Professional Documents
Culture Documents
Handbook
Contents
1. INTRODUCTION 5
4 SEPARATION 15
6 GRIEVANCE PROCEDURE 30
7 PERFORMANCE MANAGEMENT 31
9 ANNEXURE 1 48
10 ANNEXURE 2 57
BAHRAIN STEEL
Our Mission
We shape iron to help our customers make great things,
putting people and planet first.
Our Vision
• To be the most preferred partner for our customers by
being customer centric.
• To create and deliver value with a solution focus.
• To be recognized and influential with regard to our safety
practices.
• To achieve admirable results in a sustainable manner,
through innovation and invention.
• To make a positive impact to Bahrain by being socially
responsible
SULB
Our Mission
To help build great things.
Our Vision
To be a leading customer-centric value creator in the steel
industry, focusing on people, safety and sustainability.
Our Values
• Safety: “Safety for all, above all, at all times, everywhere!”
• Customer Focus: “Customer service is not a department,
it is everyone’s job!”
• Sustainability: “Working viably to develop the future!”
• Integrity: “Do the right thing, even when no one is watching!”
• Collaboration: “Together we stand, divided we fall!”
• Respect: “Respect for myself, for others, for quality of life,
and for the planet we all share!”
• Innovation: “New ideas come from anywhere!”
• Do more with less : “Measure twice, cut once”
• Is frugal
Do more • Views constraints as opportunity
with less • Uses technology to do more
• Creates value continuously
KPI Competency
60% 40%
Overtime Paid
Description
(% of Basic Rate)
The Foulath Code of Conduct (the ”Code”) is a set of principles that guide and govern the conduct of
Foulath and its subsidiary and/or affiliated companies (the “Foulath Group”) and their employees in
all matters relating to business.
The Code lays down the ethical standards that Foulath employees have to follow in their professional
lives, and it defines the value system at the heart of the Foulath Group and its many business entities.
If all of us, in our professional and personal capacities, can internalise the beliefs enshrined in the
Foulath Code of Conduct, the Foulath Group’s legacy and its future will remain in good hands. In
varying degrees, we are all the custodians of Foulath Group’s reputation. Accordingly, the company
expects each one of us to behave in an upright manner.
This Code of conduct applies to all officers and employees of the Foulath Group. It is designed to help
us understand our ethical and legal obligations in handling the Foulath Group’s business. Although
this code of conduct does not cover every issue that may arise, it is intended to establish guidelines to
which we can refer in situations where the proper course of conduct may not seem clear.
The guidelines set out in this Code are mandatory and, as such, must be observed by every one of us
at all times.
Clause: 1
National interest
The Foulath group is committed to benefit the economic development of the countries in which it operates. No
Foulath company shall accept any project or activity to the detriment of the wider interests of the communities
in which it operates.
A Foulath company’s management practices and business conduct shall benefit the country, localities and
communities in which it operates, to the extent possible and affordable, and shall be in accordance with the
laws of the land. A Foulath company, in the course of its business activities shall respect the culture, customs
and traditions of each country and region in which it operates. It shall conform to trade procedures, including
licensing, documentation and other necessary formalities, as applicable.
Clause: 2
Financial reporting and records
A Foulath company shall prepare and maintain its accounts fairly and accurately and in accordance with the
accounting and financial reporting standards which represent the generally accepted guidelines, principles,
standards, laws and regulations of the country in which the company conducts its business affairs. Internal
accounting and audit procedures shall reflect, fairly and accurately, all of the company’s business transactions
and disposition of assets, and shall have internal controls to provide assurance to the company’s board and
shareholders that the transactions are accurate and legitimate. All required information shall be accessible
to company auditors and other authorised parties. There shall be no deliberate omissions of any company
transactions from the books and records, no advance-income recognition and no hidden bank account and
funds.
Any deliberate , material misrepresentation of and / or misinformation on the financial accounts and reports
shall be regarded as a violation of the Code, apart from inviting appropriate civil or criminal action under the
relevant laws. No employee shall make, authorise, encourage or conspire in an improper payment, illegal
commission or bribing.
Clause: 3
Competition
A Foulath company or employee shall market the company’s products on their own merits and shall not make
unfair and misleading statements about competitors’ products and services. Any collection of competitive
information shall be made only in the normal course of business and shall be obtained only through legally
permitted sources and means.
On the other hand, it is vital that Foulath Company seek to obtain competitive edge that differentiate it from its
competitors and allows it to win the satisfaction of its customers. All staff are encouraged to participate and
be engaged in this effort.
A Foulath company shall provide equal opportunities to all its employees and all qualified applicants for
employment without regard to their nationality, race, class, religion, colour, ancestry, marital status, gender,
age, nationality, ethnic origin or disability. Human resource policies shall promote diversity and equality in the
workplace, as well as compliance with all local labour laws, while encouraging the adoption of international
best practices.
Employees of a Foulath company shall be treated with dignity and in accordance with the Foulath policy of
maintaining a work environment free of all forms of harassment, whether physical, verbal or psychological.
Employee policies and practices shall be administered in a manner consistent with applicable laws and other
provisions of this Code, respect for the right to privacy and the right to be heard, and that in all matters
equal opportunity is provided to those eligible and decisions are based on merit.
Clause: 5
Gifts and donations
A Foulath company and its employees shall neither receive nor offer or make, directly or indirectly, any illegal
payments, remuneration, gifts, donations or comparable benefits that are intended, or perceived, to obtain
uncompetitive favours for the conduct of its business.
However, a Foulath company and its employees may, with full disclosure, accept and offer nominal gifts,
provided such gifts are customarily given and / or are of a memorial nature.
Clause: 6
Government agencies
A Foulath company and its employees shall not, unless mandated under applicable laws, offer or give any
company funds or property as donation to any government agency or its representative, directly or through
intermediaries, in order to obtain any favourable performance of official duties. A Foulath company shall
comply with government regulations and shall be transparent in all its dealings with government agencies.
Clause: 7
Political non-alignment
A Foulath company shall be committed to and support the constitution and governance systems of the country
in which it operates. A Foulath company shall not support any specific political party or candidate for political
office. The company’s conduct shall preclude any activity that could be interpreted as mutual dependence /
favour with any political body or person, and shall not offer or give any company funds or property as donations
to any political party, candidate or campaign.
Clause: 8
Health, safety and environment
A Foulath company shall strive to provide a safe, healthy, clean and ergonomic working environment for its
people. It shall prevent the wasteful use of natural resources and be committed to improving the environment,
particularly with regard to the emission of greenhouse gases, and shall attempt to offset the effect of climate
change in all spheres of its activities. A Foulath company, in the process of production of its products shall
strive for economic, social and environmental sustainability.
A Foulath company shall be committed to supply goods and services of world class quality standards, backed by
after-sales services consistent with the requirements of its customers, while striving for their total satisfaction.
The quality standards of the company’s products shall meet applicable national and international standards.
Clause: 10
Corporate citizenship
A Foulath company shall be committed to good corporate citizenship, not only in the compliance of all
relevant laws and regulations but also by actively assisting in the improvement of quality of life of the people
in the communities in which it operates. The company shall encourage volunteering by its employees and
collaboration with community groups.
Clause: 11
Cooperation of Foulath companies
A Foulath company shall cooperate with other Foulath companies, by sharing knowledge and physical, human
and management resources, and by making efforts to resolve disputes amicably, as long as this does not
adversely affect its business interests and shareholder value. In the procurement of products and services,
a Foulath company shall give preference to other Foulath companies, as long as they can provide these on
competitive terms relative to third parties.
Clause: 12
Public representation of the Group
The Foulath group honours the information requirements of the public and its stakeholders. In all its public
appearances, with respect to disclosing company and business information to public communities such as
the media, the financial community, employees, shareholders, agents, dealers, distributors and importers,
a Foulath company or the Foulath group shall be represented only by specifically authorised directors and
employees. It shall be the sole responsibility of these authorised representatives to disclose information about
the company or the Foulath Group.
Clause: 13
Third party representation
Parties which have business dealings with the Foulath Group but are not members of the Foulath Group, such
as consultants, agents, sales representatives, distributors, contractors and suppliers, shall not be authorised
to represent a Foulath company without the written permission of the Foulath Company. Third parties and their
employees are expected to abide by the Code in their interaction with, and on behalf of, a Foulath company.
Foulath companies are encouraged to sign a nondisclosure agreement with third parties to support
confidentiality of information.
The use of the Foulath, Bahrain Steel and SULB names and logos shall be governed by manuals, codes and
agreements to be issued by Foulath Holding. No third party or joint venture shall use the Foulath brand to
further its interests without specific authorisation.
Clause: 15
Ethical conduct
Every employee of a Foulath company, including the chief executive, shall exhibit culturally appropriate
behavior in the countries they operate in, and deal on behalf of the company with professionalism, honesty and
integrity, while conforming to high moral and ethical standards. Such conduct shall be fair and transparent
and be perceived to be so by third parties. Every employee of a Foulath company shall preserve the human
rights of every individual and the community, and shall strive to honour commitments. Every employee shall be
responsible for the implementation of and compliance with the Code in his / her environment. Failure to adhere
to the Code could attract severe consequences, including termination of employment.
Clause: 16
Regulatory compliance
Employees of a Foulath company, in their business conduct, shall comply with all applicable laws and
regulations, in letter and spirit, in all the territories in which they operate. If the ethical and professional
standards of applicable laws and regulations are below that of the Code, then the standards of the Code shall
prevail.
Clause: 17
Concurrent employment
Consistent with applicable laws, an employee of a Foulath company shall not, without the requisite, officially
written approval of the company, accept employment or a position of responsibility (such as a consultant or a
director) with any other company, nor provide freelance services to anyone, with or without remuneration. In
the case of the chief executive, such approval must be obtained from the board of directors of the company.
Clause: 18
Conflict of interest
An employee of a Foulath company shall always act in the interest of the company, and ensure that any business
or personal association which he / she may have does not involve a conflict of interest with the operations of
the company and his / her role therein. An employee of a Foulath company, shall not accept a position of
responsibility in any other non-Foulath company or not-for-profit organisation without specific approval.
The main areas of such actual or potential conflicts of interest shall include the following:
a) An employee of a Foulath company conducting business on behalf of his / her company or being in a
position to influence a decision with regard to his / her company’s business with a supplier or customer
where his / her relative is a principal officer or representative, resulting in a benefit to him / her or his /
her relative.
b) Award of benefits such as increase in salary or other remuneration, posting, promotion or recruitment
of a relative of an employee of a Foulath company, where such an individual is in a position to influence
decisions with regard to such benefits.
c) The interest of the company or the Foulath Group can be compromised or defeated.
Notwithstanding such or any other instance of conflict of interest that exist due to historical reasons, adequate
and full disclosure by the concerned employees shall be made to the company’s management. It is also
obligatory upon every employee to make a full disclosure of any interest which the employee or the employee’s
immediate family, including parents, spouse and children, may have in a family business or a company or firm
that is a competitor, supplier, customer or distributor of or has other business dealings with his / her company.
Upon a decision being taken in the matter, the employee concerned shall be required to take necessary
action, as advised, to resolve / avoid the conflict. If an employee fails to make the required disclosure and the
management of its own accord becomes aware of an instance of conflict of interest that ought to have been
disclosed by the employee, the management shall take a serious view of the matter and consider suitable
disciplinary action against the employee.
Clause: 19
Protecting company assets
The assets of a Foulath company shall not be misused; they shall be employed primarily and judiciously for
the purpose of conducting the business for which they are duly authorised. These include tangible assets such
as equipment and machinery, systems, facilities, materials and resources, as well as intangible assets such
as information technology and systems, proprietary information, intellectual property, and relationships with
customers and suppliers.
The involvement of a Foulath employee in civic or public affairs shall be with express approval from the chief
executive of his / her company, subject to this involvement having no adverse impact on the business affairs of
the company or the Foulath Group. Labor Union affairs are exempted from this clause.
Clause: 21
Confidentiality
Every employee of a Foulath company shall ensure, at all times, the integrity of data or information furnished
by him / her to the company. He / she shall be entirely responsible in ensuring that the confidentiality of all data
is retained and in no circumstance transferred to any outside person / party in the course of normal operations
without express guidelines from or, the approval of the management.
Data, information and documents pertaining to the Foulath Group are to be used strictly for the performance of
our respective duties and may be disclosed or communicated to persons outside the Foulath Group only to the
extent that the information in question is needed by such persons in connection with their business relations
with the Foulath Group, or where the information is already in the public domain or is required to be disclosed
by law or court order. In case of doubt as to whether the information may be disclosed and to whom it may be
sent, the employee should consult our supervisor or the Legal Department.
Every employee is required, for the duration of his / her employment with the Foulath Group and after his / her
employment terminates, to keep such information confidential and to use the utmost discretion when dealing
with sensitive or privileged information. Such information includes, in addition to the technology used by the
Foulath Group, intellectual property, business and financial information relating to sales, earnings, balance
sheet items, business forecasts, business plans, acquisition strategies and other information of a confidential
nature. Confidential information must not be discussed with or disclosed to any unauthorized persons,
whether Foulath Group personnel or persons outside the Foulath Group. We must take the necessary steps
to ensure that documents containing confidential information, when sent by fax or other electronic media, are
not brought to the attention of unauthorized persons, whether Foulath Group personnel or persons outside
the Foulath Group. Every employee must take appropriate security measures when destroying documents that
contain confidential information (regardless of the medium by which such documents are recorded).
Every employee must also keep confidential any similar information relating to the organizations with which
the Foulath Group has a business relationship of any kind.
Clause: 22
Whistleblowing
Every employee of a Foulath company shall promptly report to the management, when she / he becomes
aware of any actual or possible violation of the Code or an event of misconduct, act of misdemeanor or act
not in the company’s interest. Any Foulath employee can choose to make a protected disclosure under the
whistleblower policy (a copy of the Whistleblower policy is available on the Foulath Group intranet) of the
company, providing for reporting to the chairperson of the audit committee or the Head of Internal Audit. Such
a protected disclosure shall be forwarded, when there is reasonable evidence to conclude that a violation is
possible or has taken place, by an email, which shall bear the identity of the whistleblower. The company shall
ensure protection to the whistleblower and any attempts to intimidate him / her would be treated as a violation
of the Code.
Foulath Group owns the e-mail and internet systems used in the workplace and thus every employee should
use these systems primarily for work-related communications. Although each employee will have individual
passwords to access the e-mail and internet systems, the Foulath Group reserves the right, subject to applicable
law, to access and monitor the use of these systems in appropriate circumstances.
The employees are strictly prohibited from using the e-mail and internet systems for any improper or illegal
purpose, including the transmission of messages that may be viewed as insulting or offensive to another
person, such as messages, cartoons or jokes that could be construed as harassment of others on the basis of
race, color, religion, sex, age, national origin or disability.
Clause:24
A Shared Responsibility
Every employee is responsible for adhering to the values of Foulath Group in his / her daily lives as employees
of the Foulath Group and for making every effort to ensure that the rules of conduct are respected by all.
Conduct that is contrary to these rules is punishable by disciplinary action up to and including termination of
employment, in compliance with all applicable laws and procedures.
Clause: 25
Compliance with Laws
Foulath Group employees must comply with every local, state, federal, national, international or foreign law or
regulation that applies to the Foulath Group’s business. If we are unsure whether a particular legal provision
is applicable or how it should be interpreted, we should consult our supervisor or the Legal Department.
Many of the Foulath Group’s activities are subject to complex and changing legislation governing domestic and
international trade and commerce. Ignorance of the law is generally not considered a valid defense when an
infraction is committed, regardless of the jurisdiction where the Foulath Group is operating.
Note:
This Code of Conduct does not provide a full, comprehensive and complete explanation of all the rules that
employees are bound to follow. Employees have a continuing obligation to familiarise themselves with all
applicable laws, company policies, procedures and work rules.
Delay in attendance up to 15
minutes without permission or an Verbal Written
2 25% 50%
acceptable excuse if this results in Warning Warning
delaying the work of others
This in addition
Leaving work early without
Written 1 Days to deducting
9 permission or an acceptable excuse 10% 25%
Warning Deductionn the hours of
not exceeding 15 minutes
late coming
Verbal Written
4 Sleeping during working hours 25% 50%
Warning Warning
1 Days 2 Days
7 Manipulation of attendance records 25% 50%
Deduction Deduction
Verbal Written
2 Writing or posting ads on walls 25% 50%
Warning Warning
Verbal Written
15 Refusal to work overtime 25% 50%
Warning Warning
Leaving important/confidential
Verbal Written
18 information on the printer, 25% 50%
Warning Warning
copier or fax machine
Verbal Written
22 Misuse of company email 25% 50%
Warning Warning
Concealing, destroying, or
opening documents received
through mail and making it easy Written
24 10% 25% 50%
for others to do the same. This Warning
clause applies to both printed
and electronic documents/files.
Termination
If the worker fails to perform his
without
5 essential duties under the contract
Notice &
of employment.
Compensation
Termination
If the worker discloses the secrets
without
6 of the establishments by which he is
Notice &
employed.
Compensation
Termination
If the worker is not following the
without
10 regulations prescribed by the law on
Notice &
the exercise of the right to strike
Compensation
Termination
Sexually harassing an employee at
without
12 work whether by reference, speech,
Notice &
act or any other means
Compensation