Fighting Bribery and Corruption Policy

Warba is fully committed to fighting all forms of corruption in every country where it’s offices are located. All employees are expected not to accept or offer, directly or indirectly, during the course of their duties, any money, gifts, special services or any other benefits to or from government officials, politicians, or any other person or organization, with a view to inducing them to do or not do something within the scope of their job or position.

The international regulations for fighting corruption also apply to indirect corruption carried out by third parties in the name of or on behalf of a company or an individual. In many countries, companies and individuals may be liable for civil and criminal penalties, including fines and prison sentences.

The Company recognizes that corrupt practices committed in one country may result in civil and criminal proceedings not only in that country but also in another country, given the extra-territorial application of certain regulations related to fighting corruption.

Each employee at Warba should be aware that corrupt practices will expose them personally and the Company to very significant adverse commercial consequences that include loss of tenders or contracts, in addition to serious damage of Company reputation.

Compliance Program Elements

  • Warba has developed internal policies, business code of conduct and ethics and procedures that address compliance expectations, provide guidance on dealing with potential compliance issues, explain when and how to communicate compliance issues to appropriate personnel, and detail how potential compliance issues will be reviewed and resolved.

  • Warba has established a Compliance Committee and a Compliance & Quality Assurance Manager who will be responsible for implementing the Compliance Manual, carrying out compliance checks, and overseeing the Warba compliance program.

  • Warba is committed to providing proper and continuing training to all employees on the compliance program, internal policies, procedures and business code of conduct and ethics

  • Monitoring and auditing activities are important parts of an effective compliance program. The Compliance and Quality Assurance Manager conducts ongoing monitoring and auditing activities to ensure ongoing observation, review and analyze key activities and risk factors to identify potential compliance breaches and to update the compliance activities, based on changes in applicable laws and regulations.

  • Warba promotes professional excellence and encourages open and honest communication among all personnel.

    Warba employees and external stakeholders may report in any of the following ways:

    • Compliance Hotline: Directly to the CQAM through the anonymous hotline number at [00964 783 377 9903]

    • Website: Anonymous reports can be made through the Warba Website: Navigate to www.warbaco.com, at the bottom of the page, click, “Report”

    • Open door policy: Phone calls or face-to-face reports to the CQAM can be made at any time. In all cases, managers or supervisors who get a report will be required to discuss the report with the CQAM

  • All employees shall abide by the standard level of conduct and disciplinary described in:

    • Internal System and Regulations

    • Employment contract and its annexes (Job Description, etc.)

    • Warba policies, and any other documents related to standards of discipline that may be adopted by the company.

  • Warba is committed to taking prompt corrective action to address any fraud, waste, abuse, noncom-pliance, misconducts or any other improper activity identified through internal audits, investiga-tions, effective communications channels made available by Warba, or other means.

Quality Policy

  • • Using reputable suppliers for drug provision.

    • Consistently providing products and services in a manner that satisfies client requirements in all respects.

    • Implementing appropriate actions to address any risks and opportunities associated with internal/external issues, and to meet the needs and expectations of interested parties.

    • Complying with statutory and regulatory requirements.

    • Continued improvement in servicing Warba clients by enhancing Warba’s Quality Policy objectives and performance evaluation, including audit results, corrective actions, and management review.

    • Establishing annual quality objectives at strategic and operational levels within the Company that will be measured and reported upon at the management review meeting.

    • Ensuring all Company personnel are fully competent to carrying out their assigned task.

    • Controlling and continually monitoring all facilities, products and projects undertaken.