EGYPTIAN COMPANY

EGYPTIAN COMPANY CONTRACTING & TRADING

ECCT Social Responsibility Policy
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ECCT Social Responsibility Policy

The Egyptian Company Contracting & Trading seeks to be a good company citizen in all aspects of its operations and activities.

To this end we have brought together a series of operating principles under the broad heading of Company Social Responsibility (CSR) to serve as a guide to employees in all aspects of their work for the company. The principles cover all areas of the company’s operations and have been developed with reference to the relevant codes and best practice, including the revised Combined Code and international statements and guidelines such as the UN Universal Declaration of Human Rights. Taken together, these principles form our CSR policy. The policy can be divided into six :

  • Ethical Business Conduct
  • Policies Specific to Employees
  • Policies Specific to the Group
  • Fair Employment Practices
  • Workplace Health and Safety, and Environmental Policy

1. Ethical Business Conduct

A. Our Principles

We value the principles of accountability, honesty and integrity in all aspects of our business. Our policy is to conduct our business in a manner which ensures:

  • Fair treatment of all employees and clients
  • Transparency of our business policies and practices
  • High standards in all matters relating to health, safety and the environment
  • Ethical business practices throughout our operations

We recognize that the involvement of our employees is the key to the future success of the business and we have for many years adopted a policy of keeping employees fully informed on all matters affecting them. We have consistently operated a remuneration strategy that recognizes both corporate and individual performance. We are also committed to best practice in employment matters, recognizing the role this plays in attracting and retaining staff.

To succeed in delivering the best possible service to our clients, every employee is expected to adhere to the company’s core values and to uphold them in the workplace.
Employees are expected at all times, to exercise the highest ethical judgment and comply with laws applicable to their duties.

2. Policies Specific to Employees

A. Compliance with Codes and Regulations

In addition to the company’s internal operating principles employees shall adhere to all national laws and regulations. As civil contractor our managers will be required to familiarize themselves with the codes of practice and regulations in force in Egypt. Also this shall be followed in case we work overseas.

Whistle Blowing

In the event that an employee discovers a breach of company policy there is a facility for him/her to report that breach in confidence either via his line manager or via an anonymous email address sent directly to the Head of Internal Audit. The Head of Internal Audit has a duty to investigate fully the detail behind such a report and as part of the investigation will not normally make reference to the anonymous report. Maliciously motivated reports for which there is no real basis for making a report are not welcomed and may result in disciplinary action being taken against the employee making the accusation.

B. Outside Interests

The Group requires that employees avoid at all times any situation which may involve a conflict of interest between the employee and the company. Employees are expressly prohibited from accepting other paid employment, including directorships in other companies, without the consent of the Executive. In general, this does not apply to charitable work or relationships with non-profit organizations unless this has the potential to impact on the employee’s normal duties.

C. Dealing with Customers and External Parties

The Group is committed to the provision of accurate information and fairness in all its dealings with customers, officials and any other external party having direct business with the group.

D. Confidentiality

Every employee shall respect any information which is confidential to the Company including, but not limited to, trade secrets, confidential knowledge or any information concerning the process or invention used by the Company. Breaches of confidentiality may be cause for disciplinary action.

Data Protection

We are committed to protect our Employer’s data. If the Company conducts business in a jurisdiction where stricter rules apply, then it will comply with those rules as a matter of course. All employees and agents of the Company are responsible for ensuring compliance with the policy. Information collected may be accessible throughout the Company but will not be disclosed to any third party in a form which identifies the individual concerned. It will not be used for marketing purposes without the individual’s consent and will not be sold to third parties.

E. Malpractice

The Company actively works to deter malpractice in its workplace, with specific attention to activities involving bribery and corruption, fraud, money laundering and insider trading.

The Company has procedures for staff to follow in order to ensure observance of these principles. The Compliance Database contains guidance on the value of gifts which may be given (or accepted) by staff to (or from) counterparts in the industry, the frequency with which those gifts may be made (or accepted) and how they should be recorded.

F. Use of Company Information / Assets

Employees shall use the company’s computer systems, internet and email systems for business use. Any employee found to have disclosed confidential information, been abusive or malicious in using these facilities, or misusing the systems in any way may face disciplinary action. The Company strictly prohibits the use of its internet or email systems for acquiring, producing or disseminating pornography or similar material, including the use of abusive language or offensive images.

3. Policies Specific to the Company

A. Political Contributions

It is the Company’s policy not to make contributions for political purposes. However, employees are not hindered from being politically active in their own time using their own resources.

B. Company Governance

I. Background

The Company does projects for its clients. Our ultimate goal is to deliver superior and consistent performance across the projects’ life.
Since its beginning in 2004, the Company has been committed to its core business values of integrity, transparency, honesty and accountability. These values form the basis of optimum corporate governance. The Company is committed to complying with good corporate governance policies and to listening to and acting in accordance with the wishes of its Employers.

II. Organization

The Board of Directors currently comprises the Chairman and six Executive Managers:

    • Chairman: Eng. Sayed Abdel Rahim (General Manager).
    • Projects Manager: Eng. Maher Melikah.
    • Technical Manager: Eng. Ayman El-Gundor.
    • Q/C Manager: Eng. Ahmed El-Tabakh.
    • Financial & Administration Manager: Mr. Mahmoud Marzouk.
    • Accounting Manager: Mr. El-said Abdel Hamid.
    • Procurement & stores Manager: Mr. Adnan Ibrahim.

III. Meetings of the Board

The Board of Directors is scheduled to meet every month to review projects performance and strategy and has a formal schedule of matters reserved for its decision, which includes the setting of company goals, objectives, budgets and other plans. In particular, the Board regularly receives reports on the company’s corporate social responsibilities and they have identified the relevant risks to the company’s short and long term values, more on which is contained later in this document.

IV. Internal Controls

Mr. Mahmoud Marzouk, Head of Financial & Administration, has overall responsibility for the Company’s system of internal control and for reviewing its effectiveness. The internal controls are designed to cover all risks to achieving the Company’s objectives including all business, operational, financial and compliance risks. The internal controls are designed to manage, rather than eliminate, risk of failure to meet business objectives and to provide reasonable, but not absolute, assurance against material misstatement or loss.

The system of internal control is embedded within the day to day operations of the Company and a strong control culture is combined with clear management responsibility and accountabilities for individual controls.

At least once a year the Executive presents a formal risk control report to the Board.
This includes a summary of significant risks, key internal controls, the work of the monitoring functions and findings arising during the period. In addition, the Board regularly receives reports on the Company’s social, ethical and environmental (SEE) issues which are further detailed later in this document. In this context, the board has identified staff retention and corporate reputation as the significant risks to the company’s short and long term value. Directors are keenly aware of the importance of these issues and are committed to ensuring that any risks are assessed and minimized.

C. Community Investment

ECCT Community Investment Programme comes under the overall direction of Eng. Sayed Abdel Rahim and is managed by Mr. El-said Abdel Hamid, Accounting Manager.
The Community Investment Programme has two main components, charitable giving and support for a wide variety of local organizations especially in building schools.

I. Charitable Donations

At the commencement of each fiscal year the Board will agree an amount which should be allocated to donations to charity and support for good causes. The Company will aim to grow this core amount over time and, depending on the profitability of the Company, may make specific one-off donations.

The amount allocated is administered by a by Mr. El-said Abdel Hamid. He will consider proposals for the use of the funds. The proposals may come from the Board, from employees, and from individuals and groups out with the company. Each proposal will be considered on its merits.

II. Activities in the Community

Since the Company was founded in 2004 the company has grown and diversified its working areas. We have been involved with national and local charities, schools and educational authorities.

We encourage employees to be active in the community in their own right and to this end operate a flexible working policy which permits staff to use a certain amount of working time each year to devote to charitable activities. Members of staff act as school governors, or are members of parent/teacher associations.

III. Benefits of Community Involvement

As the Company becomes more involved in the community the company may be invited to propose or participate in new projects.

4. Fair Employment Practices

In formulating employment policy the Company has been guided by the relevant legislation in Egypt that encourages companies to foster openness, sustainability, and respect for employees’ rights. The policies are periodically reviewed and updated, when appropriate.

A. Equal Opportunities Employer

The Company is committed to providing equal opportunities to all workers and job applicants.
It aims to ensure that no job applicant shall receive less favorable treatment on the grounds of sex, marital status, sexual orientation, race, color, religion or belief, nationality or ethnic or national origin. The company will not treat an employee or job applicant less than favorably for a reason relating to their disability or part time or fixed term status unless this can be justified.

The Company will also take all reasonably practical steps to ensure that disabled applicants or workers are able to participate in its business activities on an equal basis with people who are not disabled. All employees are responsible for complying with this policy and for ensuring that the standards of behavior required by the company are observed by:

      • Treating others on their merits and disassociating themselves from any form of direct or indirect discrimination, victimization or harassment.
      • Bringing to the attention of their Manager any suspected working practice in breach of this policy. And Working together to promote a harmonious working environment free from discrimination, harassment and bullying. .
      • The Company regards direct or indirect discrimination, victimization and harassment as a serious matter. Employees who fail to comply with this policy will be subject to the Company’s disciplinary procedure. All breaches of this policy will be regarded as serious disciplinary matters and will, if there has been victimization, intentional discrimination or deliberate harassment be regarded as potential gross misconduct leading to summary dismissal. The Company recognizes that misunderstandings can arise where people of a different sex, interests and cultures work together. Any employee who believes that he or she is being treated in a way that is contrary to this policy should raise the issue with their Departmental Manager. If an employee feels that it is inappropriate to approach their Departmental Manager he or she may contact the Human Resources Department.

B. Human Rights

ECCT supports the Universal Declaration of Human Rights in all of its spheres of influence.
It upholds the freedom of association and recognizes the right to collective bargaining.

C. Forced / Child Labor

The Group does not utilize or promote forced or child labor of any kind. We adhere strictly to country laws governing labor standards.

D. Discrimination, Sexual Harassment and Other Forms of Harassment and/or Bullying

All staff are entitled to work in an environment which respects their personal dignity and which is free from harassment, bullying or any other type of intimidation. Harassment, whether on the grounds of sex, race, color, nationality or ethnic origin, religion or belief, or age, disability, sexual orientation, being in an inferior position in terms of power or hierarchy (leading to bullying), willingness to challenge harassment (leading to victimization) or otherwise will not be tolerated by the Company.

E. Employee Benefits

The Company recognizes the value of its employees and has identified and assessed their long term retention as key to the short and long term value of the Company. To this end, the Company aims to attract and retain skilled employees and enhance the life/work balance of each individual. The Company offers its full time staff a range of benefits, including a pension scheme, maternity and paternity leave and generous holiday allotment. Also available to employees are personal development and training programmes designed to enhance the employee’s skill base. All such programmes shall relate directly to the specific role of the individual within the Company and are linked closely with his/her annual performance review.

F. Grievances

The Company has adopted a grievance procedure to provide employees who consider that they have a problem or compliant about their work with a mechanism for resolving the issue fairly and speedily. The grievance procedure encompasses the statutory grievance procedure.

5. Workplace Health & Safety

A. Health & Safety Policy

The Company aims to provide each employee with a safe place to work. All Company locations are required to abide by the local health and safety regulations. Relevant information on occupational health and safety is provided to staff. Further information on health and safety topics can be discussed with the Company’s Human Resource department.

B. H&S Records

The group records all accidents and/or near misses and investigates these to determine if preventative action is required to prevent further accidents.

6. Environmental Policy

A. Background

The Company understands that its activities affect the environment and the communities in which we operate. We believe that we have a responsibility to identify and manage these impacts as effectively as possible. We are committed to continually improving our environmental performance and moving towards best practices in corporate sustainability.

B. Environmental Management Team

Each project manager is responsible the implementation and communication of this policy. Reporting regularly to the general manager, they shall also be responsible for establishing and monitoring performance against appropriate industry benchmarks.

Project managers shall be responsible for the day to day control of the environmental
programme and for reporting on its progress. The Company may seek advice from external specialists as and when required.

C. Communicating the Policy

All employees are informed of the policy and are encouraged to contribute to the achievement of its objectives. A general overview is included in the staff induction programme and employees are encouraged to provide feedback and suggestions.

D. Environmental Policy

The Group aims to:

      • minimize the environmental impacts of our existing operations and ensure that the environmental impacts of new operations are fully assessed and minimized prior to their introduction;
      • reduce consumption of materials in all operations, where practicable, to re-use rather than dispose of materials where possible, and promote recycling and use of recycled materials;
      • seek to improve the energy efficiency of buildings and to manage energy wisely in all operations;
      • reduce, wherever practicable, the level of harmful emissions from our office premises;
      • introduce programmes that aim to minimize waste;
      • dispose of waste and effluents in a responsible manner;
      • Promote the ownership and control of environmental issues at business level.
      • provide the necessary training and support in order to ensure that staff fulfills their requirements;

E. Environmental Risks

As a company working in the construction sector, there are many environmental risks associated with the company such as dust during earth work, noise from heavy equipment, water pollution when drainage from de-watering system, CO2 emissions from equipment & transporting of material etc.

Energy used for heating, lighting and cooling of offices and for office equipment is another critical element of the process.

The Environmental Policy seeks to mitigate these risks and the Environmental Management System explains further how we seek to achieve this aim.

F. Environmental Management System

The company’s Environmental Management System (EMS) has the following components and objectives. As additional areas for monitoring are identified, they will be integrated into the EMS.

I. Water

We seek to keep rivers or canals clean & reduce the amount of water used. In shared projects we will investigate the possibility of the installation of separate meters to monitor use and cost.

II. Dust

ECCT always avoid air pollution by dust, spreading water over working area during earth works is one example.

III. Energy

The group aims to reduce the consumption of energy and will also strive to ensure that their office premises use energy in as efficient a manner as possible. Energy is used for office lighting, heating and cooling systems and for the operation of office equipment and kitchen appliances.

      • Lighting ECCT will encourage the use of low energy lighting and where practicable, the use of segmented areas which will allow lights to be switched off when not required.Likewise we will encourage the use of manual and passive infra-red switches where practicable.
      • Heating To make more efficient use of heating systems we will ensure that the temperature is set for a comfortable working environment and not more than 25Co. Where heating is provided as part of a leased or rented building system, we will aim to ensure that thermostats are available for use by ECCT employees.
      • Air conditioning Air conditioning units are available in most of our office locations. These will only be used when required and will be switched off when the office is not in use.
      • Kitchen appliances We will aim to ensure that our kitchen appliances are energy efficient and that they release the minimum amount of waste product.

IV. Paper

We seek to reduce the amount of paper used and to increase the amount of paper that is recycled. ECCT will strive to reduce the amount of paper purchased and will encourage staff to re-use or recycle paper.

Where possible, client reports will be printed on recyclable and chlorine free paper. In addition, staff is encouraged to make use of electronic communications in the form of email and the scanning of documents into electronic records for storage.

V. Waste

General office waste is collected and removed each day by cleaners and taken to a compactor for removal by a waste contractor, or is collected weekly by the local authorities.
Toner cartridges are collected after use for donation to charity.

Redundant equipment, which is not sold or given to a charity, will be collected by an approved third party company who will dispose/ recycle the hardware in a manner that is environmentally friendly.

VI. Hazardous materials

We will accept responsibility for monitoring hazardous materials found in the office or site, including, for example asbestos, polychlorinated biphenyls (“PCB’s”) and refrigerants to ensure that they do not pose a risk to our employees.

We will ensure that annual service and maintenance programmes for our air conditioning plants are carried out, as required under current guidelines.

VII. Transport

Transport is a major source of CO2 emissions. To reduce these emissions the company insures that the owned or subcontractors equipment & cars’ engines are always in good condition.

VIII. Supply Chain Management

We wish to encourage sustainability and environmentally sound sourcing and production methods in our suppliers’ manufacturing and delivery processes. To this end we will inform our suppliers of our Environmental Policy and we will inform them that we will look to favour companies with established environmental policies and practices in the allocation of future contracts. We will also aim to use local suppliers and local goods and services, where practicable.

IX. Involvement in the Community

ECCT has been fostering good relations with the community.

ECCT will identify any specific community areas of concern on which ECCT’s business has an impact. If so, ECCT is willing to work towards integrating these concerns into its EMS procedures and will work to resolve them.

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