Message from the Donson Management

To all Donson Trading and Contracting W.L.L (DTC) employees, contractors and other business partners The Board of Directors and senior management of DTC and controlled entities are committed to ensuring that the Company and its employees maintain the highest ethical standards and integrity at a personal and corporate level.
DTC has adopted this Code of Conduct to provide a set of guiding principles, practices and standards of behaviour which are to be observed by all DTC employees, contractors and business partners. The Code underlines the value that the Directors place in DTC’s business image and culture. The Board will keep the Code of Conduct under review to
ensure it continues to reect DTC’s Business values and culture, and the expectations of Employees and the community.

The Code provides guidelines on principles, practices and standards of behaviour. It also serves as a ready reference for some Company procedures. All Employees and Contractors are expected at all times to act consistently with the principles set out in this Code and in the best interests of the Company.

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Controlled By Executive Committee DTC Group Human Resources

Document ID REF-0011 Page 1 of
Issued By DTC Committee Coverage DTC
Date of issue 12 JUNE 2021 Version 1.0
 

DONSON Trading and Contracting WLL Code of Conduct:
Structure of the Code of Conduct
This document contains a summary of the key elements that collectively comprise the DTC Code of Conduct.

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For ease of reference the Code has been grouped under the following headings

Compliance with the Code

Corporate
Employees and the Workplace
Protecting Assets, Resources and Information
Information Technology & Communications Systems
Chain of Responsibility.

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Ethics
DTC expects all of its business to be conducted in compliance with high ethical standards of business practice.
We apply these standards to all our dealings with Employees, customers, suppliers, legal authorities and other stakeholders.
DTC is committed to competing fairly in all markets in which we operate, and to complying with all applicable competition laws and guidelines.
DTC expects all our dealings with customers and consumers to be conducted in good faith and with integrity, and to comply with all applicable consumer and fair trading laws in all jurisdictions in which we operate, and in particular our obligations under
Qatar Law.

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Bribery and Corruption
DTC recognises that our reputation for conducting business in an ethical and honest way is a core company value that must be valued and protected. The Board of DTC has endorsed the DTC Anti-Bribery and Anti-Corruption Policy, covering the areas of:
Bribery and corruption
Receiving gifts, entertainment and favours
Giving gifts, entertainment and favours
Facilitation payments
Political contributions and charitable contributions

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DTC has a “zero-tolerance” approach to acts of bribery and corruption by any of our Employees or Contractors. As well as being morally wrong, bribery and corruption are criminal offences that expose DTC and individuals to the risk of prosecution, fines and
imprisonment.
 

You must notify your manager or a member of DTC’s Executive Committee as soon as possible if you believe or suspect that a conflict with or a breach of the Anti-Bribery and Anti-Corruption policy has occurred or may occur in the future.

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Diversity and Discrimination
DTC is committed to diversity and equality in all areas and all levels of its operations. Diversity means those attributes which may dier from person to person, including gender, age, ethnicity and cultural background.

DTC strengths and dierences and seeks to respect these. There are many areas in which people experience discrimination and DTC will continue to work towards an anti-discriminatory environment, based on open discussions with Employees, Contractors, customers, suppliers and others on perceptions of discrimination and by ensuring that our practices reect relevant legislation and good
practice.

DTC is committed to providing an equal opportunity to all existing and prospective Employees without discrimination based on religion, disability, gender, age, marital status, sexual orientation, race or ethnicity.

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Energy consumption policy
Our aims are to gain control over our energy consumption by reviewing and improving our purchasing and operating practices.
Comply with all relevant statutory regulations to promote energy eciency. Reduce the amount of pollution, particularly greenhouse gas emissions caused by energy consumption. Use fuels as eciently as possible. Reduce where possible our dependence on fossil fuels through the use of renewable energy.
 

Environmental Policies
Donson is committed to minimizing the impact of its business activities on the environment. Donson will do all that is reasonably practical to ensure continuous improvement in environmental performance, including ongoing communication and awareness, active reporting of environmental incidents and implementing changes to our business activities based on the circumstances of past incidents.
Donson requires its employees to cooperate in the management of environmental matters. Employees must monitor the continued eectiveness of the company environmental controls within the scope of their day to day work and report to
management issues of concern or areas of improvement. DONSON will conduct all of its activities in accordance with relevant legislation and government policy.

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EMPLOYEES AND THE WORKPLACE
Occupational Health and Safety policy Donson encompasses a diverse range of business activities including trading contracting and shipping of appointed cargo, its warehousing, transport, and value added services. Donson is committed to eliminating work place injuries and illness by providing a safe and healthy work environment that is free from risk to all employees, contractors, and visitors.

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For Donson to achieve its objective, the board and management will:
Provide and maintain safe workplaces and equipment, including safety equipment and develop and enforce safe work practices.
Comply with all relevant statutory safety and health legislation, regulations, codes of practice and industry standards.
Provide ongoing safety and health information and training to all employees to enable them to identify and eliminate, where possible, all workplace hazards and work practices that could result in an injury or illness.
Clearly dene all roles and responsibilities within Donson.
Maintain a safety and health risk management system where hazards in the workplace
are identied, assessed and eliminated, where possible, or else controlled according to the hierarchy of controls.
Consult with sta on safety and health matters and respond appropriately to all matters raised.
Set measurable safety and health objectives and targets to support the aim of zero injury and illness within the workplace.
Monitor and report on safety and health targets and objectives to ensure continuous improvement.
Provide a consistent approach to safety and health matters across all Donson business activities.
Provide injury management services and support to all employees in the event of a work
related injury or illness in order to facilitate the injured employees’ return to work.
Promote a culture where personal responsibility for safety and health at all levels within the organization is second nature.
Commit adequate resources to meet all statutory safety and health obligations
and to implement this policy.
A high standard in Workplace Safety and Health can only be achieved with the co-operation and active participation of all Donson employees, managers and contractors.

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Fatigue Management
Fatigue is an ongoing acute state of tiredness leading to mental or physical exhaustion and prevents people from functioning within normal boundaries. Fatigue is more than feeling tired or drowsy, it is a physical condition that can occur when a person’s physical
or mental limits are reached. Managers, supervisors and individuals all share a responsibility to ensure that fatigue does not impact on the health or safety of themselves or others, and to minimise and manage the adverse eects of fatigue in the workplace. DTC has identied that Employees and Contractors falling under one of the following categories are at an enhanced risk in relation to fatigue in the workplace;
 

Shift workers
Commercial vehicle drivers

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DTC recognizes that shift workers can be one of the main worker groups susceptible to fatigue, due to disruption to a body’s natural body clock rhythm. Sleep disruption is a common problem for shift workers. DTC has identied that commercial vehicle drivers are a potentially high risk group in relation to fatigue in the workplace. In order to minimise the risks of fatigue among commercial vehicle drivers, DTC has:
Implemented a Fatigue Management Plan for all DTC commercial vehicle drivers
Compiled a DTC Journey Management Procedure that defines the procedures to be followed for every journey of over 200kms distance or 2.5 hours duration
Prescribed that a Journey Management Plan must be set up for every journey of over 200kms distance or 2.5 hours duration
DTC has established Fatigue Management Plans to ensure Employees and Contractors are fit for duty in an eort to prevent or minimise the effects caused by fatigue related incidents.

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Alcohol and Drugs
DTC is committed to providing a safe and healthy working environment for all Employees, Contractors and visitors by eliminating hazards associated with the inappropriate use of alcohol and other drugs (including prescription and over the counter medications). It is a requirement that all Employees and Contractors are not aected by alcohol or drugs during working hours. This policy applies to all DTC Employees, Contractors and visitors working for or on behalf of DTC or attending a DTC site. Where an Employee or Contractor is taking medication, or is suering from any condition that may aect or limit their ability to carry out work, they are to advise their supervisor. Any Employee, Contractor or visitor may be required to undertake random, blanket or “for cause” drug and alcohol testing. Where an Employee or Contractor returns a positive test or fails to undertake a test he/she will be suspended without pay until such time as deemed t for work or their employment or contract is terminated. Where there is a positive test result any subsequent tests to determine tness for work will be at the person’s own expense. DTC recognises that alcohol and drug abuse are medical problems that can be treated. We will help any of our Employees or Contractors who want to overcome these problems.

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Vehicle Standards
In setting vehicle standards DTC seeks to maximise safety and minimise environmental impact. DTC uses a combination of handheld and/or in-vehicle monitoring systems equipped with GPS tracking for monitoring and communications purposes for vehicles engaged within one of DTC’s transport eets. DTC aims to use fuels as eciently as possible, and to work towards all vehicles in our fleet being tted with the latest emission reduction technologies. All vehicles must be kept clean and in good mechanical repair at all times. All vehicles should be sign-written with the appropriate DTC logo. Vehicles may not carry any signage that may cause oence to the public.

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Uniforms
The majority of DTC Employees and Contractors are provided with uniforms to provide identication for the security of customers and to enhance the image and reputation of DTC, as well as incorporating high-visibility panels as an aid to the safety of the Employee or Contractor. If you are provided with a uniform, you are to:
Wear the uniforms you have been issued with at all times whilst performing duties for or on behalf of DTC.
Ensure that the appropriate DTC logo is clearly displayed on uniforms and clothing.
Keep your uniform in an “as new” clean and neat condition.

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Personal Protective Equipment
As part of DTC’s hazard management procedures, Employees, Contractors and visitors to DTC sites must wear Personal Protective Equipment (PPE) where required. DTC has written procedures that dene when and where Employees, Contractors or visitors to any DTC sites should use PPE and what types of PPE should be used. DTC also provides training and instruction in the use and maintenance of PPE to ensure Employees receive the desired level of protection from the equipment. Employees and their supervisors must ensure that PPE is maintained in a condition that ensures its continued eective use. Damaged or defective PPE should be discarded or repaired according to the manufacturer’s specications.

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Mobile Phones and Other Devices
DTC has policies that provide directions for the use of the various types of mobile devices (phones, PDA’s, iPads etc.) that are used for voice and data transfers:
Mobile devices are issued to Employees and Contractors on a needs basis for business use only.
DTC reserves the right to be reimbursed for any personal or
excessive use Only authorised personnel are permitted to use a mobile device at any work site where mobile plant, machinery and trucks are in operation and may only do so when in a safe position away from the operating plant/vehicles
Mobile devices are not to be used for unlawful or unacceptable practices such as bullying, harassment, discrimination, or anything in breach of DTC’s Diversity
 

Policy
All mobile devices issued to Employees and Contractors must be maintained in good order.

You must advise your manager or supervisor of any damage to or faults with your mobile device.

Your mobile devices and all accessories, including chargers, must be returned to your manager when you leave employment with DTC. Use of personal mobile phones during work time should be minimised and must not interfere with work practices or other workers’ concentration
Use of mobile devices while driving shall comply with the QATAR Road Traffic Code.

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Customer Service
All DTC Employees and Contractors are to ensure that our customers and our customers’ customers are treated with the utmost respect and courtesy at all times. Respond with courtesy to any complaints or issues raised by customers or anyone else, including the general public, by trying to resolve the issue immediately and/or politely advising that the matter will be reported to DTC management for immediate action
and/or response. Any such issue must be promptly reported to DTC management.

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Driver Behaviour
“Driver” refers to DTC Employees who are employed to drive a Company owned vehicle or who drives a Company owned vehicle as a part of their job, and to Contractors who undertake delivery or driving related duties for DTC.
 

As a Driver you are required to:
Comply with all laws in the conduct of your activities as a Driver
Hold a current driver’s licence applicable to the class of vehicle being driven. Any suspension or cancellation of such license will be deemed as an inability for you to perform your work
If engaged in delivery services, promptly undertake each of your delivery services in conformity with the standards of best industry practice
Wear the uniforms you have been issued with at all times (additional clothing may be worn provided it does not carry identification or the logo of another transport company or organisation)
If you have been issued with an ID badge, carry it with you at all times
Drivers shall at all times act with respect towards other Employees, Contractors, customers, and other road users. Aggressive and/or offensive behaviour will not be tolerated.

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Maintenance of Business Records
Employees are to ensure that they accurately and rigorously maintain all records relating to DTC’s business and its operations. Such records include, but are not limited to:
Correspondence, memoranda, reports, emails and file notes
Internal Audit reports
Customer Service Improvement Requests (CSIRs)
Project plans
Service Operating Procedures (SOPs)
Risk Assessments
Safety Documentation
Journey Management documentation
Vehicle maintenance records
Other HVAA-related documents

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Employees shall:
Ensure all written communications are businesslike and do not contain material that would harm our reputation if made public
Group and file all records in a logical manner for ease of reference
Ensure electronic records are kept in a logical sequence and regularly backed up
 

External Communications
Employees, including management, are not to communicate with the media on behalf of DTC. Only the Company Secretary or an officially designated Disclosure Officer are authorised to speak or disclose information on behalf of DTC.

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CHAIN OF RESPONSIBILITY
DTC is committed to complying with the legal and operational requirements of the Chain of Responsibility legislation. The DTC Chain of Responsibility systems are designed to ensure the health, safety and welfare of all those who are involved in the storage and
distribution of goods - including receivers, packers, loaders, Drivers, contracted transporters, other parties in our transport chain and the general public. All Employees are responsible for supporting and implementing the DTC Chain of Responsibility Policy and its supporting procedures as it applies to their role. DTC is committed to providing Employees and Contractors with ongoing training and
education about all relevant aspects of the Chain of Responsibility.