws and/or government policies may prevent you from providing any hospitality whatsoever to a government official, so you should ask the government official whether he or she is entitled to accept your hospitality.

Generally, no matter who your guests are, you must always be careful to ensure that the expenses are moderate and comply with the instructions in the “Gifts, travel and entertainment” section of this Code of Conduct. In all cases, you must keep a written record specifying the type of gift or hospitality and its justification, and you must ensure that the gift or hospitality cannot be considered to be given with the aim of improperly influencing a decision.

Influence peddling

Influence peddling occurs when a person offers or accepts promises, gifts or any other benefit from another person in order for the recipient to use his or her position or political influence to obtain benefits, employment, tenders or any other favorable decision, typically from a government official or public authority.

 influence peddling is strictly forbidden.

How to behave?

EL Ameed Travel Egypt employees should be particularly careful, when they are working on behalf of the company in matters involving representatives of a government agency or public authority, to ensure that there is no influence peddling or other form of Corruption or Bribery.

Examples:

- I am working on an RFP for a tender abroad. I have been told that I should contact a local influential person in the country to get this tender. May I do it?

No. You must consult your Local Contact, the Legal Department of the country concerned or the Group Compliance Department to obtain advice as to how to proceed.

- I am involved in obtaining the necessary permits to build a new EL Ameed Travel Egyptcontact center abroad. I have been told that I should contact a local influential person in that country to get the permits. May I contact this person?

No. You should not contact the local person. You must consult your Local Contact, the Legal Department of the country concerned or the Group Compliance Department to obtain advice as to how to proceed.

- I am working on the acquisition of a foreign company by Egypt Go Green Network. I have been told that the services of an intermediary located in that country are compulsory as part of the procedure for getting the necessary regulatory approvals. 

What should I do?

You must contact your Local Contact, the Legal Department of the country concerned or the Group Compliance Department to obtain advice as to how to proceed.

Gifts, travel and entertainment

When someone receives something of value without having paid the fair market value for it, he or she has received a gift. For purposes of this Code of Conduct, travel and entertainment mean giving or receiving something of value, such as meals, drinks, admission tickets, transportation, travel costs, accommodation or allowances, without paying for it.

EL Ameed Travel Egypt requires its employees who engage with clients, prospective clients, business partners, vendors, suppliers and other third parties to follow certain guidelines in considering offering or accepting gifts, travel and/or entertainment. EL Ameed Travel Egypt generally permits the giving and receiving of business gifts and entertainment under the following conditions:

- they are reasonable in value and frequency;

- they are appropriate and customary business courtesies;

- they are consistent with laws and lawful business practices applicable in that jurisdiction;

- no inference can be drawn that the gift, travel or entertainment could influence either the EL Ameed Travel Egypt employee in a business decision or the performance of his/her duties for the business decisions of the person receiving them;

- they are proper in appearance and without risk of embarrassment or harm to the reputation of EL Ameed Travel Egypt or of the person receiving the gift, travel or entertainment.

In all cases, you must keep a written record specifying the type of gift, travel and/or entertainment, its justification, and you must ensure that the gift, travel and/or entertainment cannot be considered to be given with the aim of improperly influencing a decision.

How to behave?

EL Ameed Travel Egypt employees should not give or accept any lavish or excessive gifts or benefits, whether monetary or non-monetary, directly or indirectly, to or from any government official, client, supplier, subcontractor or any other third party. Gifts or invitations should never influence a EL Ameed Travel Egypt employee’s business decision or be seen as influencing the person receiving them.

Examples:

- I have been offered a gift that I think is intended to influence my decision on a EL Ameed Travel Egypt business matter. What should I do?

Politely refuse the gift and report it to your Local Contact or your Regional Data Privacy Officer.

- As part of my job, I organize numerous meetings and trips. Now a hotel where I often book rooms for EL Ameed Travel Egypt employees has offered me a free weekend for my parents’ wedding anniversary. Can I accept it?

No. Even if you are not personally going to benefit from the gift, accepting the offer gives the appearance of accepting a benefit to influence your business decisions and makes it difficult to remain impartial when you arrange the future hotel accommodation.

Donations, contributions, philanthropy, sponsorship

Charitable donations, contributions and sponsorships are gifts given for a charitable purpose or to support a particular charitable or philanthropic cause. A charitable donation, contribution or sponsorship can be in the form of cash, services or new or used goods. It can also include emergency or humanitarian aid, development aid support, and medical care assistance.

As a responsible corporate citizen, EL Ameed Travel Egypt believes in contributing to the communities where we work by supporting worthy charitable causes, organizations and activities through our Corporate Social Responsibility Committee.

How to behave?

Any charitable donation or contribution to, or sponsorship of, a charitable cause or activity on behalf of EL Ameed Travel Egypt must be approved in advance in writing by the Chair of the Corporate Social Responsibility Committee (cs@elameedtravelegypt.com)

When contributing to a charity or sponsoring a charitable cause or activity on behalf of EL Ameed Travel Egypt , the Corporate Social Responsibility Committee must ensure that the recipient is a bona fide charity, appropriately registered or licensed in the local jurisdiction, and that the contribution is in line with our corporate values and policies.

Donations or contributions to, or sponsorship of, a charity associated with a government official are not permitted.

All approved charitable donations, contributions or sponsorships must be properly accounted for and accurately reported in the company’s books.

Political activities

EL Ameed Travel Egypt observes strict political, religious and philosophical neutrality.

Accordingly, EL Ameed Travel Egypt policy is not to make financial contributions to political candidates, elected representatives or officials, political parties, or religious organizations.

EL Ameed Travel Egypt respects its employees’ right to participate as individuals in the political process as long as they make sure that they do not represent EL Ameed Travel Egypt and their activities are not viewed by others as participation by or on behalf of EL Ameed Travel Egypt.

How to behave

If you choose to do so, participate in political activities in your own name and outside of work hours and work locations.

Never use EL Ameed Travel Egypt premises, materials, supplies, equipment or other resources for political activities.

Do not use EL Ameed Travel Egypt corporate image, logos, stationery or other Egypt Go Green Network-branded materials to support your political views.

Respect the beliefs of others.

If you participate in any political decision-making process that addresses any matter related in any way to EL Ameed Travel Egypt, its business, industry, clients or employees, you must inform your local Legal Department or Regional Data Privacy Officer and abstain from discussion and voting on such matter.

Conflicts of interest

A conflict of interest may occur when a EL Ameed Travel Egypt employee has a financial, business or personal interest or activity that interferes or conflicts, or appears to interfere or conflict, with EL Ameed Travel Egypt best interests or reputation. There are many situations that are or could be perceived as a conflict of interest, such as:

- A situation in which you learn about a business opportunity through your position at EL Ameed Travel Egypt and you, a family member or friend uses it for personal benefit or otherwise against EL Ameed Travel Egypt best interests.

You are required to make informed business choices in the best interests of the Group. You should avoid any situation in which your personal interests, or the interests of your close friends or relatives, are -- or appear to be -- in conflict with EL Ameed Travel Egypt best interests.

How to behave

When you conduct professional activities, you must act only in the best interests of Egypt Go Green Network, and refrain from benefiting or taking advantage of any situation, either directly or indirectly through a third party, for your own gain or that of others.

You must identify actual and potential conflicts of interest in advance, and comply strictly with the procedures provided for by EL Ameed Travel Egypt in specific areas of operation, such as procurement, subcontracting and business development. You must also comply with the regulations that apply in your country or the country concerned.

You must disclose in writing to your manager and local Legal Department all your outside interests or those of your family members that create, or could appear to create, a conflict of interest.

Avoid using EL Ameed Travel Egypt resources for personal gain or benefit of any kind. This includes EL Ameed Travel Egypt office equipment, materials, time, resources and/or intellectual property.