Emirates Driving Company

SUPPLIER CODE OF CONDUCT

1.0 INTRODUCTION:

Emirates Driving Company (EDC) shall strive to achieve the highest standards in conducting its training operation ethically, efficiently and economically, while giving utmost consideration to health, safety, non-proliferation and environmental protection.
Commitment to the ethical behavior requires compliance with the United Arab Emirates (UAE) and Abu Dhabi laws, government policies and EDC policies.
Emirates Driving Company (“EDC”) and its branches requires all of its contractors, subcontractor’s consultants, suppliers, sub-suppliers and vendors (collectively, “suppliers”) and their representatives to act in accordance with the highest ethical standards of personal and professional integrity in all aspects of their activities, and to comply with all applicable laws, rules, regulations, and Company standards, policies and procedures, including this Code.
This Code of Conduct sets forth the behaviors, principles and standards of conduct that suppliers must adhere to in conducting business with EDC.
To support compliance with this Code, suppliers shall be responsible for ensuring that:
a. This Code is shared with all their employees and individuals assigned to perform work for or on behalf of EDC;
b. Any work performed for or on behalf of EDC is done in full compliance with this Code, all applicable laws and regulations, and in accordance with the highest standards of ethical business conduct; and
c. Any work performed for or on behalf of EDC is done by trained individuals with the skills, expertise and certifications necessary to complete the job in a safe and compliant manner.
EDC regards its suppliers as a critical and necessary extension its mission, operations and future success and expects their full commitment to making compliance and ethics a top priority as they work with the Company.
Every Supplier is expected to meet these standards in connection with the operations of its business. Suppliers should establish and enforce policies which comply and align with the expectations of this Supplier Code. Suppliers are also expected to apply comparable standards downstream in their own supply chains.
Violations of this Supplier Code are taken seriously and should be reported upon discovery by the Supplier. Any violation of this Supplier Code may result in any of the following, or other, similar actions: asking the Supplier to audit its own organization or its supply chain and to report on its findings; recommending or requiring corrective- action plans; or making the Supplier a no preferred supplier. In some cases, the contract/assignment with the Supplier may be terminated.

2.0 APPLICATION

The Supplier Code of Conduct (“Supplier Code”) shall apply to all suppliers and their representatives (including employees, suppliers, agents and subcontractors collectively referred to as “the Supplier”) engaged in conduct business with and/or on behalf of EDC.
EDC conducts its business with honesty and integrity, in accordance with applicable laws and regulations, and in alignment with UAE laws and standards. Accordingly, EDC expects all service providers and contractors to maintain the highest ethical standards and to conduct their business with honesty and integrity. During any tendering processes, EDC will give preference to service providers and contractors/supplier that share this commitment and that demonstrate the use of ethical recruitment practices.

3.0 TERMS AND DEFINITIONS

3.1 Confidential Information - all information of whatever kind disclosed by or on behalf of EDC by any means whatsoever in respect of EDC project is confidential information.
3.2 Conflict of Interest (COI) - exists whenever there is a proposed transaction of EDC in which an employee has any actual or potential personal involvement, interest or relationship, either directly or indirectly.
3.3 Contract - a written agreement (contract, subcontract, purchase order, etc.) executed directly between or among EDC and one or more other parties seeking as a matter or right, the payment of money in a certain sum, the adjustment, or interpretation of contract terms, or other relief arising under or relating to the contract.
3.4 Employee - includes management and staff, direct hire personnel, secondees and contracted personnel supporting EDC.
3.5 Ethical Behavior - tends to be good for business and involves demonstrating respect for key moral principles that include honesty, fairness, equality, dignity, diversity and individual rights.
3.6 Fraud - the misuse of entrusted power for personal or private gain through bribery, deception, conflicts of interest, extortion, embezzlement, forgery, theft, conspiracy, misappropriation, false representation, concealment of material facts, collusion, false accounting, or any other method with the intention of obtaining an advantage, avoiding an obligation, or causing loss to another party.
3.7 Supplier/Contractor/Sub-Contractor/ Outsource - any individual or organization who furnishes items or services in accordance with a procurement document.
3.8 Whistleblowing - whistleblowing is an early warning system to avert possible risks to the organization. An effective policy to encourage whistleblowing enables employers to find out when something is going wrong in time in order to take necessary corrective action.

4.0 STANDARDS OF CONDUCT

4.1. Compliance with the Law
Suppliers shall ensure that their representatives (including employees, suppliers, agents and subcontractors collectively referred to as “the Supplier”) conduct business with and/ or on behalf of EDC in compliance with all applicable United Arab Emirates (UAE) and Abu Dhabi laws, regulations, government policies and EDC policies.
4.2. Health and Safety Management
EDC maintains a fully accredited HSE Management System and suppliers are required to comply with all applicable requirements. The safety of the public, employees and suppliers is EDC highest priority. Working safely and in compliance with all applicable safety rules, laws, standards, regulations, procedures, and rules of this Code of Conduct is a condition of engagement as a supplier to EDC. Minimum health and safety expectations and requirements are set forth below. Additional EDC requirements specific to the work undertaken by a supplier may be specified in the relevant contact based on the assessed level of risk with the scope of works being undertaken. In addition to meeting minimum legal requirements for working conditions, Supplier is expected to provide a safe, healthy work environment (e.g., clean facilities, properly maintained equipment, sufficiently lighted and ventilated facilities) and take necessary precautions to prevent accidents and injury.
4.2.1. Public Safety
Supplier shall identify and manage all potential public safety risks and hazards associated with any activity, service or product deployed in the execution of a service for or on behalf of EDC.
4.2.2. Occupational Health and Safety
Supplier shall identify and manage all potential occupational health and safety risks and hazards associated with any activity, service or product deployed in the execution of a service for or on behalf of EDC (e.g. via risk assessments and job safety analysis). Appropriate control measures shall be developed, implemented and monitored based on the minimum requirements of the EAD/ OSHAD.
4.2.3. Health Screening and Medical Surveillance
Health Screening and Medical Surveillance shall be performed by the supplier for all applicable work activities, as per the requirements of the Abu Dhabi health and safety.
4.2.4. Vehicle Safety
Supplier shall ensure that all vehicles used and transportation activities undertaken in the execution of EDC business are compliant with applicable laws, regulations and codes.
4.3. Environmental and Sustainability Leadership
EDC is committed to being an environmental and sustainability leader and demonstrating this through its actions, including conducting its business in full compliance with the spirit of all applicable environmental and sustainability laws, regulations, requirements and operating in an environmentally sensitive manner consistent with its values. EDC requires that suppliers operate in a similar environmentally responsible manner, with appropriate environmental and sustainability management and measures.
4.4. Labor Issues and Human Rights
EDC expects its suppliers to know and uphold the human rights of all workers, whether temporary or contract employees and to treat all their workforce members with dignity and respect, providing them with safe and humane working conditions.
4.4.1 Human Rights
Supplier shall foster a culture and workplace that does not tolerate harassment, including sexual harassment, threats of harassment, or retaliation for reporting harassment.
4.4.2 Labor
Supplier shall not use forced or involuntary labor nor demand work/service from an individual under threat or coercion. Work must be conducted based on freely agreed terms. Supplier shall not withhold or destroy, conceal, confiscate or deny access by workers to workers’ identity or immigration documents. Supplier shall not require nonprofessional migrant workers to bear any costs or fees associated with their recruitment, travel or migration processing.
4.4.2.1 Child labor
Employment of workers under the age of 18 should not interfere with their compulsory education and should not, by the nature of the work or the circumstances in which it is carried out, be likely to harm their health, safety, or morals.
4.4.2.2 Discrimination
Supplier shall foster a culture which seeks to promote equal opportunity for all. Supplier shall not tolerate unlawful discrimination. Job candidates and employees are expected to be evaluated based on their ability to perform the job.
4.4.2.3 Wages, working hours, and other conditions
Supplier shall meet applicable standards regarding working conditions across its entire workforce, including, without limitation, laws, regulations, and standards relating to the payment of the minimum legal wage or a wage that meets local industry standards, whichever is greater; the observation of legally mandated break and rest periods; and the health and safety of the workers in the workplace.
4.5. Ethical Business Conduct
EDC expects suppliers to conduct business in accordance with the highest ethical standards, including adherence to the following:
4.5.1. Business Integrity
Supplier shall prohibit all forms of bribery, corruption, extortion and embezzlement and shall report to EDC any violation of any anti-corruption law.
4.5.2. Criminal and Civil Claims
Supplier shall inform EDC of any recent, current or pending criminal investigations or charges and any recent, current or pending civil litigation against it or any of its employees.
4.5.3. Company Records and Disclosures
Accurate records and disclosures are critical to EDC meeting its legal, financial, regulatory and management obligations. Supplier shall ensure that facts are never misstated or material information omitted to EDC, and that all records, disclosures and communications to EDC are full, fair, accurate and timely.
4.5.4. Confidential Information
Revealing confidential or protected information obtained while working for EDC is a violation of this Code of Conduct, EDC contractual requirements and potentially the law. Supplier shall report to EDC any suspected data breach immediately following detection.
4.5.5. Fair Competition and Anti-Trust Compliance
EDC believes in fair competition and expects suppliers to comply with all applicable anti- trust or fair competition laws and regulations.
4.5.6. Responsible Procurement
Suppliers shall take reasonable steps to ensure that products and services procured are from ethical sources and that sub-suppliers are aware of and comply with the principles of conduct in this code of conduct.
4.6. Anti-Fraud and Misconduct (Corruption / bribery / financial crimes)
• Supplier shall neither make bribes nor accept them, nor induce or permit any other party to make or receive bribes on its behalf nor cause other parties, including EDC, to violate any applicable anti-corruption or anti- bribery laws when working on behalf of or with the other parties including EDC. Supplier shall use reasonable practices to prevent bribery in all forms and shall support efforts to fight corruption. Supplier shall not engage in or assist any third party with any money laundering, terrorist financing.
• EDC provides a mechanism for reporting potential activities and/or behaviors which may be construed as misconduct and/or fraudulent for example unfair practices in the procurement process of the company including pre-qualifications, bid evaluations, and contract award, bribery/corruption, reporting of fraudulent financial information to stakeholders, any government entity, or any other company matters involving fraud, employee misconduct, illegality or health and safety and environmental issues which may result in financial loss, damaging to the safety culture and reputation of EDC and / or its employees.
• Information regarding Anti-Fraud and Misconduct including the whistleblowing can email at [email protected]
4.7. Conflicts of Interest
EDC expects suppliers to exercise reasonable care and diligence to prevent any actions or conditions that could result in a conflict with EDC’s interests, or the appearance of a conflict of interest that may compromise the exercise of independent judgment during the execution of work for or on behalf of EDC specifically:
4.7.1. Conflicting Business Interests
While engaged in EDC-related work, supplier shall not engage in any activity that creates a conflict of interest, or the appearance of a conflict of interest, with EDC or in any way compromises the work that supplier is contracted to perform on behalf of EDC. A conflict of interest can arise if actions are taken or if there are interests that may make it difficult for supplier to perform EDC-related work objectively and effectively. Any potential conflicts shall be disclosed to EDC and written concurrence obtained that states supplier is allowed to remain in a situation that could be perceived as a conflict.
4.7.2. Close Personal Relationships
1 . Close personal relationships between supplier workforce members and EDC employees responsible for monitoring supplier’s performance should be avoided in order not to compromise the exercise of independent judgment, or lead to claims of a conflict of interest.
2 . To avoid these problems and to foster a positive work environment, supplier shall report to EDC any close personal relationships that result, or could result, in a conflict with this Code.
4.7.3. Gifts to EDC Employees
1 . EDC discourages suppliers from offering or giving its employees gifts, services, discounts, gratuities, payments of fees, bribes, entertainment or other benefits or items of value (collectively “gifts”) or other favors that influence, or appear to influence, the performance of their duties or assist supplier in obtaining undue or improper advantage.
2. Similarly, EDC forbids its employees, as well as members of their immediate families, from accepting gifts from suppliers doing business with or seeking to do business with EDC.
3 . The following gifts of a modest value that are customarily associated with the maintenance of ongoing legitimate business relationships are excluded from this prohibition:
a. promotional items, mementos, souvenirs, advertising novelties;
b. small items of food and beverage;
c. entertainment events or other business events hosted to establish or maintain a business relationship; and
d. supplier discounts that are available to all Employees.
4.8. Engagement with External Parties
1 . Supplier shall neither disclose the contractual relationship with EDC nor the scope of the contract to third parties.
2 . News Media: No supplier shall engage with the media to disclose any information related to the commercial relationship with EDC and/or represent EDC.
3 . Social Media: Supplier shall have processes in place to ensure that the use of social media by their workforce or representatives does not negatively affect EDC’s reputation. Processes should specifically ensure against the following:
• Representation of any content in any social media regarding EDC without prior written approval
• Posting content about EDC employees, stakeholders, suppliers or affiliates that is derogatory or in contravention of any standards in this Code of Conduct.
• Posting photographs or video of non-public areas of EDC’s premises, processes or operation without prior approval.
• Use of EDC’s logo or proprietary graphics in a way that suggests representation of EDC.
4.9. General Management and Administration
4.9.1. EDC Assets
EDC assets such as computers, telephones and mobile phones, fax machines, copy machines, conference rooms, vehicles, equipment, tools and similar assets are for EDC’s use only, unless explicit permission to use them has been secured in advance from EDC.
4.9.2. Computer and System Security

Suppliers who have access to EDC’s information systems are responsible for ensuring the security of those systems by identifying and complying with applicable EDC information and cyber security policies and standards available from EDC. Applicable requirements include ensuring the following:
a. Computer accounts, passwords and other types of authorization are assigned to authorized users and must not be shared with others. Authorized users will be held accountable for all actions taken on their system with their user identification.
b. Internet access is not used to conduct personal business, play computer games, conduct political campaigns or for personal gain.
c. Inappropriate or pirated content is not stored on EDC equipment nor transmitted through EDC network.
d. Only approved, authorized and properly licensed software is used on EDC computer systems.
e. No attempts are made to attack security controls on a computer system or network.
f. EDC-issued equipment is protected from unauthorized access and theft at all times, including locking the computer screen when the computer or laptop is left unattended.
Violations of any of the above may result in termination of supplier’s assignment with EDC.
4.9.3. Records Retention
If supplier generates or receives information, data and/or records pertaining to EDC as a result of the work performed by supplier, supplier must ensure that those records are returned back to EDC pursuant to the fulfillment of EDC’s requirements.
4.9.4. Management Systems
Supplier shall support compliance with this Code of Conduct by establishing pertinent policies and processes appropriate for the nature and scale of operations.
4.10. Supplier Concerns
1 . The standards of conduct described in this Code of Conduct are critical to the ongoing success of EDC’s relationship with the supplier. If the suppliers have business related concerns, EDC encourages them to report such concerns to the Procurement Section using the Company email: [email protected]

2 . All reported concerns are handled confidentially and can be submitted anonymously. EDC prohibits retaliation against a supplier who raises a concern or is involved in an investigation and will investigate any reports of retaliation and take the appropriate action.
3 . This Code of Conduct is not a contract. It does not confer/grant rights on any supplier, nor does it impose obligations on EDC. In case of a conflict between this Code of Conduct and EDC’s contract, the terms of the contract shall prevail.
4.11. Monitoring and Compliance with the Code
1 . EDC expects its suppliers to comply with the Supplier Code of Conduct and take necessary steps to ensure that the Code is shared with all individuals assigned to perform work for or on behalf of EDC, and that all EDC-related tasks are executed by individuals with the skills, expertise and certifications necessary to uphold the principles and meet the standards of the Code.
2 . To support compliance with this Code, EDC expects its suppliers to establish appropriate management processes and systems to monitor compliance.

SUPPLIER CODE OF CONDUCT

1.0 INTRODUCTION:

Emirates Driving Company (EDC) shall strive to achieve the highest standards in conducting its training operation ethically, efficiently and economically, while giving utmost consideration to health, safety, non-proliferation and environmental protection.
Commitment to the ethical behavior requires compliance with the United Arab Emirates (UAE) and Abu Dhabi laws, government policies and EDC policies.
Emirates Driving Company (“EDC”) and its branches requires all of its contractors, subcontractor’s consultants, suppliers, sub-suppliers and vendors (collectively, “suppliers”) and their representatives to act in accordance with the highest ethical standards of personal and professional integrity in all aspects of their activities, and to comply with all applicable laws, rules, regulations, and Company standards, policies and procedures, including this Code.
This Code of Conduct sets forth the behaviors, principles and standards of conduct that suppliers must adhere to in conducting business with EDC.
To support compliance with this Code, suppliers shall be responsible for ensuring that:
a. This Code is shared with all their employees and individuals assigned to perform work for or on behalf of EDC;
b. Any work performed for or on behalf of EDC is done in full compliance with this Code, all applicable laws and regulations, and in accordance with the highest standards of ethical business conduct; and
c. Any work performed for or on behalf of EDC is done by trained individuals with the skills, expertise and certifications necessary to complete the job in a safe and compliant manner.
EDC regards its suppliers as a critical and necessary extension its mission, operations and future success and expects their full commitment to making compliance and ethics a top priority as they work with the Company.
Every Supplier is expected to meet these standards in connection with the operations of its business. Suppliers should establish and enforce policies which comply and align with the expectations of this Supplier Code. Suppliers are also expected to apply comparable standards downstream in their own supply chains.
Violations of this Supplier Code are taken seriously and should be reported upon discovery by the Supplier. Any violation of this Supplier Code may result in any of the following, or other, similar actions: asking the Supplier to audit its own organization or its supply chain and to report on its findings; recommending or requiring corrective- action plans; or making the Supplier a no preferred supplier. In some cases, the contract/assignment with the Supplier may be terminated.

Suppliers who have access to EDC’s information systems are responsible for ensuring the security of those systems by identifying and complying with applicable EDC information and cyber security policies and standards available from EDC. Applicable requirements include ensuring the following:
a. Computer accounts, passwords and other types of authorization are assigned to authorized users and must not be shared with others. Authorized users will be held accountable for all actions taken on their system with their user identification.
b. Internet access is not used to conduct personal business, play computer games, conduct political campaigns or for personal gain.
c. Inappropriate or pirated content is not stored on EDC equipment nor transmitted through EDC network.
d. Only approved, authorized and properly licensed software is used on EDC computer systems.
e. No attempts are made to attack security controls on a computer system or network.
f. EDC-issued equipment is protected from unauthorized access and theft at all times, including locking the computer screen when the computer or laptop is left unattended.
Violations of any of the above may result in termination of supplier’s assignment with EDC.
4.9.3. Records Retention
If supplier generates or receives information, data and/or records pertaining to EDC as a result of the work performed by supplier, supplier must ensure that those records are returned back to EDC pursuant to the fulfillment of EDC’s requirements.
4.9.4. Management Systems
Supplier shall support compliance with this Code of Conduct by establishing pertinent policies and processes appropriate for the nature and scale of operations.
4.10. Supplier Concerns
1 . The standards of conduct described in this Code of Conduct are critical to the ongoing success of EDC’s relationship with the supplier. If the suppliers have business related concerns, EDC encourages them to report such concerns to the Procurement Section using the Company email: [email protected]