Our Values

Focus on Results

Strong sense of focus on results, driving tasks and projects through to completion with the flexibility to adapt to changing situations.

Integrity and Respect

Work with integrity and with respect towards people as well as the environment in which we operate.

Exercise responsibility for our actions.

Maintain Commitment to Conveyor Group and to each other.

Work collaboratively with creative spirit as we challenge ourselves to develop the business and ourselves.

Entrepreneurial Spirit and Initiative

We ought to elicit and maintain the entrepreneurial spirit and initiative that are creative in essence, for any sustainable growth to be achieved.

How to Use this Business Conduct

The business conduct clearly sets out the company’s expectations and as a member of the company you should ensure that you understand how it applies to you and your work activities. There are additional regulations, policies and procedural requirements that you are required to abide by and hence you should ensure your awareness of it. The Business Conduct is incapable to describe every possible scenario, however it does provide relevant guidance. To assist you, the key sections are laid in the following.

Who does this Business Conduct apply to?

The Business Conduct applies to the Board of Directors, all full or part time staff [‘Employees’] and contract, agency or temporary and controlled joint ventures. Additionally, all third party contractors, agents, advisors, consultants or other business associates [“Industry Partners”] must follow the principles of this Business Conduct when they work with, or on behalf of us.

In the cases of Joint ventures where Conveyor Group possesses the rights to exercise control and/or is the operator, this Business Conduct applies to all of the activities. However, in the cases where Conveyor Group does not have the control, best efforts are to be taken to influence the operation of the joint ventures.

Advice and Guidance

Where you are unclear on any aspect of the Business Conduct or you are unsure of the right action to take in a situation then always seek help. Advice can be obtained from many sources including your line or functional manager, HR representative or local legal advisor.

Personal Responsibility

As an Employee of Conveyor Group it is your personal responsibility to act in accordance with the requirements set out in this Business Conduct. Please read the Business Conduct carefully and refer it when you are uncertain of the correct action to take. You must understand, promote and apply this Business Conduct to your conduct and work with Conveyor Group.

If you suspect or become aware of any violation of the Business Conduct or have concerns that some activities carried out by others may breach the Business Conduct, you should report your concern. If you ignore or condone breaches of the Business Conduct then you are not acting in the best interests of Conveyor Group. We welcome and encourage reporting of any concerns you have about Conveyor Group activities or practice which are, or appear to be, breach of this Business Conduct.

The Duty of Managers

Those of you who are managers have an additional responsibility to ensure that this Business Conduct is applied to our business and in particular, you must ensure that:

1. all staff report to you have a copy of the Business Conduct and have been trained in its application;
2. you support staff who, in good faith, raise questions or concerns;
3. you demonstrate your personal commitment to the Business Conduct and lead by example;
4. you monitor the application of the Business Conduct and ensure consistent enforcement;
5. you ensure that all reports of violations are appropriately investigated;
6. business processes in your area of responsibility comply with the Business Conduct.

Breaches of the Business Conduct

Failure to company with the Business Conduct may lead to disciplinary action up to and including dismissal or, in the case of Contract Staff or Industry Partners, cancellation of contract.

Monitoring & Audit

The Group Compliance Manager will oversee the monitoring of the application of this Business Conduct and business units will be subject to periodic audits of compliance. The Conveyor Group Compliance Committee will monitor progress and the effectiveness of the compliance programme and will report periodically on the status of implementation and compliance to the Board of Directors.

We Comply with All Applicable Laws

Compliance with Laws

We comply with all applicable local and international laws within the countries where we do business. Where differences exist between the standard of the law or regulations and the requirements of the Business Conduct the higher standard will be applied .Where laws conflict or you are unsure of the correct action to take you should consult with your legal advisor. Senior managers with responsibility for operations in a country must ensure that our business processes are in compliance with the law.

Trading in Shares

Buying or selling publicly traded shares where you are aware of “inside” information which is not yet publicly disclosed, or passing such information to others, is called insider trading and is illegal and prohibited by Conveyor Group. This applies whether share transaction is made directly or through another person.

Trade Restrictions and Export Controls

Some Countries impose restrictions on exports and business dealings with other countries, entities and individuals. The laws and regulations governing these restrictions are complex and subject to change. If you are responsible for the export or re-export of any items, [including equipment, materials, software or services], you must be aware of these restrictions and ensure they are complied with.

We Are Committed To High Environment, Health and Safety Standards

The health and safety of people and the protection of the natural environment in which we operate are critical business considerations for Conveyor Group. We apply significant effort in managing out EHS risks and achieving our EHS objectives.

Environment

We work with respect for the environment in which we operate and we identify, assess and manage our environment risks. We set, and seek to achieve, targets that promote the efficient use of resources to reduce and prevent pollution and protect biodiversity. At all times we seek to engage openly and honestly with our stakeholders, and particularly with those people affected by operations.

We meet applicable legal standards for all aspects of environmental management and where legal requirements do not exists, or they are considered inadequate, we apply responsible standards.

Health and Safety

We are committed to achieving high standards of health and safety performance as we believe that all accidents, occupational illness and injuries are preventable. Our priority is to ensure that all our people – regardless of where they work or what they do – return home safely and well at the end of every working day.
Health and safety practices are government by EHS policies which apply to all personnel and, in addition, business may create local procedures which you should follow. Conveyor Group provides a safe place to work and you have a personal responsibility to ensure that you are competent and appropriately trained to undertake your work activities.

You must

1. Immediately stop any work that appears to be unsafe;
2. Comply with the requirements of our environmental, health and safety procedures, and assist those working with you to do the same;
3. Ensure you identify hazards and take steps to control environmental, health and safety hazards associated with your work;
4. Use the personal protective equipment required for the task you are undertaking;
5. Handle, transport and arrange for the disposal of raw materials, products and wastes in a safe, environmentally and socially responsible manner;
6. Engage regularly, openly and honestly with our stakeholders, and particularly those people affected by our operations, and take their views into account in our decision-making;
7. Make sure you know what to do if an emergency occurs at your workplace and the visitors are familiar with emergency procedures;
8. Report to your manager any accident, injury, illness, unsafe or unhealthy condition, incident, spill or release of material to the environment so that appropriate action can be taken to prevent, correct or control those conditions.

You must not

1. Undertake work unless you are trained, competent, medically fit and sufficiently rested and alert to do so;
2. Undertake work when your performance is impaired by alcohol or other drugs, legal or illegal, prescribed or otherwise;
3. Ignore a potential or actual EHS incident or assume that someone else will report it.

We Treat Employees, Industry Partners and Local Communities Fairly and With Respect

Fair Employment practices

We are committed to eliminating discrimination and encouraging diversity amongst our workforce. We treat all of our employees, whether full time, part time or temporary, fairly and with respect. Decisions related to recruitment selection, development or promotion are based upon merit and must not be influenced by factors such as gender, marital status race, ethnic origin, colour, nationality, disability, religion, sexual orientation or age.

You must not:

1. Engage in sexual harassment – i.e. unwelcome sexual advances, requests for sexual favours, physical contact or
2. Behave in any way that could be viewed as offensive, intimidating, malicious or insulting;
3. Create or support a hostile or intimidating work environment including one in which employees may feel forced to engaged in inappropriate work practices in order to ‘be accepted;
4. Humiliate, denigrate or injure another person;
5. Make racial, ethical, religious, age-related, or sexual jokes or insults;
6. Distribute or display offensive material, including inappropriate images.

Privacy of Personal Information

We will maintain the confidentiality of all employee personal information. Access to employee personal information is restricted to Conveyor Group Employees, excepting who are authorized and who have a business need for that information.

We Do Not Make or Accept Any Illegal Payments

The giving or receiving or bribes of any description, regardless of amount is prohibited. This applies to Employees, Contract Staff or Industry Partners working on our behalf.

Illegal Payments – Bribery and Corruption

Conveyor Group conducts its business honestly and transparently and does not seek to exercise improper influence on any individuals or entity. We are subject to domestic and international anti-bribery and corruption laws which target bribes in relation to both commercial entities and public officials.

We do not offer or give, nor request or receive, any bribe of any description or value to obtain or retain business, to reward the improper performance of someone’s duties or for any other purpose. This applies to everyone who works for, or provides services to, Conveyor Group.

Although bribes are usually associated with money they can also be disguised in other forms such as the offer of a job to an individual or family member, travel, accommodation, use of assets or preferential terms on a product or service. Exercising poor judgment with respect to giving or receiving gifts and hospitality could also result in a breach of the law with serious consequences for individuals and the Company.

Facilitation or ‘Grease’ Payments

Facilitation or ‘grease payments are small value payments made to public officials to speed up a routine administrative process to which the person is entitled. Example are a payment to expedite the issue of a visa, to obtain an official stamp or signature on a document , to facilitation payments and Conveyor Group does not permit such payments to be made either directly or by those who work on our behalf. If you are asked to make a payment then you should refuse and report it to your line manager and email the details to the compliance mailbox emran @ conveyor . com . bd where it will be treated in confidence. If under exceptional circumstances a facilitation payment is made under duress, such as where your health or safety is at risk, then this should be immediately reported to your line manager and legal advisor.

Gifts and Hospitality

Bona fide hospitality and promotional or other business expenditure which seeds to improve Conveyor Group’s image, to better present its capability and services or establish cordial relations are recognized as an established and important part of doing business.

Reasonable and proportionate gifts and hospitality for these purposes is not prohibited. However, inappropriate, frequent or lavish gifts or hospitality can result in an actual or perceived conflict of interest, the development of an obligation on the part of the recipient or, could be considered as bribery.

You must not:

1. Request or solicit gifts or hospitality from an individual or organization;
2. Give or receive hospitality when engaged in a bidding process;
3. Give or accept cash or cash equivalent [e.g. gifts vouchers or loans]
4. Provide or accept any gifts or hospitality that is inappropriate, indecent, and illegal or could cause reputation damage to Conveyor Group;
5. Pay for any gifts any gift or hospitality personally to avoid the approval process or recording requirements.

You must be ensured that any gift or hospitality:

1. Is for a bona fide business purpose; commission;
2. Is given or received openly and transparently;
3. Complies with applicable laws;
4. Complies with rules of the receiving organization;
5. Is not given or received frequently between the same individuals;
6. Is properly recorded.

Note that additional rules apply for gifts and hospitality provided to Foreign Public Officials and you should familiarize yourself with these.

Policy summary for gifts and hospitality

1. Staff can self approve gifts and hospitality providing that the requirements of the Gifts and Hospitality Policy are met and values are less than US$50 (gift) and US$150 (Hospitality). Above these Limits, or if it is a frequent occurrence, management approval is required as defined in the Policy.
2. With the exception of low value (US$25) promotional items such as calendars, diaries, caps, tee shirts etc., all gifts and hospitality must be recorded on the Conveyor Group Gifts and Hospitality register.
3. Business may apply more restrictive approval limits to suit local culture and conditions and staff should ensure that they are aware of the requirements that apply to them.
4. Expenditure related to Foreign Public Officials

Who is a Foreign Public official?
A Foreign Public official includes officials, whether elected or appointed, who hold a legislative, administrative or judicial position of any kind of a country or territory outside the Bangladesh. It also includes any person who performs public functions in any branch of the national, local, or municipal government or who exercises a public function for any public agency or enterprise of such a country or territory.

The above includes Employees of National Oki companies, State owned companies, suppliers or joint ventures, government ministries, immigration, customs and politicians or political candidates.

There are many circumstances where we may incur legitimate expenditure related to foreign public officials. This includes expenditure which seeks to improve Conveyor Group’s image, to better present its capability and services or establish cordial relations.

However, under the UK Bribery Act and many other local and international laws, the offer, promise or giving of any financial or other advantage to a Foreign public official with the inter of obtaining or retaining business is an offence {a bribe} which carries severe penalties for individuals and companies.

You must ensure that any gift, hospitality or other expenditure related to a foreign public official cannot be considered as a bribe. This applies even under circumstances where there is a contractual requirement to incur expenditure such as the provision of training or technical/operational meetings.

You are expected, and it is your personal responsibility, to use your good judgment. You must ensure that any expenditure on foreign public officials is properly authorized and is transparent, ethical and in compliance with local and international laws, this code of Business Conduct and any other policies that have been implemented.

Our Commitment To Corporate Responsibility

Conveyor Group behaves responsibly in all aspects of our business to create an environment that help us to successfully deliver our business plans, continue our growth strategy, and contribute to social and economic development, both within and outside of our core business activities. We call this Creating Shared Prosperity.

Human Rights:

Conveyor Group supports and respects the protection of internationally recognized human rights. We uphold and promote human rights within our sphere of influence which can include, but is not limited to, employees, contract staff, industry partner and suppliers.

Child Labour:

Conveyor Group does not use underage, forced or compulsory labour and everybody who works for Conveyor Group is expected to be aware of this and abide by this commitment.

Charitable Donation:

We support local and community social enterprise projects and education and capacity building initiatives and we also make charitable donations to appropriate and relevant causes.

Political Contributions and Activities:

We do not make any political contributions to political candidates, parties, committees or their representatives, and we do not participate in any invention in the political process of any countries.

Accuracy of Accounts & Records:

Truthful and accurate information, whether financial or non-financial in nature, is essential to support sound business decisions, to meet our legal and regulatory obligations and meet our responsibility to all of our stakeholders. We maintain internal accounting controls and ensure that books, records and accounts reflect accurately, transparently and in sufficient detail, all transactions in connection with our business.

Note: It is our intention to practice the rules above within our companies. Any similarities to/with other organization’s rules are merely coincidental.