Business Ethics and Law

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Case study 3

- You recently joined your company as the Chief Compliance Officer.

- The company is a medium sized company based in Riyadh doing business in the construction industry.

- The CEO of the company is really concerned because the Company does not have a Compliance and Ethics Program. The Company previously had difficult experiences in negotiating contracts with new clients and subcontractors.

- The CEO asks you to propose a new Compliance and Ethics Program to be discussed at next Board Meeting. The CEO also wants you to make proposals for a Corporate Governance of the company if this can facilitate the setting up of the new Compliance and Ethics Program.

- Please draft a document detailing your proposed Compliance and Ethics Program and a new a Corporate Governance structure. Explain the reasons for this new program, the objectives and the legal background.

As a chief of corporate control department, I will follow the best practice in designing my program which will result to high compliance in the company with keeping into consideration that my program is not enough if it is not followed with change management "supported by the top management" to have the employees’ commitment.

The program will be as follow:

Introduction:

This Code of Business Conduct and Ethics expresses the commitment of the company to conduct business in accordance with all applicable laws, rules and regulations and the highest ethical standards. All employees, associates, independent contractors and directors are expected to follow the Code. The company Whistleblower Policy is part of the Code. The company also expects our suppliers and vendors to abide by this Code. This Code is not intended to cover all laws or policies nor every possible ethical issue that we may face. Each employee should read and become familiar with the Policy Guide, which is not part of the Code. Our managers must be the models of ethical behavior. The company Whistleblower Policy is part of the Code.

If an employee has questions about this Code or are unsure, whether it applies in a specific situation, so he should ask his manager or the Chief Compliance Officer.

Compliance with laws, rules, and regulations

The company policy required all employees to comply with all applicable laws, rules and regulations. Each of us must be dedicated to complying fully with the letter and spirit of the laws, rules and regulations that apply to our business. The Policy Guide provides guidance as to certain of the laws, rules and regulations that apply to company's activities

The program will cover the following areas:

- Intellectual property

- Confidentiality and privacy

- Personal conflicts of interest

- Corporate opportunities

- Integrity and fair dealing

- Equal employment opportunity and harassment

- Environment, safety, and health

And with regard to Corporate Governance structure it will be as follows:

[pic 3]

Sincerely yours,

Ibrahim.