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Business EthicsInductee Training Session
2
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
Inductee Training Session - Objectives
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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
Business Code of Conduct & Ethics
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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 .
Business Code of Conduct
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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.
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
DoSpeak positively about MobilyTreat everyone with honesty,
fairness, and respectTake pride in yourself, your
colleagues, and our companySmile!
Do not× Do anything that may bring
Mobily into disrepute× Disrespect a person even when
they are disrespecting you
Business Code of Conduct
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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.
DoCare for company property, and
report any misuse or misappropriation
Ensure that all property is properly stored and secured when not in use
Do not× 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
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
Response Test #1.1
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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
Response Test #1.2
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Business Code of Conduct
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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.
DoGet approval from Manager
prior to accepting invitations to events or functions
Return delivered gifts to donor
Do not× 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
Gifts and Favors Scenario
Response Test #2
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Can you receive this gift?
• If yes, when?
• If yes, what must you do?
• If not, why not?
• If not, how would you say ‘no’?
• What do you do if you are unsure?
Scenarios
A pen?
Dinner?
A car?
2 tickets to a major sport event?
A trip for you to Dubai?
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
Response Test #3
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Business Code of Conduct
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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
DoDisclose any direct or indirect
interest that you or you family may have in an undertaking that either competes with, or supplies to Mobily
Do not× 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
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?
Response Test #4
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Fraud Awareness
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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.
Business Code of Conduct
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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.
DoReport any inappropriate
approaches to your Manager / supervisor, or Ethics Hotline at the earliest opportunity
Do not× 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
Bribery
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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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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?
Response Test #5
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Business Code of Conduct
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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.
DoTake care when using portable
telecommunication devicesUse non-disclosure agreementsConsult / report to Legal
Department
Do not× 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 Conduct
Business Code of Conduct
22For further information on Email and Internet Use, refer to section 7.7 of the Mobily 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.
DoUse extreme caution when you
send and receive confidential information in email.
Beware of ‘Reply All’ emailsConsider your language and tone
in your emailsReport any instance where
improper emails are circulated
Do not× Use the internet for personal use
whilst working
If you accidentally send confidential information to the wrong people, you could cause great damage
Business Code of Conduct
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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.
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
DoReport in good faith ethical
breaches Consider other reporting
mechanisms (reporting through normal management structures)
Provide as much information as possible
Do not× Make malicious allegations× Retaliate or discriminate against
persons reporting
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
Response Test #6
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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
Response Test #7
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Section 3:
Whistleblowing
Whistleblowing
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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: 0560311477E- Form on IntranetEmail: [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.
DoReport in good faith ethical
breaches Consider other reporting
mechanisms (reporting through normal management structures)
Obtain as much information as possible
Do not× 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
For further information on Whistleblowing, refer to the Whistleblowing Policy
The Mobily Ethics Hotline is not be used for malicious, slanderous or abusive calls.
Whistleblowing – Categories of Misconduct
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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
Guide to Ethical Decisions
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Decision appears appropriateDecision appears appropriate
Is this illegal?(country & local laws)
Does this contradict withMobily Business Code of Conduct or other policies?
Does this conflict with ourValues and our Culture?
Could this adversely impact anyMobily stakeholders?
(customers, shareholders,employees, suppliers)
Would you feel concernedif this appeared as a
newspaper headline?
Could this impact Mobilyif all our employees
did this?
Yes / Maybe?
Yes / Maybe?Yes / Maybe?
Yes / Maybe?
Yes / Maybe?Yes / Maybe?
No
No
NoNoNo
No STOP & CONSULT
Q1
Q2
Q3Q4Q5
Q6
Ethical Dilemma
Q6
Q5 Q4 Q3
Q2
Q1
No
No No No
No
No
Employees should always seek the advice of his/her manageror ethics officer where there is any question in their mind on whether their decision is appropriate.
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Section 7:
Conclusion
Business Ethics
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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
Business Ethics
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Any Questions?
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Thank you!
