Transcript Business Ethics Inductee Training Session Contents CEO Message Inductee Training Session - Objectives Section 1: Business Code of Conduct Section 2: Whistleblowing Section 3: Guide to Ethical.

Business Ethics
Inductee Training Session
Contents
CEO Message
3
Inductee Training Session - Objectives
4
Section 1: Business Code of Conduct
5
Section 2: Whistleblowing
26
Section 3: Guide to Ethical Decisions
29
Section 4: Conclusion
31
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CEO Message
Welcome to the Mobily Inductee Training Program!
We pride ourselves in conducting business to the highest standards of Honesty, Fairness, and Accountability.
These concepts of ‘fair play’ reside in unison with our core values. We should never lose sight of the fact that
success without integrity would be shallow and self-defeating. Ethics is integrated in everything that we do, and
with everyone that we do business with.
This training is provided to give each of you an overview of our expectations on how you conduct yourself, and
supply guidance in matters relating to business ethics. Of course, you should seek input from your Manager or
supervisor in a circumstance where you have an issue, or where you need to report misconduct.
The objectives of the Code are:-
To establish rules of conduct and
standards of behavior for
employees of Mobily
To make employees accountable
for exhibiting and/or reporting
inappropriate behavior or violating
the Mobily Business Code of
Conduct
To highlight that ethical and
responsible behavior is a crucial
factor in the long term success of
Mobily
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Inductee Training Session - Objectives
The three central themes from the training will be: Understanding and complying with the Business Code of Conduct & Ethics (the ‘Code’)
 Knowing how to seek advise and assistance from your colleagues and Managers
 Recognise that you have a reporting obligation on ethical matters which place Mobily,
or you, at risk
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Section 1:
Business Code of Conduct
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Business Code of Conduct & Ethics
Purpose of the Code
To provide the ethical framework on which we base our decisions as individual members
of Mobily. It defines our behavior in dealings with Mobily’s stakeholders and in the
conduct of our day to day activities .
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Business Code of Conduct
Maintaining our Reputation
“Our reputation is based on the integrity of the company’s
personnel, and our dedication to Honesty, Innovation, Quality,
Accountability, Service, Fairness, and Respect”
“Positive reputation takes years to establish, and seconds to
destroy…”
People seek to do business with those that they trust. Even the
perception of behaving in an unethical manner will have an
impact on how our business partners and customers see us.
Do
Do not
Speak positively about Mobily
Treat everyone with honesty,
fairness, and respect
Take pride in yourself, your
colleagues, and our company
Smile!
× Do anything that may bring
Mobily into disrepute
× Disrespect a person even when
they are disrespecting you
After our people, our reputation is perhaps the most precious commodity that we have in our possession
For further information on reputation, refer to section 4 of the Mobily Business Code of Conduct
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Business Code of Conduct
Company Property
“All the company assets will be used for legitimate business
purposes and it will be the responsibility of all employees to ensure
the company assets are safeguarded”
Legitimate business purpose extends to proper and efficient
usage also.
Includes company time; cash; checks; drafts; land; buildings;
records; vehicles; equipment; any physical asset; scrap and
obsolete items.
Do
Do not
Care for company property, and
report any misuse or
misappropriation
Ensure that all property is
properly stored and secured
when not in use
× Remove Mobily property for
personal use
× Permit other personnel to misuse
company property that has been
assigned to you
Theft is a serious offense. Mobily has a zero tolerance policy, and will take strong action.
For further information on Company property, refer to section 10.1 of the Mobily Business Code of Conduct
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Response Test #1.1
Company Property Scenario
You witness a reception clerk, who works in the central customer service centre,
loitering inside the IT inventory store. As you watch, he exits the IT store through the
fire exit. You know he does not have permission to be in the store, and he should have
permission from the IT inventory manager to enter. What would you do?
A.
Confront the reception clerk
B.
Report it to the IT inventory manager
C.
Inform his direct supervisor
D.
Report it to your direct supervisor
E.
Report it to the Mobily Ethics Hotline
F.
A, B, and D
G.
All of the above
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Response Test #1.2
Company Property Scenario – Deeper observations
You witness a reception clerk, who works in the central customer service centre,
surreptitiously removing three external USB hard drives from the IT store and placing
them in a handbag. He exits the IT store through the fire exit. You know he does not
have permission to be in the store, and that these items require a requisition and
release form issued by IT inventory manager. With these extra observations, would your
response be different? What would you do?
A.
Confront the reception clerk
B.
Report it to the IT inventory manager
C.
Inform his direct supervisor
D.
Report it to your direct supervisor
E.
Report it to the Mobily Ethics Hotline
F.
A, B, and D
G.
All of the above
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Business Code of Conduct
Gifts and Favors
“A gift or a business courtesy that is valued at more that SR 100 is
not to be accepted under any circumstances. The offering and
giving of gifts should be discouraged”
Provisions apply to all employees at all times, even when on
leave.
Disclose any offered or received gifts to your supervisor and
Compliance Office as soon as is possible.
Do
Do not
Get approval from Manager
prior to accepting invitations to
events or functions
Return delivered gifts to donor
× Accept money from a customer of
supplier
× Solicit for yourself or any third
party anything of value from
anyone in return for service /
information
Gifts valued under SR 100 (such as logo inscribed pens, caps, shirts, and coffee mugs) are permissible
For further information on Gifts & Favors, refer to section 7.5 of the Mobily Business Code of Conduct
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Response Test #2
Gifts and Favors Scenario
Scenarios
Can you receive this gift?
 A pen?
•
If yes, when?
 Dinner?
•
If yes, what must you do?
 A car?
•
If not, why not?
 2 tickets to a major sport event?
•
If not, how would you say ‘no’?
 A trip for you to Dubai?
•
What do you do if you are unsure?
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Response Test #3
Gifts and Favors Scenario
You become aware of a colleague who accepted a Tissot watch as a gift from a supplier
who is bidding for a supply contract with Mobily.
A.
Do nothing
B.
Confront your colleague
C.
Report it to the Mobily Ethics Hotline
D.
Report to your supervisor
E.
Both C and D
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Business Code of Conduct
Conflicts of Interest
“Avoidance of conflicts between personal interest and the interests
of Mobily, or even the appearance of such conflicts”
Perception is reality when it comes to conflict of interest.
Never allow business dealings on behalf of Mobily to be
influenced – or even appear to be influenced – by personal or
family interests
Do
Do not
Disclose any direct or indirect
interest that you or you family
may have in an undertaking that
either competes with, or
supplies to Mobily
× Enter into any form of competing
business
× Offer any trading assistance to
any person outside of Mobily,
including family and friends
× Undertake a second job
* Trading assistance through confidential information the employee has by virtue of his/her employment
For further information on Conflicts of Interest, refer to section 7.4 of the Mobily Business Code of Conduct
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Response Test #4
Conflicts of Interest
You are at a party talking to someone you haven’t met before. When you mention
where you work, he tells you that the brother of one of your managers is the director of
a company which supplies a significant amount of services to Mobily, and that they are
currently bidding for a large services contract.
Q. What issues could this raise?
Q. Would you do anything with
this information?
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Fraud Awareness
What is Fraud?
Fraud is a theft where deceit or trickery is involved. Fraud is
a criminal offense punishable by fines, imprisonment, or
both. In the business world, it can also result in the loss of
employment, benefits and reputation, with a significant
reduction in opportunity for any onward employment.
Fraud can either be committed by persons external to a
company, by persons within, or a combination of both.
Zero Tolerance
Mobily has a “zero tolerance” attitude towards fraud and
unethical behavior, and will prosecute or apply other
appropriate sanctions against those who are found to have
committed fraud.
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Business Code of Conduct
Bribery
“Bribery means giving or receiving an undue reward to influence
the behavior of someone in government or business to obtain
commercial advantage which violates the laws of Saudi Arabia”
We will remain committed to transparency in all our dealings.
Mobily does not permit any ‘facilitation’ (“Rashwa”) payments to
government officials.
Do
Do not
Report any inappropriate
approaches to your Manager /
supervisor, or Ethics Hotline at
the earliest opportunity
× Offer or promise anything of value
to improperly obtain or retain
business
× Make improper payments through
third parties
× Accept any form of inducement to
do, or not do something that is
contrary to your duties
A breach of the law in these matters is a serious offense, and has far reaching impacts for you and the company
For further information on Bribery, refer to section 9 and section 11.2 of the Mobily Business Code of Conduct
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Bribery
What is Bribery?
Offering, giving, soliciting or accepting of an inducement or reward, which may influence the
action of any person.
•
That is, an individual receives a bribe as a reward or incentive for action or inaction contrary to the
proper conduct of his or her duties, for the direct benefit of a third party
•
Direct or indirect loss
•
Not only cash/money, it is any item of benefit
•
Bribery relates to the giving AND/OR receiving of bribes
•
It is also the ‘offering or promising’ of a bribe, or the ‘requesting or agreeing to receive’ – not only
actual payment / receipt
•
Amounts are irrelevant, it does not matter how small the amount, it is the intention that counts
.
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Bribery and Corruption
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Response Test #5
Bribery Scenario
Your senior contact at a government agency, that has been regularly bought products
and services from Mobily, calls you to say that he has established a charity to provide
medical care to infants, and asks you to make a respectable contribution to help the
charity get off the ground. You know that this agency has recently announced a public
tender for a major data warehouse and collocation project.
Q. How do you respond?
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Business Code of Conduct
Dealing with Confidential Information
“During and after employment, every employee is responsible for
ensuring that propriety information is protected from theft,
unauthorized disclosure or inappropriate loss”
Applies to both formal documents (letters, memo’s reports) and
informal documents (emails, notes).
Includes Mobily business, financial, marketing, and service plans;
and Customer & employee data.
Do
Do not
Take care when using portable
telecommunication devices
Use non-disclosure agreements
Consult / report to Legal
Department
× Discuss sensitive information in
public places
× Leave your computer or device
unlocked and unattended
× Take sensitive work documents
home unless approved by a
Manager
Be conscious of what documents you leave on your desk, and secure materials overnight
For further information on Confidential Information, refer to section 10.3 of the Mobily Business Code of Conduct21
Business Code of Conduct
Email and Internet Use
“The company will not tolerate discriminatory, offensive,
defamatory, pornographic and other similar types of messages or
materials sent by email or accessed through the internet”
Have no expectations of privacy with respect to any
communications through Mobily’s communication systems
Mobily reserves the right to monitor and inspect, at any time and
without notice, all electronic communications and information on
computers used in the company’s business.
Do
Do not
Use extreme caution when you
send and receive confidential
information in email.
Beware of ‘Reply All’ emails
Consider your language and
tone in your emails
Report any instance where
improper emails are circulated
× Use the internet for personal use
whilst working
If you accidentally send confidential information to the wrong people, you could cause great damage
For further information on Email and Internet Use, refer to section 7.7 of the Mobily Business Code of Conduct
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Business Code of Conduct
Reporting obligations and ‘No Retaliation’ policy
“If you have been involved in a possible violation of the Code, or if
you witness or learn of a potential violation of the Code, you must
report this matter immediately”
To the extent possible, Mobily will keep report confidential. You
can report anonymously
Retaliation, retribution or harassment against an employee who
make a reports in good faith is prohibited.
Do
Do not
Report in good faith ethical
breaches
Consider other reporting
mechanisms (reporting through
normal management structures)
Provide as much information as
possible
× Make malicious allegations
× Retaliate or discriminate against
persons reporting
Mobily will use it’s best efforts to investigate code compliance matter professionally to all concerned
For further information on Reporting Obligations, refer to section 14 of the Mobily Business Code of Conduct
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Response Test #6
Expense Scenario
Your supervisor enters your office and asks you for to submit an expense claim for him
for SAR 650.00 of expenses he tells you he incurred entertaining a client the previous
evening. He submits receipts from a restaurant, and indicates that there were 2 people
dining. At lunch your supervisor’s wife stops by to drop in a document, and you
overhear her telling the receptionist what a great time she had at dinner with your
supervisor the night before.
What do you do?
A.
Do nothing
B.
Confront him
C.
Report it to the Mobily Ethics Hotline
D.
Tell your colleagues and hope they do something about it
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Response Test #7
Reporting and Confidentiality
You have overheard one of your colleagues making a call to the Mobily Ethics Hotline in
which he made an allegation about a supervisor that you both work for. You have no
knowledge of the allegation. What would you do?
A.
Do nothing
B.
Have a quiet conversation with the colleague making
the allegation
C.
Inform the supervisor that he is under suspicion
D.
Discuss with your closest colleagues to see if they
know anything about the allegation
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Section 3:
Whistleblowing
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Whistleblowing
Mobily Ethics Hotline - Whistleblowing Facility
“Enables a person who is aware of an unethical practice to report
their concerns without necessarily informing their supervisors and
without revealing their identity, if they choose to do so.”
Call: 0560311477
E- Form on Intranet
Email: [email protected]
It is not acceptable to discriminate, disadvantage or adversely
treat a person’s employment or career for the purposes of reprisal
for a disclosure made pursuant to the Whistleblowing Policy.
Do
Do not
Report in good faith ethical
breaches
Consider other reporting
mechanisms (reporting through
normal management structures)
Obtain as much information as
possible
× Use Ethics Hotline to report HR
issues, grievances, or general
concerns or suggestions
× Make malicious allegations
× Discuss disclosures with
colleagues
× Retaliate or discriminate against
whistleblowers
The Mobily Ethics Hotline is not be used for malicious, slanderous or abusive calls.
For further information on Whistleblowing, refer to the Whistleblowing Policy
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Whistleblowing – Categories of Misconduct
Unethical Behavior
The range for behaviors that can be considered unethical is very broad. It can be anything from wasting
time which an employee is being paid, to committing a million dollar fraud. The type of misconduct that
can be reported through the Mobily Ethics Hotline include:Giving or accepting bribes, kickbacks, or inappropriate gifts
Misuse of confidential information
Stealing, theft, or fraud
Misusing your position in Mobily and influencing others to your personal advantage.
Abusive or intimidating behavior
Misreporting actual time or hours worked
E-mail and Internet abuse
Discrimination on the basis of race, color, gender, age, or similar
A situation that places employee interests over company interests
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Section 4:
Guide to Ethical Decisions
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Guide to Ethical Decisions
Employees should always seek the advice of his/her manager
or ethics officer where there is any question in their mind on
whether their decision is appropriate.
Ethical Dilemma
Q1
Yes / Maybe?
Is this illegal?
(country & local laws)
No
Decision appears appropriate
No
Q6
Could this impact Mobily
if all our employees
did this?
Yes / Maybe?
STOP & CONSULT
Yes / Maybe?
No
Q5
Would you feel concerned
if this appeared as a
newspaper headline?
Yes / Maybe?
Yes / Maybe?
Q4
Could this adversely impact any
Mobily stakeholders?
No (customers, shareholders,
employees, suppliers)
Q2
Does this contradict with
Mobily Business Code of
Conduct or other policies?
No
Yes / Maybe?
Q3
No
Does this conflict with our
Values and our Culture?
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Section 7:
Conclusion
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Business Ethics
Conclusion

Ethical business behaviors are essential to the success of Mobily

Mobily has implemented a Business Code of Conduct and Ethics

All Mobily employees must be aware of the code and uphold it at all times

Stick to the Guideline for Ethical Decision Making

When in doubt as to a course of action, consult with your manager / supervisor
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Business Ethics
Any Questions?
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Thank you!
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