Careers

Policies

Anti-Bribery, Corruption and Fraud Policy

Scope

This Policy is applicable to every Employee(s) including senior management and members of the Board of Directors. The requirements under this Policy also extend to intermediaries, suppliers, service providers, consultants or vendors doing business with the Company.

ESG

Definitions of key terms

Bribery:

“Bribery is an offence, committed intentionally comprising of a promise or offer to any person, or the solicitation or acceptance by any person, directly or indirectly, of an undue advantage, for the official himself or herself or another person or entity, in order that the official act or refrain from acting in the exercise of his or her official duties”.

In simple terms, Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s view or conduct or to obtain an improper advantage.

Bribery can take many forms, such as;

  • Making or receiving cash payments
  • Social benefits
  • Giving or receiving in kind or expensive gifts
  • Giving or receiving travel benefits, hospitality
  • Quid Pro quo – means a favor or advantage granted in return for something
  • Loans
  • Discounts
  • Services
  • Award of a contract

Corruption:

Corruption can be defined as a lack of honesty and integrity in one’s action or inaction; the misuse or abuse of a position for personal gain. This can also include any benefit enjoyed by someone other than the person involved in the corruption, for example a family member or colleague.
Corruption includes bribery, embezzlement / misappropriation of funds / properties, conducting business under influence, abuse of power and functions, illicit enrichment of person’s wealth and properties.

Fraud:

Fraud is an intentional deception to secure unfair or unlawful gain, or to deprive a victim of a legal right. Fraud can violate civil law (e.g., a fraud victim may sue the fraud perpetrator to avoid the fraud or recover monetary compensation) or / and criminal law (e.g., a fraud perpetrator may be prosecuted and imprisoned by governmental authorities). The purpose of fraud may be some monetary gains or other benefits.
Fraud includes deception, forgery, extortion, bribery, corruption, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts and collusion. The types of corporate frauds include procurement fraud, theft of cash, physical assets or confidential information; misuse of accounts; financial accounting misstatements; inappropriate journal vouchers; false employment credentials; fraudulent expense, benefit or claims; malign data, data manipulation, data theft by transferring, copying, leakage etc.
Internal Fraud relates to Fraud as mentioned above perpetrated by staff or their representatives and may include falsifying books, records, concealing payments or misrepresenting payments.
External Fraud relates to Fraud as mentioned above perpetrated by associated persons, counterparties or unrelated external persons and may include making a false claim under a policy or attempting to divert funds.

Policy Statements

  • The Company has zero-tolerance to Bribery, Corruption and Fraud and is committed to undertaking its business in a fair and transparent manner
  • Company prohibits offering, soliciting, or accepting any Bribe (whether in cash or other financial benefit), to or from any person or company, and whether they are a public official/body or private person/company, to gain commercial or personal advantage.
  • An act of Bribery not only by an Employee(s) but also any other person acting on behalf of the Company or representing the Company, is prohibited.
  • Bribery payment through third party is also prohibited in the Company.
  • Facilitation payments must not be made unless an Employee(s) faces a life-threatening situation. In such cases, the Employee(s) shall notify the Company immediately of the threat and of about the payment and other details.
  • Employee(s) must exercise reasonable due diligence corresponding to the risk perceived with respect to bribery, corruption, and fraud in all business transactions with customers and third parties to prevent and detect bribery, corruption, and fraud. A reference to this Policy may be made in the business contracts executed with counterparties.
  • All business transactions must correctly record both the amount and a written description of any transaction with required disclosure and transparency as per applicable recognized standards. Employee(s) must ensure that there is a reasonable relationship between the substance of a transaction and how it is described in the Company’s books and records.
  • If any Employee(s) becomes aware of bribery, corruption or fraud being conducted at present or in the past, must inform the Compliance Head or report through the Whistleblower channel. The Employee’s identification and interest will be protected under Whistleblower Policy of the Company.
  • If any Employee(s), under coercion or undue influence from colleagues, is made to offer any bribery or facilitation payments or receive any undue monetary or other benefits. must inform the Compliance Head or report through the Whistleblower channel. The Employee’s identification and interest will be protected under Whistleblower Policy of the Company.
  • No political contributions are made from or on behalf of QIC Group.
  • Employee(s) involved in bribery, corruption and fraud offence are liable for termination. The Company can also initiate the civil and criminal proceedings against the Employee(s) and proceed to recover financial loss incurred to the Company from the Employee(s) and associated parties found in violation of this policy.
  • Department Heads across all departments are responsible to ensure that proper internal controls, checks and balances, supervision, and oversight are exercised in the business processes to prevent and detect bribery, corruption, and fraud. The primary responsibility to ensure the existence and maintenance of an effective and efficient systems rests with the front-line management.
  • The Employee(s) and their supervisors have the responsibility to conduct due diligence in every business transaction and check for red flags, if there exists one.
  • The possible red flags include requesting cash payments, payments to third parties instead of the main party in the business contracts, abnormally high commission, or contract rewards than what is reasonable, issuing policies on credit and payment pending since long / bad debts, contractors / suppliers providing no actual service than just facilitating, Employee(s) or external parties insisting on urgency or confidentiality and so on.

Gifts & Hospitality

  • Company recognizes the importance of hospitality for establishing goodwill within business relationships. However, all Employee(s) must exercise caution either when accepting or providing gifts and hospitality.
  • This Policy applies to provision and/or receipt of gifts and/or hospitality and Employee(s) shall not accept or provide such gifts and/or hospitality that are not reasonable or above the material threshold limit.
  • The material threshold limit for a gift or hospitality is fixed for one financial year either in one transaction or in series of transactions taken together. If it exceeds the material threshold, Employee(s) shall escalate for approval to the next level, not less than the Pillar Heads level.
  • However, in case an Employee(s) receives such a gift and is unable to return it as it may affect the business relationship, the Employee(s) shall immediately disclose it to the Compliance Officer of the Company.
  • The Compliance Officer shall maintain a register for recording transactions of the nature contemplated in this Para 4, provided they are excessive or above the material threshold limit.

Modern Slavery Policy

Scope

This Policy is applicable to every employee including senior management and members of the Board of Directors and Group-entities.
The requirements under this Policy also extend to intermediaries, suppliers, service providers, consultants, and all the other supply chain partners who are directly or indirectly doing business with the Company.

ESG

Definitions of key terms

Modern Slavery have been defined in two terms as below:

Forced Labour:

Any work or service that is exacted or exploited from any person under the menace of any penalty, fear, or coercion and to which the person has not offered himself or herself voluntarily or is not as per terms of employment contract. It refers to situations in which persons are coerced to work using violence or intimidation, or more subtle means such as manipulated debt, retention of identity papers or under paying or threats of denunciation to immigration authorities or blocking free movement.
Exploitation shall include, at a minimum, prostitution of others or other forms of sexual exploitation or the removal of organs, slavery or practices similar to slavery like compensating lesser than others for the same work and output or discriminating on the basis of appearance, color, gender or race.

Human Trafficking:

Human trafficking shall mean the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Policy Statements

  • Company has zero tolerance to Modern Slavery in whatever shape and form it may present in.
  • The Company prohibits Modern Slavery in all shapes and forms across its group-entities as well as supply chain partners, intermediaries, investment companies, investment managers, service providers, consultants and all the other partners including but not limited to second tier supply chain partners.
  • Any contract entered by the Company with supply chain partners, intermediaries, service providers, consultants, investment managers, investee companies and others, requires an explicit clause obliging them to comply with the applicable or equivalent regulations prohibiting Modern Slavery, if they do not have an official Policy on Modern Slavery in line with this Policy.
  • The Company prohibits engaging with parties who have been convicted of Modern Slavery by recognized international organization or local legal and regulatory authorities or based on suspicion of violation of this policy.
  • The Company neither charges itself nor allows recruitment consultants to charge any recruitment related cost, commission, visa or travel / hotel expenses to the Employees.
  • The Company prohibits any ambiguity, misrepresentation, or manipulations whatsoever in making any offer for employment. Offer Letter is designed to bring in clarity, consistency, and transparency in terms of identified job description, compensation break-up, working location, probation period, brief terms of employment etc.
  • The terms of notice period in the employment contract are designed to provide fair and equitable protection to the interests of every Employee(s) that allows smooth transition of employment, subject to any regulatory norms.
  • Based on the job role and seniority of an employee, in specific situations a non-Compete clause with a reasonable non-compete period in the employment contracts is inserted to protect the interest of the Company from a competing company during the non-compete period operating in the same industry, subject to any regulatory norms.
  • The Company does not hold any money deposits or retain or withhold any personal documents, educational certificates, or passport of
  • The Company ensures full rights and benefits of Employee(s) as per local labor legislations and duly honors immigration related rules.
  • The Company ensures that no Employee’s freedom of movement is regulated, curtailed, or blocked, after duty hours.
  • The Company facilitates free movement of Employee(s) within or outside the country as per prior approved leave and travel benefits to ensure non-interruption to business operations, subject to applicable local law and regulation.
  • The Company provides a hygienic, healthy, and safe environment for the Employee(s) and allows effective collaboration among colleagues to execute the job efficiently.
  • The Company encourages Employee(s) to maintain proper work balance and work within the official duty hours, however, to meet exceptional business exigencies, the Company has a policy to compensate for the extra hours worked.
  • The Company prohibits psychological, economical, or violent threats, intimidation, bullying, in violation of which disciplinary action or legal prosecutions are initiated.
  • The Company is neutral to appearance, color, gender, race, or origin of Employee(s) in terms of fixing compensation. The Company encourage fair compensation to all Employees and do not target any group or Employee or adopt subtle means to underpay.
  • The Company has a pre-determined day for release of monthly salary to pre-approved bank accounts of the Employees every month, as per the payroll cycle and prohibits any withholding or deductions or over-dues in violation of the employment contract, subject to local labour laws.

Code of Conduct

1. Code of Conduct

    1. QIC offers a secure and positive work environment to encourage employees to give their best and in turn expects employees to adhere to certain ethical and cultural values and project an image of integrity and professionalism.
    2. QIC conducts its business with honesty and integrity, and with respect for the interests of its business partners and employees. All employees are expected to follow the provisions listed herein.

2. Rights of an Employee

QIC has the right and obligation to provide all employees with:

    1. A safe and healthy work environment, free of harassment.
    2. Appropriate guidelines and supervision.
    3. The equipment required to perform their duties.
    4. Relevant training and development to improve their ability to perform their duties and to develop them for other possible positions within QIC.
    5. Regular appraisal of their performance through a structured performance Management system in a fair and transparent manner.
    6. Remuneration and benefits commensurate with the duties and responsibilities assigned to the role and consistent with the remuneration policy of QIC.
    7. Respect due to any person in the organization and to business associates and visitors alike; and
    8. Confidential safekeeping of personal information.

3. Obligations as an Employee

Employees on the other hand are expected to:

    1. Apply their knowledge, skills, and judgment to the best of their ability to perform the requirements of the job.
    2. Maintain effective working relationships with other employees.
    3. Support QIC’s values and mission.
    4. Provide the highest standard of professional service.
    5. Continually strive for improvement in the proficiency and effectiveness of their work for QIC.
    6. Maintain confidentiality over QIC’s affairs both while employed and after the termination of employment, for whatever reason.
    7. Ensure the security of QIC property, data, and information.
    8. To conduct themselves responsibly in all dealings with third parties and other staff.
    9. Declare any personal interest that they may have in a supplier’s business.
    10. when at a third party’s premises, conform to their rules and requirements where these are not contrary to those of QIC; and
    11. Report any unethical approach made to or known by them in connection with QIC business.

4. Respect at Work

    1. It is the policy of QIC to maintain a professional and ethical business environment and workplace, with due respect to the customs and values of different cultural groups and nationalities.
    2. Behavior of a disrespectful, discriminatory, or harassing nature has no place in the work environment and will not be tolerated.
    3. Each individual has the responsibility for maintaining acceptable standards of personal behaviour and for assuring that others have the opportunity to carry out their work assignments in a business-like atmosphere, free from discrimination.
    4. In case of alleged discrimination or harassment incidents, the affected individual should bring the matter immediately to the attention of their line manager and the HRD. QIC will assure that the matter will be handled in a confidential, fair, and professional manner, which will respect the rights and privileges of all parties involved.
    5. Employees shall treat all persons fairly regardless of such factors as race, colour, national origin, sex, marital status, age, religion, political belief, or physical status.

5. Health, Safety and Environment

    1. QIC is committed to running its business in an environmentally sound, safe, and sustainable manner and expects all employees to take appropriate action and promptly report any hazardous situation.
    2. QIC shall issue appropriate personal protective equipment and shall have safety work instructions for all hazardous activities.

6. Smoking

QIC has a “no smoking policy” inside its company premises. Smoking is only allowed in designated areas, outside the buildings.

7. Alcohol and Substance Use

    1. The possession, use, distribution, or sale of any alcoholic beverage or prohibited substance on QIC property or whilst conducting QIC’s business is strictly prohibited.
    2. In case of a suspicion of violation, QIC has the right to demand alcohol and/or drug test of the employee.

8. Dress Code

Personal appearance and attire must reflect a professional work environment and shall conform to the rules of decency in accordance with local customs.

9. Confidentiality

Employees shall maintain the utmost confidentiality with regard to QIC and its client information. This principle continues to be applied after the termination of employment.

10. Conflict of Interest

    1. QIC requires its employees to avoid any personal activities and financial interests, which may be in conflict with their commitment to perform their duties effectively.
    2. Employees may not undertake any external business or employment without the prior written permission of the Group CEO

11. Bribery

    1. Company prohibits offering, soliciting, or accepting any Bribe (whether in cash or other financial benefit), to or from any person or company, and whether they are a public official/body or private person/company, to gain commercial or personal advantage. Bribery payment through a third party is also prohibited in the Company.
    2. If any Employee(s) becomes aware of bribery, corruption or fraud being conducted at present or in the past, must inform the Compliance Head or HR Department. The Employee’s identification and interest will be protected.

12. Gifts and Entertainment

    1. Company recognizes the importance of hospitality for establishing goodwill within business relationships. However, all Employee(s) must exercise caution either when accepting or providing gifts and hospitality.
    2. This applies to the provision and/or receipt of gifts and/or hospitality and Employee(s) shall not accept or provide such gifts and/or hospitality that are not reasonable or above the material threshold limit.
    3. The material threshold limit for a gift or hospitality is fixed for one financial year either in one transaction or in a series of transactions taken together. If it exceeds the material threshold, Employee(s) shall escalate for approval to the next level, not less than the Pillar Heads level. Not reporting valuable gifts may lead to disciplinary actions.

13. Company Assets

Employees shall take adequate steps to safeguard QIC’s fixed and movable property and funds.

14. Electronic Access and Telephone

    1. Employees shall take adequate steps to safeguard QIC’s fixed and movable property and funds. Employees may only use the electronic access at their disposal for QIC’s official business and communication.
    2. Limited and reasonable private e-mails are permitted as long as they do not interfere with normal business operations or put the Information Technology system at risk of viruses and similar threats.
    3. The same principle applies to telephone facilities. International dialling will only be provided to employees who need it to conduct their company-related matters.

14. Corrective Action

In such a case the policies stated above have been breached QIC will take the necessary disciplinary actions

Copyright © All rights reserved QIC Group Doha, 2005-2023