Whistleblowing Policy

Company may impose a penalty against the defaulter from inside the Company in case of failure to comply with provisions of this Policy and if he did not disclose infringements came to his attention. The Company may adopt legal actions in accordance with regulations and bylaws of the Company. When it is brought to attention of the Company that someone from outside the Company knows about infringement and he covered-up the same; then the Company may submit a report on the same to competent entities, as applicable.

• • Confidentiality: The company shall not uncover identity of the whistleblower and shall maintain his safety, shall not make him accountable as a result of his report, except in conditions where the law obligates the Company to disclose the identity of the whistleblower to conduct investigation depending on nature of the violation. Further, the Company shall maintain the non-spread of the report or details thereof to parties other than those who are concerned with the report.
  • Protect the whistle-blower in accordance with related laws and regulations, adopt all necessary actions to protect him and not to harm him. The Company shall incur any expenses or charges to maintain the reported information or to maintain the whistleblower.
  • Methods of whistle-blowing: provide proper methods for infringements whistle-blowing to achieve quick and easy whistleblowing via all available methods, provided that all reports shall be checked periodically and systematically in order to process the report at the earliest.

Each infringement whistleblower shall observe the following:

• Seek credibility in whistle-blowing (reporting) by avoidance of rumors, fears, and allegations without a real basis.
• Shall not attempt to disrepute others, entrap, revenge individuals with good faith, or to undermine confidence in the Company or affiliates thereof.
• Seeking accuracy in reporting and avoid incomprehensible indications, clarifying all details related to the report that could provide guidance to violation condition, description, and place thereof. Whistle-blower shall enclose whatever provides more details and evidence on violations as possible and inconsistency with the nature of the violation.
• Report on violation swiftly at the earliest possible chance.
• Incur outcomes of malicious allegations. The Company may adopt all lawful actions against the whistle-blower if he is an affiliate thereof or litigates him before judicial tribunals.
• Whistle-blower shall observe strict confidentiality of the report to achieve general interest and to give the Company opportunity to conduct respective obligations towards the report, conduct necessary search and investigation in accordance with established actions, and to maintain reputation of the Company against allegations based on insufficient evidence, dependency on rumors, uncertainties, personal fears, or concern not based on realities.

• The Company welcomes any report intends to guide the Company to rectify fault, take action, to detect infringements, or to strengthen and protect values through the whistle-blowing on the below activities:
  • Financial and administrative corruption: represented in infringing financial rules and provisions organizing administrative and financial work progress in the Company and bringing in material or moral benefit, directly or indirectly, to the violator/offender, including but not limited to: theft, embezzlement, manipulating financial notes through internal information, conflict of interests, bribe, influence peddling, forgery, fraud, deceit, manipulating accounts and data, acquisition of any material or moral benefit.
  • Violating rules, regulations, and instructions applicable under the scope of this Policy.
  • Violating the Company’s policies and procedures: this means any conduct violating or potentially violating any policy or process handbook approved by the Company.
  • Violations to environment, health and safety procedures (HSE): this involves conduct vulnerable to cause damage and harm to environment or workplace, or may endanger safety and security of staff or properties, or may form risk over health and safety of humans.
  • Harassment and improper actions, violating public order, Islamic morality, valid traditions, and customs, including conducts that could discredit reputation of the Company or, leave the Company vulnerable to criticism, or causing damage to the same as a result of improper actions or violating public order and Islamic morality.
  • Misuse of the Company’s properties or assets through the unauthorized use overuse of authorities, unpermitted authorities, abuse, or such use that could endanger the safety of the Company’s properties and assets.
  • Abusing power by staff and executives of the Company in decisions against the interest of the Company or subsidiaries, or against one of the staff.
  • Adopt unlawful operations of the Company and giving implication to others that such operations are lawful, which causes material and unmaterial damages.
  • When there is an explicit conflict of interest in any contracts or works conducted by the Company.
  • In the case of law circumvention by adopting unlawful operations causing financial losses and legal consequences.
  • In case of knowing about cover-up on clear lawful breaches damaging business of the Company or any employee thereof.
  • In case of giving powers and authorities granted by the Company to third parties unlawfully and without legal cause such as: exchanging passwords.
  • Violations against related parties being conducted by an employee of the Company, or threatening with unduly termination of contracts
  • without cause in the executed contract.
  • When a related party, directly or indirectly, expresses or gives hints on giving financial or non-financial benefits, or promise employee of the Company with benefit.

• Scope of this Policy is to protect all who raise reports and complaints against infringements and violations committed by any individual for which a procedure of the reported infringed work, whatever it is, passes through NUPCO.
• Moreover, the scope of the Policy involves actions conducted inside or outside headquarters of the Company related to reputation thereof and impacts the performance of affiliates, or leaves the Company vulnerable to criticism from others with the intention of insulting.

The objective of this Policy is to provide any information from inside or outside the Company to guide departments of the Company to assume respective duties through the whistle-blowing on infringements, improper conducts and actions violating regulations and instructions, unethical behaviors, or conducts violating policies, procedures and instructions of the Company.

The National Unified Procurements Company for Medical Supplies (NUPCO) has developed policies and processes ensuring the achievement of high-level transparency, disclosure, and integrity in dealings thereof. NUPCO has complied with the implementation of such policies and processes on infringements and whistleblowing (reporting) on the same and significant developments in accordance with legal and regulatory requirements without contravening instructions received from competent entities.

The following clauses and expressions have the meaning set forth in front thereof unless otherwise, text requires: Company: National Unified Procurements Company for Medical Supplies (NUPCO), including NUPCO subsidiaries. Board of Directors: NUPCO Board of Directors. Chief Executive Officer: NUPCO Chief Executive Officer (CEO) Staff of the Company: Each natural person associated with NUPCO under the employment contract. Related Parties: Service providers, suppliers, contractors, customers, bidders, workers, service providers who provide service directly inside or outside the company whether in warehouse/stores, etc.