King Abdullah

Petroleum Studies
and Research Center

Code of Ethics and Conduct

KAPSARC Code of Ethics and Conduct ii
Document Properties
Custodian Human Resources
Approved by KAPSARC Management Team
Distribution Board of Trustees
KAPSARC Management Team
KAPSARC Employees
Facilities Management contractor and
subcontractors

Revision Record
Date Issue Reason for change
July 1, 2012 Permission received from
SRAK to use their Code of
Conduct as a base.
November 15, 2012 0.8 Modified from original,
expanded, and some
sections trimmed, to fit
KAPSARC
December 3, 2012 0.9 First official draft, to be
approved by the Board of
Trustees
January 15, 2013 1.0 Approved by Board of
Trustees
July 2, 2013 1.1 To produce a simplified
version, as requested by
Board of Trustees

Version Control
The Code will be reviewed at least annually and is subject to
modification. The custodian keeps one set of the originally
approved and signed version. Any revisions will be made to this
existing version.

The most up-to-date version of this document will be published on

KAPSARC’s intranet, or otherwise distributed by the Center.

KAPSARC Code of Ethics and Conduct iii

KAPSARC Code of Ethics and Conduct iv
KAPSARC Code of Ethics and Conduct v
Table of contents

Summary vii

1. Explaining the Code of Ethics and Conduct 1

1.1 What does the Code of Ethics and Conduct cover? 1
1.2 Who must follow the Code? 1
1.3 How can you report a violation or other concern of the
1
Code?
1.4 What could happen to individuals who violate the Code? 2

2. Personal and professional integrity 2

2.1 Conflicts of interest 2
2.2 Bribery and corruption 3
2.3 Gifts and hospitality 4
2.4 Political activity and payments 6
2.5 Insider dealing 7

3. People 7
3.1 Equal opportunity 7
3.2 Harassment 8
3.3 Substance abuse 9

4. Health, safety, security, and the environment 10

5. Research integrity 11
5.1 Objectivity, integrity, and quality 11
5.2 Plagiarism 11
5.3 Protecting confidentiality agreements 12

6. Financial reporting and asset protection 12

6.1 Financial reporting 12
6.2 Protection of corporate assets 13

7. Information management 14
7.1 Public disclosure 14
7.2 Intellectual property 14
7.3 Data privacy and protection 15
7.4 Record management 16

KAPSARC Code of Ethics and Conduct vi

SUMMARY
Below is a summary of the provisions for KASPARC’s Code of
Ethics and Conduct. It is included as a useful outline and is not
intended as a substitute for the whole Code or other business or
departmental policies not contained herein. Employees are
expected to read the entire Code of Ethics and Conduct and
encouraged to provide their input and feedback.

Explaining the Code of Ethics and Conduct

The Code is a set of rules and guidelines designed to help

employees navigate everyday life at work in KAPSARC. It covers
ethical behavior and compliance requirements, as well as relevant
laws and regulations, though it is not comprehensive. Everyone
who works at KAPSARC must follow the code, even contractors –
no exceptions. Any violations or concerns about the Code should
be reported to your line manager or the Director of Human
Resources (HR). Any failure to follow the code may have severe
consequences, such as disciplinary action or even termination of
employment.

Personal and professional integrity

Conflicts of interest
All employees must disclose, in writing, any actual or potential
conflicts of interest between their private activities and KAPSARC
business. Conflicts may arise when an employee or a family
member has a professional or financial interest w an outside party
that is in a business relationship with the Center e.g. a contractor,
stakeholder, or consultant. If an employee intends to use their
position within KAPSARC to benefit materially or financially, this
must be reported to their line manager.

Bribery and corruption

Giving or accepting bribes is absolutely forbidden, directly or
indirectly, no matter what the form, including favors. ‘Facilitation’
payments are also prohibited and considered the same as bribery.
Gifts and hospitality

KAPSARC Code of Ethics and Conduct vii

It is strictly forbidden to ask for gifts or hospitality and employees
are also discouraged from accepting or offering them. It is
recognized that there are times when declining may be considered
discourteous. In these cases, employees should fully understand
the criteria for accepting or offering gifts as set out in the Code and
seek advice from their line managers if they are in doubt.

Political activity and payments

KAPSARC reserves the right to make its own political
representation, but on the whole does not participate in politics or
make payments to any political parties or organizations.
Employees are allowed to participate in politics, and may take a
leave of absence to stand for office. Political participation,
including donations, are entirely at the employee’s own expense
and time.

Insider dealing
All employees must abide by applicable laws and regulations when
dealing with the trade of shares or other securities. Employees
should exercise integrity when party to confidential or inside
information. No such information should be used for personal
advantage nor should misinformation be spread which is designed
to manipulate the price of publicly listed securities.

People

Equal opportunity
KAPSARC provides equal opportunity to all job applicants and
employees. Discrimination of any kinds if not tolerated. All
employment related decisions must be based on merit,
qualifications, performance, and other job-related factors, never on
family relations or personal connections. Favoring individuals
related through family, tribe, culture, or background is strictly
forbidden.

KAPSARC Code of Ethics and Conduct viii

Harassment
KAPSARC enforces a zero tolerance policy when it comes to
harassment. Any action or behavior that an individual or group
finds unwelcome, humiliating, intimidating, or hostile will be met
with serious consequences that may include disciplinary action,
dismissal, or even legal action. Anyone who believes they have
been subject to harassment must report the incident immediately.

Substance abuse
KAPSARC supports a safe, productive working environment by
ensuring the workplace is free from substance abuse, such as
illegal drugs, misuse of prescription drugs, or other substances,
such as alcohol. Employees are prohibited from being at work or
attending KAPSARC business while impaired by drugs or alcohol.
Consuming, possessing, selling, or distributing these substances
is strictly forbidden.

Health, safety, security, and the environment

All employees are expected to abide by safety and security

policies and protect the safety and security of fellow colleagues.
Contractors and other individuals on KAPSARC premises must
follow all relevant health and safety regulations.

Research integrity

Objectivity, integrity, and quality

Researchers are responsible for maintaining the highest standards
of research by retaining their objectivity, integrity, and quality of
work at all times. Bias and misrepresentation are not allowed.

Plagiarism
Proper credit must always be given for work performed by others.
Plagiarism is not tolerated.

Protecting confidentiality agreements

Any proprietary or confidential information must be protected by
KAPSARC employees when entrusted to them by the Center or
outside stakeholders or partners.

KAPSARC Code of Ethics and Conduct ix

Financial reporting and asset protection

Financial reporting
All KAPSARC business transactions must be recorded clearly and
accurately. Employees are expected to execute only approved
transactions and maintain adequate records.

Protection of corporate assets

KAPSARC assets may be of considerable value. All employees
are expected to use due diligence in using and safeguarding them.

Information management

Public disclosure
Public disclosures of KAPSARC information can only be made by
authorized spokespersons. Employees must not disclose
confidential information or release any media or materials related
to the Center without permission from Public Relations. Seek
guidance from the Director of Public Relations if in doubt.

Intellectual property
Employees must follow all laws and regulations related to
intellectual property, such as patents, trademarks, copyrights and
other protected information, whether owned by the Center or an
external party. Employees are encouraged to follow general IP
principles outlined in the Code.

Data privacy and protection

KAPSARC is committed to protecting all private data. Employees
should be aware that business-related files may also contain
personal or sensitive data.

Record management
KAPSARC is required by law to maintain appropriate and timely
records of its activities, including electronic files. All employees
must do their part to make and store these records.

KAPSARC Code of Ethics and Conduct x

KAPSARC Code of Ethics and Conduct xi
1. Explaining the Code of Ethics and Conduct
The Code of Ethics and Conduct is a set of basic rules and
standards about ethical behaviors and principled decision-making.
It is a common reference point for anyone unclear about a specific
situation and a valuable toolkit that can help you put our values
into practice. Not only do we make sure we comply with all
relevant legislation and regulations, we also make sure that our
individual behavior is in line with honesty, integrity and respect for
people.

1.1. What does the Code of Ethics and Conduct cover?

The Code covers the ethical behavior and the compliance

requirements expected of our employees. As a KAPSARC
employee, you are responsible for compliance with all the laws
and regulations in force which apply to your work, as well as with
the Code of Ethics and Conduct. The Code does not provide
exhaustive information about every single KAPSARC standard or
policy. You are responsible for complying with policies relevant to
your role and work area, and for exercising good judgment.

1.2. Who must follow the Code?

Every employee, secondee, manager, officer, and director of

KAPSARC must follow the Code of Ethics and Conduct in all
aspects of KAPSARC’s activities. Contractors and consultants
must also follow the Code. Independent contractors or consultants
working on our behalf or in our name, through outsourcing of
services, processes or any business activity, will be required to act
consistently within the Code when acting on our behalf.

1.3. How can you report a violation or other concern of the

Code?

If you believe a provision of the Code has been or is being

violated, you have a responsibility to raise your concerns through
your line manager or Human Resources. Your report will be held in
the strictest confidence. If you prefer, you can report a suspected

KAPSARC Code of Ethics and Conduct 1

violation to the leadership team. Your concerns will be taken
seriously and investigated quickly. If a violation of the relevant
laws or policies is proven, appropriate action will be taken.
 
Retaliation of any kind against anyone who reports or assists in
responding to an issue concerning the Code will not be tolerated.
KAPSARC will protect its employees against retaliation; in turn, it
expects employees who believe that retaliation has taken place to
report it. At the same time, anyone who files a report with the
intention of spreading falsehoods or to threaten or damage any
employee’s reputation, will also be subject to disciplinary action.

1.4. What could happen to individuals who violate the Code?

Violation of the provisions of the Code of Ethics and Conduct, or of

any laws or regulations governing our operations, may have
severe consequences for the individuals concerned and also for
KAPSARC. A failure to follow the Code that involves a criminal act
or omission could result in prosecution after referral to the
appropriate authorities. Employees who violate the Code or any
laws or regulations may also be subject to internal disciplinary
action, including termination of employment.

2. Personal and professional integrity

2.1. Conflicts of interest

Employees must disclose to KAPSARC any actual or potential

conflict of interest between private activities and KAPSARC
business, and obtain approval before engaging in the proposed
transaction or activity. Your employment in KAPSARC is
considered your full-time occupation during working hours. Outside
those hours, you may engage in other employment or activities,
provided you disclose them in writing to KAPSARC and they do
not conflict – or appear to conflict – in any way with the Center’s
interests. Actual conflicts must be avoided and all conflicts—
whether actual or potential, must be disclosed, recorded and
resolved.

KAPSARC Code of Ethics and Conduct 2

A conflict of interest may arise where an employee or an
employee’s spouse, child or close family member (such as a
parent or sibling) has outside employment, financial or other
participation, for example as an employee, director or consultant,
in any business which is a contractor, other stakeholder, or
competitor of KAPSARC or is seeking to become one. Excuse
yourself and anyone who works for you from making decisions that
may create a conflict of interest.

If employees intend to use knowledge, information, experience or

position gained through their association with KAPSARC to further
their personal interest materially in some outside capacity, they
have a duty to disclose that intention to KAPSARC through their
line manager. However, be aware that the acceptance of any offer
of future employment, consultancy or directorship with a
KAPSARC contractor, other stakeholder or competitor constitutes
a potential conflict of interest.

2.2. Bribery and corruption

Acts or allegations of bribery can do serious damage to our

reputation. Any KAPSARC employee who is found to be giving or
taking bribes or involved in any other acts of corruption, will be
subject to disciplinary action which may ultimately lead to
dismissal and, if appropriate, criminal proceedings.

As such, no director, officer, employee or other representative of

KAPSARC may offer, pay, solicit, or accept bribes, directly or
indirectly in any form (including favors). This applies to
transactions with a foreign or domestic government official or
employee or with any private company or person, and whether in
the conduct of domestic or international business. Also, it applies
whether the payment is made or received directly or through a
third party, such as a contractor, other stakeholders, a relative, or
charity.

KAPSARC policy makes no distinction between bribes and so-

called ‘facilitation’ payments, which are also prohibited. A
facilitation payment is a small payment to a low-level public official,
which is not officially required, to enable or speed up a process

KAPSARC Code of Ethics and Conduct 3

which is the official’s job to arrange. No contractors or other
stakeholder is permitted to make facilitation payments on our
behalf.

When in doubt, make sure to satisfy yourself about the status and
probity of any agent and make sure the agent understands the
KAPSARC position on bribery and facilitation payments. Please
report any concerns you may have about corrupt activities, either
within KAPSARC or in dealings with third parties, to your line
manager.

2.3. Gifts and hospitality

KAPSARC strictly forbids employees to solicit gifts or hospitality.

KAPSARC requires employees to abide by these rules of behavior
not only to protect our reputation, but also to protect themselves
against unfounded allegations of improper behavior.

As a general principle, we discourage employees from accepting

gifts or hospitality from a contractor or other stakeholders.
However, it is recognized that there are times when refusing to
accept gifts or hospitality from a business partner or declining to
provide them would be considered discourteous. KAPSARC
employees should consider the following questions before
accepting or offering a gift or hospitality:

Could my acceptance or offer lead to an obligation or imply an

obligation?
Is this gift or hospitality a ‘reward’ for a business transaction?
Is this gift or hospitality excessive in value?
Would I feel uncomfortable explaining to my work colleagues,
family or the media?

If the answer to any of these questions is “yes”, the gift or

hospitality should not be offered or accepted. If, however, you are
able to accept a gift you should:

Report any gifts or hospitality of any value (offered or

accepted) to your line manager.
Keep a written record of all your received gifts or hospitality.

KAPSARC Code of Ethics and Conduct 4

 Take into consideration the policy of the recipient’s company.

Acceptable gifts and hospitality

You may accept or give the following without the prior approval of
your line manager unless applicable local regulation applies lower
value limits. However, any of these must be reported subsequently
to your line manager and recorded:
A gift (whether of one or more items) of a value not exceeding
50 US Dollar or its equivalent, including corporate gifts which
feature the logo of the donor (diaries, calendars etc.) and gifts
given during the festive season of the year, for example New
Year and Eid.
Meals related to a business context of a value not exceeding
100 US Dollars or its equivalent per person.
Occasional invitations to events, not exceeding 200 US Dollar
or its equivalent in value per person and not extending over a
period of more than one day. ‘Occasional’ means not more
than two or three times a year with the same business partner.

You may only accept or give the following with your line manager
or President approval:
Gifts or hospitality with a value exceeding the above.
Events for periods exceeding the length or occurring more
frequently than the norms above.
Travel or accommodation.
Gifts or hospitality given to or received from government
officials or representatives.

Prohibited gifts and hospitality

You may never accept or offer the following with or without

approval:
Illegal gifts or hospitality
Cash or cash equivalents (e.g. vouchers or tickets)
Personal services
Loans
Gifts or hospitality of an inappropriate nature or in
inappropriate venues
Events or meals where the business partner is not present

KAPSARC Code of Ethics and Conduct 5

 Gifts or hospitality during periods when important business
decisions are being made
Any of the above through an intermediary, such as a charity

If you do have to refuse a gift, don’t be embarrassed. Refer to

KAPSARC policy and explain that you are unable to accept their
generosity.

2.4. Political activity and payments

While KAPSARC may work with industry associations, we always

reserve the right to make our own representation where
necessary, in accordance with our public policy positions.
However, KAPSARC does not make payments to political parties,
organizations, or their representatives. KAPSARC does not take
part in politics.

KAPSARC must comply with all laws regulating participation in

political activities. In addition, even where the law permits
corporate political contributions or expenditures, our funds and
resources may not be used to contribute to any political campaign,
political party, political candidate, or any of their affiliated
organizations.

KAPSARC employees who wish to engage in activities in the

community, including standing for election to public office, will be
given the opportunity to do so if it is a right conferred by law or is
considered appropriate in the light of local circumstances. For
example, leave of absence may be provided to run for a public
position or to carry out the duties of that position if elected. The
opportunity may be provided to return to KAPSARC after
completion of the public office.

The participation of KAPSARC employees, including contributions

of time or money, is carried out entirely on their own account and
their political opinions do not represent KAPSARC’s position.
KAPSARC employees will not be reimbursed by KAPSARC for
any personal political contributions, expenditure or gifts.

KAPSARC Code of Ethics and Conduct 6

 2.5. Insider dealing

Although KAPSARC does not own publicly traded shares or other

securities, it collaborates with organizations who are publicly
traded. Consequently, we must abide by the applicable laws and
regulations on dealing in shares or other securities. The
consequences of non-compliance may include criminal
prosecution, and fines for both KAPSARC and the individual
concerned, as well as internal disciplinary action.

KAPSARC employees must exercise their integrity when they find

themselves in the position of working with stakeholders who may
disclose inside information about the organization which is not
generally available to the public. No confidential information
gained through collaboration with a stakeholder should be used to
personal advantage for insider dealing and buying shares or other
securities in that organization. In addition, it is illegal to be involved
in ‘market abuse’. Market abuse involves spreading false
information or engaging in activities designed to manipulate the
price of publicly listed securities.

Seek advice from the Finance department or General Counsel if

you are considering a transaction in shares or other securities and
have any doubt about its propriety.

3. People

3.1. Equal opportunity

KAPSARC provides equal opportunity to all job applicants and

employees and does not tolerate unlawful employment
discrimination of any kind. KAPSARC is committed to creating and
complying with lawful human resources policies and practices in all
aspects of employment, including recruitment, selection, hiring,
evaluation, promotion, training, discipline, development,
compensation and termination. KAPSARC will ensure that its
employment related decisions are based on relevant qualifications,
merit, performance and other job-related factors.

KAPSARC Code of Ethics and Conduct 7

Nepotism (employing or favoring relatives or members of the same
tribe, culture, or background) is destructive to the workplace. You
should never make employment related decisions, including hiring,
evaluation, promotion, training, discipline, development,
compensation and termination of employment based on any
criteria other than merit and business considerations. Every
employee should refrain from nepotism and ensure they do not
create the impression of nepotism, which undermines the strong
value base of the Center.

If you have questions about the workplace culture or would like to

report any concerns about equal opportunity, contact the HR
Director.

3.2. Harassment

KAPSARC will not tolerate harassment in the workplace – that is

any action, conduct or behavior which any individual or group of
individuals finds unwelcome, humiliating, intimidating, or hostile.
Employees should be particularly sensitive to actions or behaviors
that may be acceptable in one culture but not in another.

The consequences for an individual who engages in harassment

are serious and may include disciplinary action, up to and
including dismissal or termination of contract, and potentially legal
action. Certain actions and behaviors are also illegal in many
countries. Both KAPSARC and the individual may be subject to
civil penalties if found to be in breach of a legal requirement.

The effects of harassment

The effects of harassment on individuals can be serious and may

include anger, fear or depression as well as feelings of
helplessness or confusion. People may suffer physical or mental
illness and may find their relationships at home and work affected.
The employee may feel that it is impossible to continue working in
the same department or even for KAPSARC. To avoid any
potential instances of harassment, please do not:

KAPSARC Code of Ethics and Conduct 8

 Behave in an unwelcome, humiliating, intimidating or hostile
manner.
Make inappropriate jokes or comments.
Assume that what is acceptable in one environment is equally
acceptable in another.
Distribute or display offensive material, including inappropriate
pictures or cartoons.
Spread malicious rumors or use voicemail, email or other
electronic media to transmit derogatory, harassing or abusive
comments.

The impact on KAPSARC can be equally serious: reduced

productivity and morale together with higher absenteeism and
employee turnover. Performance standards may drop and, as a
result, there may be an adverse effect on the quality of our
research and our reputation. KAPSARC may also be legally liable
for harassment by its employees. In order to avoid this, please try
to:

Treat all employees, contractors or other stakeholders, and

visitors with respect.
Create a work environment free from harassment.
Learn about local behaviors, practices and customs that may
differ from those familiar to you.
Use an informal approach to resolve the issue where
appropriate before raising a formal grievance.

If an employee feels he or she has been harassed, there are a

number of ways to raise the issue both informally and formally. In
most instances, the line manager or HR Director should be the first
point of contact.

3.3. Substance abuse

KAPSARC strives to provide a safe, productive work environment

for its employees by ensuring that the workplace is free from
substance abuse, that is, the use of illegal drugs, the misuse of
legal drugs or other substances, and the use of alcohol. This policy
applies in accordance with applicable legal and regulatory
requirements.

KAPSARC Code of Ethics and Conduct 9

Employees are prohibited from being at work or attending to
KAPSARC business while impaired by drugs or alcohol. Do not
use, possess, sell or distribute illegal drugs, or misuse legal drugs
or other controlled substances. Alcohol consumption is not
permitted on any KAPSARC premises.

Searches and ‘for cause’ testing

A search may be conducted where there is good reason to believe

that drugs or alcohol have been brought to the workplace or are in
an individual’s possession. Searches might include personal
effects, desks, lockers and other KAPSARC property. The failure
of an individual to consent to a search will be considered serious
misconduct. In situations that give cause for concern either in the
workplace or after accidents or near misses, KAPSARC may at its
discretion require an employee to undergo a medical examination,
including a blood test for alcohol. In other cases, you may be
asked to comply with a rehabilitation program.

4. Health, safety, security, and the

environment
Protecting our health, safety, security, and the environment (HSE)
should be a daily priority for everyone at KAPSARC. Make sure
you are familiar with the laws, regulations, policies, and
procedures that apply to your job. Broad principles include:

Do no harm to people
Protect the environment
Comply with all applicable HSE laws and regulations

HSE Rules include, but are not limited to complying with the law,
standards and procedures, intervening in unsafe or non-compliant
situations, and respecting our neighbors.

KAPSARC owned and operated facilities must operate with the

necessary permits, approvals and controls that are designed to
protect health, safety and the environment. KAPSARC contractors
are expected to commit to the same levels of HSE protection as

KAPSARC Code of Ethics and Conduct 10

KAPSARC. No one should carry out tasks for which they are not
trained, competent, medically fit and sufficiently rested and alert.

5. Research integrity

5.1. Objectivity, integrity, and quality

As an independent institution, KAPSARC must maintain objectivity

and balance in its research efforts. The Center does not work to
advance the interests of any external organization. Researchers
are expected to exhibit the highest levels of integrity, honesty, and
responsibility while conducting their work.

Researchers should strive to apply scientific reasoning in research

and sufficiently explore existing literature prior to publishing any
results. It is your responsibility to maintain an up-to-date level of
knowledge in your research field and reveal any potential conflicts
of interest when conducting research.

There may be instances where the availability of information is

limited, or the information available does not directly support your
hypothesis. Data that cannot be found cannot be made up.
Research based on inaccurate or fabricated data is misleading
and biased, and is contrary to the spirit of KAPSARC.

Be impartial in developing conclusions about such information and

the associated analysis and always be transparent in every aspect
of your work. Do not allow for the misrepresentation of any
research. Don’t be hesitant to acknowledge any errors that are
raised during your research work.

5.2. Plagiarism

Always give proper credit for work performed by others, whether

they are colleagues at the Center or external parties. The entities
or individuals to whom recognition is due must be specifically
named. Do not plagiarize any content in your work, research or
otherwise.

KAPSARC Code of Ethics and Conduct 11

Copying a sentence, paragraph or even a phrase without citing
your sources is considered plagiarism and is a major offense in the
academic and professional world. It has often resulted in the
dismissal of colleagues, potential lawsuit for the organization and a
tainted reputation. Acts or allegations of plagiarism could seriously
damage your reputation and that of KAPSARC.

5.3. Protecting confidentiality agreements

Do not disclose any information entrusted to you in confidence by

KAPSARC or its stakeholders. This applies to external copyrighted
information purchased and/or obtained by KAPSARC, or any other
confidential or contractual information. What is discussed in
confidence remains in KAPSARC.

6. Financial reporting and asset protection

6.1. Financial reporting

All KAPSARC business transactions must be reflected accurately

and fairly in company accounts. KAPSARC expects all employees
to gain approval for transactions before carrying them out and to
ensure accurate and true records of all transactions (including
those giving rise to liabilities) are maintained in company accounts,
financial statements and other documents.

KAPSARC expects that its employees will only execute

transactions, and access assets in accordance with their
management’s general or specific authorization or delegation of
authority. KAPSARC also requires that once a transaction has
been approved and carried out, the related records be submitted
for inclusion in its accounts and records. In the event of an audit,
employees are also expected to co-operate fully with auditors by
responding to questions, providing documentation and clarifying
transactions and reported data as required.

6.2. Protection of corporate assets

KAPSARC Code of Ethics and Conduct 12

KAPSARC assets may be of considerable value – whether
financial or physical assets or intellectual property – and are
intended to be used only to advance KAPSARC business
purposes and goals. These assets must be secured and protected
in order to preserve their value.

All employees are entrusted with KAPSARC assets in order to do

their jobs. We are all personally responsible for safeguarding and
using KAPSARC assets appropriately. Such assets include
buildings, sites, equipment, tools, supplies, communication
facilities, funds, accounts, computer programs, information,
technology, documents, know-how, data, patents, trademarks,
copyrights, time, and any other resources or property of
KAPSARC.

All employees are responsible for protecting KAPSARC assets

against waste, loss, damage, misuse, theft, misappropriation or
infringement and for using those assets in responsible ways.

Accurate, reliable and timely preparation of business records and

documents, including those that relate to expenses incurred by
employees on behalf of the Center, are required by law. Such
records are important to the proper discharge of its financial, legal
and reporting obligations. Falsification of asset records or
misrepresentation of facts may constitute fraud and can result in
civil and criminal liability for both individuals and the Center.

Employees are required never to conceal, alter, destroy or

otherwise modify company records or documents except as
authorized in accordance with established standards and
guidelines. Neither are they to conceal, alter, destroy or otherwise
tamper with documents. Finally, employees should never
intentionally make a false or misleading entry in a report, record, or
expense claim.

7. Information management

KAPSARC Code of Ethics and Conduct 13

 7.1. Public disclosure

Whilst KAPSARC promotes openness, it must guard against

uncontrolled disclosure of information that may jeopardize its
reputation. To ensure compliance, public disclosures must only be
made by authorized spokespersons. Any public written or oral
communication that can be attributed to KAPSARC may amount to
a public disclosure. This includes not just regulatory filings, but
information issued to the public, such as press releases,
speeches, presentations and other information accessible to the
public.

KAPSARC employees must exercise careful judgment based on

knowledge of the relevant facts and expert advice when
considering a public disclosure. Employees must not disclose
information to the public (unless they are specifically authorized to
do so) and must always keep confidential information confidential
unless you are specifically permitted to tell other persons,
internally or externally. Those authorized to make disclosures must
ensure that information provided to the public is true, accurate and
complete (stating all material facts). No disclosure should be
misleading. The loss or theft of any information (such as the theft
of your computer) must be reported to your line manager
immediately.

All external presentations, speeches, videos, articles and

publications must be formally cleared by the Director of Public
Relations prior to release. In particular, press releases and all
interactions with the media have to be cleared in advance by the
President. The Director of Public Relations must be consulted prior
to any engagement with the media including, for example, press
conferences or interviews.

7.2. Intellectual property

KAPSARC is required to comply with the intellectual property

framework. ‘Intellectual Property’ (IP) includes patent rights,
trademarks and service marks, domain names, copyright
(including copyright in software), design rights, database extraction
rights, rights in know-how or other confidential information

KAPSARC Code of Ethics and Conduct 14

(sometimes called ‘trade secrets’ or ‘proprietary information’) and
rights under IP-related agreements.

KAPSARC must protect IP provided by its collaboration partners

and other stakeholders, for instance by preserving the
confidentiality of proprietary information, and ensuring that third
party IP relationships are governed by formal agreements.
Employees should never knowingly infringe the valid IP rights of
any third party or disregard obligations of confidence owed to any
third party. KAPSARC will comply with its stakeholders’ IP
agreements, which specifically support centralized ownership and
control of IP assets.

General IP principles and guidelines include:

Using trademarks and domain names only when authorized by
the legal owner.
Obtaining written consent from third parties to use copyrighted
images, graphs or excerpts of their written works in specified
KAPSARC research papers or any other documents.
Keeping a copy of written consents from the IP owner, and
forwarding the consent to KAPSARC’s custodian of such
records.
Not disclosing IP unrelated to the Center that you developed or
used before joining KAPSARC.
Never disclosing proprietary information in a public forum
without prior clearance.
Not using IP from prior employment or other sources in your
current work without notifying your supervisor and obtaining the
appropriate written consent.

7.3. Data privacy and protection

KAPSARC is committed to respecting the privacy of any personal

data that it possesses. Those with access to personal data must
only use it in a way authorized by applicable law. There may be
legal restrictions on transferring personal data to another party
including to KAPSARC’s stakeholders. There may also be
additional legal restrictions on transferring personal data outside
its country of origin.

KAPSARC Code of Ethics and Conduct 15

Personal data created, used, transferred to or stored on
KAPSARC IT and communication facilities or on media provided
by or on behalf of KAPSARC may under certain circumstances be
monitored and analyzed by or on behalf of KAPSARC. Personal
data should be protected by reasonable security safeguards
against such risks as loss or destruction or unauthorized access
to, or unauthorized use, modification or disclosure of, data.

Employees should be aware that business-related files can also

contain personal data and remember that sensitive personal data
is often more protected by legislation than non-sensitive personal
data. When in doubt, do not handle personal data before making
sure you know which data protection laws, if any, are applicable
and which requirements must be met.

7.4. Record management

KAPSARC must be able to retrieve records quickly and reliably.

When each record’s retention period has ended, appropriate
disposal is required, unless there is a particular need to continue
holding the records, such as an investigation or litigation. Records
must be managed securely throughout their life cycle in line with
their importance to KAPSARC and in compliance with legal, tax,
regulatory, accounting and business retention requirements.

A record is defined as a sub-set of information created or received

as evidence of a business activity or required for legal, tax,
regulatory or accounting purposes or important to KAPSARC
business or corporate memory. Some examples of records are:
contracts, audit reports, financial information, product
specifications, corporate policies, minutes of meetings, guidelines
and procedures.

Electronic records (including images, instant messaging, email

messages, voice recordings or electronic files) must be treated in
the same way as records in any other format. This is because it is
the content which determines a record, not the medium or its
format.

KAPSARC Code of Ethics and Conduct 16

Some information produced in the course of KAPSARC activities
has only temporary value and should be disposed of as soon as it
is no longer required. Determining whether information has only
temporary value is a matter of judgment and if an individual is in
any doubt as to whether something is a record or not they should
consult their line manager. Before leaving your post, ensure to
transfer custody of all relevant records, whether moving position
inside KAPSARC or leaving the Center entirely.

KAPSARC Code of Ethics and Conduct 17