ALKRA TECHNOLOGIES FZ-LLC
 

 

 

1. PREAMBLE  

The present document consists of three parts:

• The first part states our ethical values and principles of conduct.
• The second part describes the behavioural we expect from our employees and contractors respecting our values, all regulations and current laws.
• The third part defines our commitments to
• our shareholders,
• our suppliers,
• our employees and contractors,
• and to the countries we are based or operate in.
•  ALKRA TECHNOLOGIES works together with companies present in many countries and many professions, all of whom contribute to the same mission:

RESPOND TO THE INCREASE IN HEALTHCARE NEEDS THROUGHOUT THE DEVELOPING WORLD BY PROVIDING CUTTING-EDGE TECHNOLOGY AND KNOW-HOW TO RESULT IN BETTER CARE.

Our ethics policy is based on 5 values that demonstrate our willingness to sustainably grow and operate in line with our social and corporate responsibilities.

These values are:

• respect for the individual and tolerance,
• respect for human values, 
• performance,
• integrity,
• diversity and multiculturalism.

Each employee or contractor is a stakeholder of the respect to and the application of these values.

The present document also provides a practical approach of the behaviours and obligations one should have in professional situations, and particularly concerning the following:

• respect for the law,
• conflicts of interest,
• political activities,
• corruption,
• gifts,
• assets protection,
• confidentiality,
• public expression,

THE RECOMMENDATIONS IN THIS DOCUMENT ARE NO SUBSTITUTE FOR EXISTING CONVENTIONS, LAWS OR REGULATIONS ON AN INTERNATIONAL OR NATIONAL SCALE, BUT THEY COMPLETE THEM.

In case of doubt on how to behave in a given professional situation, any employee or contractor of ALKRA TECHNOLOGIES is encouraged to ask for advice within their hierarchy.

Finally, the implementation of this ethics and conduct policy implies that any employee or contractor of ALKRA TECHNOLOGIES, or any external person, must have an easy access to the alert procedure to report an individual or collective lack of respect for the values, regulations or laws.

For every employee or contractor, a solution to report an ethical or a conduct issue concerning an immediate

superior or a higher hierarchic level is available.

 

2. OUR VALUES

We respect and promote, as individuals and as a company, the following values:

Respect for the Individual and Tolerance
The respect for the individual is the core of our ethics policy. The individual rights govern our relations with each other. We advocate dialogue which instigates trust and openness to other cultures.

This continuous dialogue within the organization aims to deliver a win-win situation for us and our employees or contractors.

Performance

We put the performance of our employees in carrying out their profession and the performance of the company in each of its activities at the service of our client.

The value thus created through cooperation and work in networks of the employees and the company, contributes to the profitable and sustainable growth of ALKRA TECHNOLOGIES. This should benefit everyone, our customers, employees, contractors, shareholders, business partners and the community.

Integrity

As employees and contractors of a company working with different interests, our integrity forms an important part of our conduct policy.

It excludes any form of corruption and recommends acting with righteousness, honesty and transparency.

Diversity and Multiculturalism

ALKRA TECHNOLOGIES is an international company based on the cultural and intellectual wealth of the entirety of its partners.

This leads to the encouragement of international flexibility with local hiring and promotion of multicultural teams in order to better apprehend a growth free of borders. 

3. OBLIGATIONS OF OUR EMPLOYEES AND CONTRACTORS

Every employee and contractor of ALKRA TECHNOLOGIES commits to respect the principles described thereafter.

Respect for the Law

ALKRA TECHNOLOGIES complies with national and international legislations and conventions.

ALKRA TECHNOLOGIES ensures that all ethics and conducts standards are respected, considering the context, particularly social, through its activities or the activity of its partners or subcontractors.

This is the framework which makes each employee and contractor of ALKRA TECHNOLOGIES commit to comply with the laws and regulations of every country they engage with, with a focus on responsibility, integrity and professionalism.

Conflict of Interest

An employee or contractor could face the risk of conflicts of interest if their personal interest happens to impact the impartial and objective performance of their professional activities.

This personal interest of the employee or contractor includes any benefit for themselves or in favour of relatives, friends, individuals or organizations with which they have any working or political relationship.

It also includes all civil or financial obligations which the employee or contractor might be subject to.

Conflicts of interest can emerge from different circumstances, such as: 

• Personal connections that an employee or contractor has with a third party currently in business with ALKRA TECHNOLOGIES or in competition with ALKRA TECHNOLOGIES. Such connections can result from:
  • a financial participation an employee or contractor would have with a customer, supplier, services provider, partner or competitor of ALKRA TECHNOLOGIES,
• a beneficial employment they would be engaged with on behalf of a third party, for instance, as an employee, consultant, representative, etc.,
• an operation in which they could find themselves personally and directly or indirectly involved with, in working relations with this third party, for example as a result of the negotiation or execution of a contract in which they are a party.
• The offering of gifts or benefits from a third party which they are in contact with as employee or contractor of ALKRA TECHNOLOGIES.
• The pursue of a public activity that could interfere with ALKRA TECHNOLOGIES’ activities.

In such situation they commit to, in the interest of loyalty and transparency, immediately inform their superior, who will have to make the appropriate decisions in order to comply with the law whilst preserving the interests of ALKRA TECHNOLOGIES.

Political Activities

ALKRA TECHNOLOGIES commits itself to adopt, anywhere it is present, a neutral political attitude, particularly by refusing to support any political group.

This neutrality is a necessary condition for healthy and long-lasting relations, built on values like transparency and mutual respect, to be tied between ALKRA TECHNOLOGIES and the elected representatives it is in contact with.

More generally, ALKRA TECHNOLOGIES will ensure that no event it would organize can be interpreted as a direct or indirect privileged support towards a political party or any other group of influence.

The involvement of an employee or contractor in any political responsibility is strictly personal. These activities can only be pursued outside the workplace and the workhours. Moreover, no one should, in any case, make use of ALKRA TECHNOLOGIES’s image to support their involvement.

No employee or contractor shall involve his company in a partisan position, nor use their position within ALKRA TECHNOLOGIES to back up their opinion. 

Corruption and Bribery, Public officials [1]

Whatever commercial or financial interests are at stake, ALKRA TECHNOLOGIES ensures that its resources and assets are not used for corruption purposes. Because of its activities in development, construction and response to call for tenders, which may require contacts and authorizations from local communities or national or international bodies, ALKRA TECHNOLOGIES seeks to fight public agents’ corruption.

Every employee or contractor of ALKRA TECHNOLOGIES who wishes to get a third party to contract with an entity of ALKRA TECHNOLOGIES must not use any kind of active or passive corruption.

No employee or contractor of ALKRA TECHNOLOGIES shall have any of the following practices, at any time and in any form, in relation with a public pfficial¹ at an international, national or local level, a political party, party official or candidate to political office:

• bribery (offering, promising, giving, authorizing or accepting any undue pecuniary or other advantage to, by or for any of the persons listed above in order to obtain or retain a business or other improper advantage, e.g. in connection with public procurement contract awards);
• extorsion or solicitation (demanding of a bribe whether or not coupled with a threat if the demand is refused);
• trading in influence (offering or solicitation of an undue advantage in order to exert an improper, real or supposed influence with a view of obtaining from a public official an undue advantage for the original instigator of the act or for any other person);
• laundering the proceeds of the corrupt practices mentioned above.

A search of background and reputation will be conducted for any intermediary or facilitator:

• review of previous achievements if any,
• research of the company and/or the individual on lists of sanctions, such as World Bank Debarment List, Development Aid sanction lists, or any other public list.

Moreover, the relationship shall require a contractual framework stipulating:

• the nature of the service,
• the expected targets,
• the levels and conditions of remuneration,
• the commitment to the respect of the present code.

The contract shall be signed only by the persons entitled to engage the contracting parties.

In case of doubt on the conduct to adopt, the employee or the contractor of ALKRA TECHNOLOGIES will seek advice from their superior in charge and, in case of discovering or suspecting a corrupt practice, will report in writing to them (“Alert Procedure”).

Gifts

No employee or contractor of ALKRA TECHNOLOGIES must accept or solicit any gift, any favour or invitation, as well as any other benefit for himself or anyone else, coming from persons or organizations which the employee or contractor has or had business relations with, that could impact the impartiality which their functions are carried out with or constitute a reward related to their activity.

This also excludes gifts under the form of money in cash or exchangeable for money in cash.

This does not exclude common acts of courtesy or hospitality, or symbolic or small gifts, or invitations with professional training or information purposes.

Assets Protection

ALKRA TECHNOLOGIES possesses material assets (premises, working tools, etc.) and immaterial assets (image, reputation, information) that must be preserved and valued.

Every employee or contractor of ALKRA TECHNOLOGIES must try, by any legal and appropriate means one disposes of, to prevent any event that would harm ALKRA TECHNOLOGIES’ assets, material or immaterial, and should naturally not be found guilty of such actions.

Everyone must ensure that the company’s assets are used only for professional purposes.

Confidentiality

Every employee or contractor may detain information belonging to ALKRA TECHNOLOGIES that should be kept confidential if its disclosure or premature revelation could be damaging to ALKRA TECHNOLOGIES’ interests.

Such information could be related to products, studies, technical projects, industrial data, financial and commercial data, and more broadly, any information that one might acquire in the course of his functions.

Every employee or contractor, other partner or service provider will respect the nondisclosure commitment of partial or general information concerning the development or the strategy of ALKRA TECHNOLOGIES, whether verbal, in writing or electronically.

Every contractual or pre-contractual relation will be subject to a confidentiality agreement between ALKRA TECHNOLOGIES and the third part in question.

An employee, a contractor, a business partner or a service provider of ALKRA TECHNOLOGIES should always be aware of the necessity to withhold confidential information from third parties.

However, every employee will make sure that the information flow required for proper works execution happens appropriately, either internally or externally, and will check its accuracy at all times.

These obligations are permanent during the contractual relation and will carry on for five years after the end of the contractual relation between the employee, the contractor, any other business partner or service provider and ALKRA TECHNOLOGIES.

Any disclosure of confidential information that could harm the development of ALKRA TECHNOLOGIES states a serious misconduct and will be subject to appropriate measures.

ALKRA TECHNOLOGIES retains the right to press charges against any person or organisation infringing this provision.

Public Expression

Publicly taking position on behalf of ALKRA TECHNOLOGIES is a responsibility that cannot be taken without prior internal approval.

Every employee or contractor mandated to represent ALKRA TECHNOLOGIES must behave professionally and maintain the coherence of ALKRA TECHNOLOGIES’s image and expression (compliance with values, corporate strategy, corporate identity, corporate signature policy). 

They will ensure that information is indeed shared and understood by all involved.

Every employee or contractor, whose position involves a permanent duty of non-disclosure, should show restraint when publicly expressing themselves about public authorities, the company, its managers, its employees or its contractors. 

Harassment

The proper implementation of the company’s mission implies that each employee or contractor of ALKRA TECHNOLOGIES operates in a positive work environment, particularly free of any pressure or persecution of a morale nature or any action considered as sexual harassment.

ALKRA TECHNOLOGIES commits to take all steps necessary to prevent and punish any action of this kind, particularly by requiring its managers and senior employees to show appropriate behaviour and attentive listening.

Every employee or contractor of ALKRA TECHNOLOGIES must make sure that their actions are not violating their colleagues’ rights or dignity, impacting on their physical or mental health, or compromising their professional future.

Everyone must be aware of the fact that this kind of behaviour is prohibited and will, depending on the country, be subject to heavy disciplinary and/or penal sanctions.

 4. OUR COMMITMENT TO SUPPLIERS

In order to maintain our values we select the following collective action principles for our suppliers:

Observe our subcontractors practices on respecting the law, health and safety, ethical behaviour and respect for the environment

ALKRA TECHNOLOGIES informs the subcontracting companies and consultants they call upon that they expect absolute compliance with the law and the current international standards (for example concerning the prohibition of child labour).

ALKRA TECHNOLOGIES’ requirements are particularly related to:

• compliance with the law,
• health and safety of the employees and contractors,
• ethical conduct towards customers, and particularly respect for the individual and integrity,
• respect for the environment.

Any failure deemed significant and not corrected after observations, regarding the respect for legislation, health and safety of the employees and contractors, ethical conduct towards customers and respect for the environment, may result in a cancellation of the relations with the subcontracting company, in compliance with contractual obligations.

More specifically, with regards to the safety of employees of subcontracting companies, reporting of workplace accidents for projects they are assigned to might be requested.

Guarantee the respectful and fair treatment of all suppliers

Guarantee transparency, impartiality and fair treatment in consulting as well as in contract awarding.

Ensure the confidentiality of the exchanged information.

Base the supplier selection on an objective evaluation of the suppliers - price and capability - aimed at the quality of the products purchased.

Ensure the protection of our subcontractors staff at our project sites

Ensure health and safety for the people on site through the strict compliance with current regulations.

Ensure that all subcontracting companies’ staff is protected through the application of measures that identify the work conditions regulated by applicable laws.

Establish integrity in our common language

Allow each supplier to build its trust in ALKRA TECHNOLOGIES on the integrity of its employees and organisation.

Communicate the present code of ethics and conduct throughout the company, control and condemn, if necessary, any violation of our principles.

Ensure that each employee or contractor pursuing purchasing activities applies adapted regulations for different situations and follows all behavioural principles.

Establish with our suppliers, in all integrity, balanced contractual relations that allow concluding contracts respected by everyone.

In every country, ask to refuse, like we do, child labour, and more generally apply the fundamental rights defined by the International Labour Organisation.

5. OUR COMMITMENT TO EMPLOYEES AND CONTRACTORS

In order to maintain our values, we select the following collective action principles for the relationship with our employees and contractors: 

Ensure Health and Safety

ALKRA TECHNOLOGIES prioritises the health and the safety of its employees and contractors.

Maintaining good working conditions and taking human factors into account are an everyday concern, as well as the economic performance, the respect for the environment and our customers’ satisfaction.

ALKRA TECHNOLOGIES must create a work environment favourable to the safety and the physical and mental health of every staff member, whatever their functions and the risks exposed to might be, in compliance with the regulations.

Adapt employees career paths: training and mobility

ALKRA TECHNOLOGIES aims to recognise and to promote the versatility of its employees.

To do so, ALKRA TECHNOLOGIES will strive to make, throughout their employees entire professional career and regardless of their category, adapted programs available to them:

• information about the evolution of their profession and organisation evolution including available positions,
• continuous training to prepare them for new positions and new technologies, 
• skills and potential development, establishing permanent progress and training.

When a change of role is asked from an employee, because of a development within or outside the company, methods that favour adaptation and change management will be searched, notably through appropriate training and information.

When a change of role is asked by the employee himself, ALKRA TECHNOLOGIES commits to support them through the different steps, by considering the skills and capacities of the applicant as well as the needs and constraints of the company.

This flexibility allows the employee to enrich their career and life path with new experiences.

Avoid any form of discrimination

ALKRA TECHNOLOGIES is focusing on three specific areas:

Professional equality between men and women: ALKRA TECHNOLOGIES will engage voluntary measures to ensure no discrimination in the career paths, in the access to positions of responsibility, and the rates of remuneration for equivalent work.

Promotion of disabled workers: ALKRA TECHNOLOGIES will develop a policy for employing workers with disabilities. In the case of the occurrence or the evolution of a handicap, ALKRA TECHNOLOGIES will look for the best solution to adapt the workplace to the employee’s specific needs.

Origin (ethnical, national, cultural, religious, familial, regional, etc.) should never be a motive to deny anyone a job opportunity.

In the same way, no position should be reserved or forbidden to an employee or contractor because of their origin. This includes the efforts to promote diversity within the work teams.

6. OUR COMMITMENT TO COUNTRIES WE OPERATE IN

ALKRA TECHNOLOGIES respects the sovereignty of the countries in which we are present, either in the form of project owner or as a business partner.

ALKRA TECHNOLOGIES commits to never take part in a country’s politics. We should not make any public declaration promoting one or other political tendency, nor should we finance any political action or party whatsoever.

However, since ALKRA TECHNOLOGIES is an actor in the economic development of the countries it is based in or works in, we can express our positions on the following to the authorities:

• matters concerning our activities or our shareholders, 
• aspects of ethics and conduct, particularly in regard to human rights.

Alexander Kraus
Director and CEO
March 2021 

 

[1] “Public official” refers to the definition of the US Foreign Corrupt Practices Act (FCPA) of 1977, the UK Bribery Act of 2010, OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (1977), and any similar law or regulation.