In furtherance of our desire to have a culture founded on principles that drive a sustainable business, this code of business conduct is designed to set certain standards of conduct for all employees and officers of General Machinery Limited (Gmach) as well as persons that provide goods and services on behalf of Gmach and other stakeholders such as customers and suppliers. These rules do not cover every issue that may arise but set out basic principles to guide all employees in carrying out their duties.

These rules are to be adapted as the case may be, depending on local laws and regulations or should local codes of business conduct apply. In the event that any aspect of the code is unclear or is not precise enough, the employee should obtain clarification from his/ her supervisor as to how to handle the situation.

All employees, whatever their position, must comply within the limits of their duties, within the rules set forth below, that form part of their normal duties of loyalty and good faith and ensure that they are also complied with by all persons In their teams or under their supervision.

General Machinery Limited (hereinafter referred to as “Gmach”) will adhere to the highest legal, moral and ethical standards in its relationship with its employees, customers, competitors, partners, government, media, business colleagues, suppliers and the public.

This code of conduct applies to all General Machinery Group of Companies as listed

below;

1. General Machinery
2. Victoria Motors Limited
3. Victoria Equipment Limited
4. Victoria Pumps Limited
5. Victoria Engineering Limited
6. Victoria Motors (Rwanda) Limited
7. Kibira Properties Limited
8. Mercantile Car Rentals Limited
9. Mercantile Executive Services Limited
10. VEQ Hoima Limited
11. SUS-Tech Limited
12. Specialised Motors Limited
13. Merca Limited

To maintain its reputation on integrity, all Gmach employees must act responsibly, fairly, openly and honestly in all business matters.

The following policies and principles represent and summarise Gmach’s business conduct, applicable to all its Directors and Employees.

The code of conduct is designed to ensure that all Gmach employees act with honesty and integrity in all business dealings and should provide accurate, full, and complete disclosure to its members In Its public findings and disclosure as required by law. The company views violations of this code as a severe disciplinary matter.

Gmach is governed by Ugandan laws and is required to comply with, Ugandan legislations and the respective Acts and regulations. We will therefore conduct all our activities in compliance with all applicable laws, regulations and judicial decrees wherever we conduct business.  At no time will employees take any action on behalf of Gmach that they know, or reasonably should know, violates any law or regulation.

Although not all employees are expected to be well versed with the various laws and regulations that apply to their business activities, it is important to know when to seek help or advice from colleagues, supervisors or third parties. Beyond compliance with the relevant laws and regulations, all employees are expected to carry out their duties with diligence and should meet the highest standards of professional conduct while dealing with customers or other stakeholders.

Employees should ensure that all partners and supporters are treated with fairness, with the selection criteria being objective and transparent such as quality of service delivery, meeting deadlines and general courtesy. Gmach’s goal is for each employee to act in a manner which exercises sound judgement, high morals and ethical standards in business dealings on behalf of the Gmach.

3.1 Employees' Responsibilities

1. To understand and comply with Gmach's code of conduct and the various policies and procedures in carrying out their respective tasks.
2. To be honest, fair and trustworthy in all business activities and
3. To provide and support a culture that values ethics and
4. To provide and support an environment that promotes equal opportunities and freedom from harassment to all.
5. To avoid all conflicts of interest between work and personal
6. In matters that involve Gmach, report to the General Manager, Group Head of HR or Head of department any suspected violations of the law, code of conduct and any other violated policies and procedures.
7. Managers should set good examples for other employees and are responsible for directing the actions of others.

Every manager and/or supervisor is expected to take the necessary steps to ensure employees comply with this code. They should provide guidance and assist employees in resolving questions concerning the code but also allow employees to express any concerns regarding compliance with this code of conduct.

No one has the authority or mandate to order another employee to act contrary to this code of conduct nor cooperate in any investigation regarding such possible violations.

3.2  Business Practices

It is Gmach's policy to deal with its employees, customers, business associates, partners, suppliers, competitors, the Government and all stakeholders that it operates business with in a straightforward and honest manner.

3.2.1 Conduct with Employees

Our employees are a valuable resource and our goal is for every employee to be personally Involved and share in the company's success. Gmach shall strive to treat all employees fairly and equally in all aspects of the employer-employee relationship.

3.2.2 Conduct with Customers

Serving customers is the focal point of our business. Exceeding customer expectations is the best way to ensure sustainable business growth. It is the Gmach policy to work with customers and develop a long-term relationship, understanding and anticipating their needs, to identify and remove obstacles that may be perceived while conducting business with us, and to promptly but courteously respond to customer inquiries and requests.

In addition, employees are obligated to accurately represent the services of Gmach in marketing, advertising and sales efforts. We will strive to provide services of the highest quality and continuously improve the quality.

3.2.3    Conduct in the community and environment matters

Gmach's environmental, health and safety policy is to comply with national and environmental laws and regulations, as well as to prevent occupational illnesses and injuries, conserve natural resources, minimize waste and limit environmental Impact.

Gmach is committed to preventing illnesses and injuries, conserving resources and minimizing waste. Gmach aims at improving efficiency and profitability while reducing /or eliminating the environmental impact on employee health and safety.

Gmach is committed to protecting the health and safety of its employees, customers, visitors and the general public. It is the Gmach policy to ensure that all facilities, services or products meet the health and safety standards.

3.2.4    Interaction with competitors

Gmach 1s an astute competitor in the market. Employees will, however, not engage in illegal or improper acts of acquiring competitor info (trade secrets, customer prospectuses, price lists, new developments, facilities) and competitor operations.

In addition, Gmach will not hire employees from competitor companies for purposes of obtaining confidential information, on competitors' personnel, customers and suppliers, nor seek such information from competitor employees subsequently hired by Gmach.

3.2.5 Supplier/ vendor, contractor relationships

When purchasing goods and services, Gmach will select suppliers on the basis of ability, performance and value, irrespective of their political affiliation or position on public policy issues. Procurement decisions shall reflect the best judgment of Gmach management with regard to quality, technology, responsiveness, as well as cost.

Persons acting on behalf of Gmach and/or involved with vendors shall refrain from any personal business dealings or activities that conflict with the business interests of Gmach. Suppliers are expected to adhere to all laws in the country in regard to sourcing products being supplied to any Gmach company.

3.2.6  The use of consultants

Consultants, agents and other implementing partners who offer services to the Gmach group must adhere to the principle of this code of conduct in the course of their work on behalf of General Machinery Limited. Before entering into a consulting relationship, Gmach shall ensure that;

• no material conflict of interest exists
• the consultant is genuinely qualified for the proposed work
• the compensation is reasonable
• there is a written agreement outlining the work to be performed if the company's financial commitment is greater than USD 3,000= (or equivalent) or the services are material to the business of Gmach
• a Non-Disclosure Agreement (NDA) has been signed and
• the consultant commits in writing that it along with its employees and agents will also comply with the code of conduct and Non-Disclosure Agreement (NDA).

3.2.7 Media contact

News media contact, responses and public discussion of the business and the companies’ financial status or outlook of Gmach shall only be made by the Managing Director, Board through the Chairperson or its designated spokesman. Both must consult with the Gmach group Lawyer if a statement might have legal implications.

Inquiries from the press should be directed to the Managing Director or a designated company spokesperson of the Board of Directors. If reporters/journalists question an employee, he/she should immediately refer them to one of these persons. To protect Gmach as well as himself, the employee must always assume that company information is confidential unless he/she has been authorised to comment or has seen it in a written publication.

3.2.8 Corruption

Because Gmach is a Ugandan Company and carries out business in a regulated sector, all employees are required to be aware of and comply with major national laws and conventions on corruption practices, including sector-centric laws and regulations.

Corruption is the abuse of trust or of office in order to obtain personal gain and includes but not limited to, acts of; bribery, fraudulent acts/wrongful acts as stipulated in the Anti-Corruption Act, No.6 of 2009, laws of Uganda.

Corruption may involve the exchange of items of value or the provision of services or other favours in order to obtain personal benefit by virtue of the employment position. It does not only involve money but may extend to all manner of gifts intended for personal gain derived from an official favour or position.

Corruption also includes bribery in all forms - direct and indirect through third parties. Employees and business partners shall not offer nor accept an offer as a bribe, facilitation payment, kickback or other Improper payment for any reason. The direct or indirect offer, payment, solicitation or acceptance of bribes in any form is totally unacceptable and is punishable by law.

Therefore, it is the policy of the Group to prohibit corruption and fraud through the Whistle-Blowers Procedure and to promptly investigate any acts of corruption, fraud or other wrongful acts committed by its employees or any persons who directly/indirectly commit the fraudulent acts/ or other wrongful acts under the instruction/approval of the employee.

All employees and business partners of the Group are required to abide by this policy during the execution of the assignment.

3.2.9    International Laws

a) Foreign business travel

Gmach employees travelling internationally need to fully understand applicable export or travel requirements for each country before departure (e.g. Visa, immunisation requirements etc.). In case of doubt, employees are advised to contact management for further information and guidelines.

Employees have a duty to become internationally familiar with particular customs and practices of countries with whlch they conduct business. What may be acceptable in one country may not be appropriate in another country. This requirement also applies to electronics and other services that the Bank may offer in the future.

b) Visitors

Visits by a person to Gmach premises where confidential and sensitive information is held, must be monitored and controlled. Visitors should be hosted In a designated area which is adequately monitored. Gmach shall continue to use the available reasonable technology facilities to enhance the monitoring of access to confidential information and confined areas.

b) International boycotts

It may be illegal to enter into agreements with representatives of countries or to provide information that could be construed as furthering boycotts of countries or restricting international trade practices. Some governments may impose criminal or civil penalties on companies, their international subsidiaries and employees for violating boycott laws.

3.2.10 Political Activities

Political activities on all Gmach premises, on the job, are strictly prohibited. Employees who wish to engage in political aCtlYities must do so in their own time and outside the Gmach premises.  All employees' political activities must be carried out during the employees* private time and at their own expense. Management should be privy to such activities.

Gmach shall not use its funds or assets for contributions towards or support of political candidates for office. Examples of prohibited political activities include, but are not limited to:

• Use of the Gmach’s internal mail and e-mail services to advance the interest of any political party or political view.
• Conducting meetings concerning any political matter on the company
• Advertising or promoting any politica{ matter on the company
• Discussing and promoting political views and programs.
• Purchasing tickets for political fundraising events and in-kind contributions such as paying for the Gmach’s employees for work on political campaigns.
• Using any of Gmach’s assets such as vehicles, premises etc to further political

All employees and General Machinery operations situated wherever, must comply with these restrictions as they apply to the use of the Gmach’s funds or its other assets.

3.2.11 Religious Activities

Gmach respects the rights of each employee to affiliate to a religious faction, belief, practice, norm, and custom of their choice. Examples of prohibited religious activities, but not limited to: discussion, debate, or promotion of religious beliefs, practices, customs, denigration or criticism of religious beliefs, practices and customs.

3.2.12 Attire

Employees are expected to dress in proper business attire at all times while representing Gmach interests outside the office, or while meeting customers within the office. Informal dress code inside the office premises is acceptable provided that It remains within conventional business standards. The cultural context of Uganda and other countries should be taken into consideration.

1. Guidelines for men
   • Formal: Business suit, or jacket, shirt and
   • Informal: Casual pants, and conservative shirt or t No shorts, no sandals, nor buttoned down shirt, no sport attire, no excessive jewellery allowed.

1. Guidelines for women
   • Formal: Business suit, or skirt and Closed-end shoes, classic briefcase and/or handbag.
   • Informal; Casual pants/skirt/dress and top. No tank tops, spaghetti tops, beachwear, party wear, flip-flops, excessive jewellery, flamboyant nail polish, excessive make-up, extremely short skirts (skirt should be at or not of height further up the knees), or very revealing attire.
   • All staff members shall observe the appropriate dress code, which enhances the public image of General Machinery. All Staff members, including those who wear uniform, are expected to be neat, tidy, and smartly dressed at all times. Staff members wear a uniform to market and enhance the corporate image of Gmach.

3.2.13 Hygiene

Bodily odour causes discomfort and distraction to other employees, and is an impediment to teamwork. Employees are expected to be hygienically presentable. Reporting to work with proper hygiene, ensuring regular showers/baths at home, as well as oral hygiene, is very important. Staff should wear clean clothes to avoid bad odours. Poor hygiene affects teamwork and co-workers should escalate such matters to the Group Head of HR.

3.2.14 Gifts, Gratuities and other Payments

Gifts and gratuities shall not be given or received except of nominal value (not more than $1,000-. Where local custom is so strong that to refuse a gift, or to not reciprocate with a gift, would be considered an insult, or where receiving and/or giving a gift is recommended by, or is part of, the local customs, a gift can be received or given if permitted by the local law and only upon proper approval of management or Human Resources.

3.2.15 Donations and Sponsorships

Gifts and gratuities shall not be given or received except of nominal value (not more than $1,000=. Where local custom is so strong that to refuse a gift, or to not reciprocate with a gift, would be considered an Insult, or where receiving and/or giving a gift is recommended by, or is part of, the local customs, a glft can be received or given if permitted by the local law and only upon proper approval of management or Human Resources.

3.2.16 Bribes and Kickbacks prohibited

Employees are not authorised to pay or receive any bribe, kickback or other similar unlawful payments to or from any customer, public official, government or any other individual, whether foreign or domestic to secure any concession contact or other favourable treatment for Gmach or the employee.

This prohibition extends to the payment or receipt of money or anything else of substantial value when the employee has reason to believe that some part of the payment or fee will be used as a bribe, kickback or for any other illegal activity.

3.2.17 Quality of service

All services provided by the employees must be in strict compliance with the Company's approved procedures in accordance to the highest professional standards used in the industry.

Reviews of each employee's performance shall be conducted periodically and the results shall be recorded and documented as required. The Supervisors conducting such review(s) shall be personally responsible for their proper conduct and the authenticity of the data obtained.

3.2.18  Books, Records and Information Management

Gmach requires full compliance with the spirit and letter of applicable laws and regulations requiring books of account, customer records and other documentation to be accurately maintained.

Accordingly, employees are reminded of the following record-keeping requirements:

1. All books and records of accounts must be kept in reasonable detail and must accurately and fairly reflect all transactions of the
2. All transactions must be properly and promptly recorded at the point of executing the transaction.
3. No undisclosed or unrecorded transaction may be established for any
4. False or fictitious entries must never be made in any of the Company's records, systems or software or in any public record for any reason nor should permanent entries in the Company records be altered in any way.
5. A system of internal accounting controls shall be maintained which is sufficient to provide reasonable assurance that transactions:
1. Are executed in accordance with Senior Management's general or specific

1i)    Are recorded as necessary, to maintain accountability for the company assets.

All employees should be aware that penalties for violating the procedures, laws and

Regulations above could be severe for the Companies and the employees involved.

3.2.19  Time and Labour records

Time of entry and departure from the office shall be recorded for all staff using the defined clock-in system. Attendance records will be reviewed by Heads of Department in determining the salary payable for each particular period worked.

3.2.20 Expenses Records

Specific categories of Employees may incur expenses that are reimbursable by the Company.  Management expects employees to exercise good judgment and discretion regarding expenses and not to incur expenses that are unreasonable or questionable in nature. Staff members who exploit this avenue will be dealt with accordingly.

3.2.21 Retention of Records

Legal and regulatory practice requires that retention of certain records such as tax returns, Customer transactions, personnel, health and safety, environmental matters, contracts and corporate structure, shall be retained for various periods of time as stipulated in the Records Retention policy. Gmach employees must ensure compliance to these defined regulatory requirements.

Records should be disposed of in accordance with the company's record retention policy. Disposal or destruction of company records and files of this nature is not discretionary with any employee, including the originator of such records; it should be executed in accordance with the relevant policy.

Note: When litigation or an investigation or audit is pending or imminent, relevant records must be secure and not be destroyed until the matter is resolved. Destruction of records to avoid disclosure of information in a legal proceeding may constitute a criminal offence. This may also lead to disciplinary procedures, including dismissal.

Questions on record retention should be directed to the Company-appointed legal advisor or Senior Management, particularly if any litigation, investigation or administrative action involving the company or any of its officers, suppliers or customers is pending.

3.2.22 Internet, voice mail, electronic mail and computers

Use of Internet, voicemail, electronic mail and computers requires responsible judgment, supervisory discretion and compliance with applicable laws and regulations.

Users must be aware of and follow management policies for Internet, voicemail, electronic mail and computer usage.

Individuals are not guaranteed privacy while using the Company voicemail, e-mail and computers and should not expect it. To the extent that employees wish their private activities to remain private, they should avoid using the company voice mail, electronic mail, the internet and computers for such activities.

In order to avoid or reduce the risks inherent in the use of Information Technology within Gmach, the following rules are necessary:

• The information on your computer is of great importance. It is your responsibility to ensure that your data is protected by Antivirus software and backed up daily in accordance with your office’s operating procedures.

• Every message sent by a Gmach staff reflects the company's image and reputation. Therefore, messages must be appropriate and
• No Gmach Staff is allowed to share any password. Anyone caught will be subjected to a disciplinary hearing, which includes summary dismissal.
• Information received from a customer should not be released to another customer without the prior consent of the original sender. If in doubt consult your Head of Department, General Manager or the Managing Director.
• Employees are not authorized to retrieve or read any e-mail messages that are not sent to Any exception to this requirement must receive prior approval from Senior Management.
• Particular care should be taken when sending confidential or commercially sensitive information. If in doubt, please consult your Head of Department.
• Staff should bear In mind that even when a confidential message is erased, it is still possible to retrieve and read that message.
• Avoid the use of indecent, obscene, sexist, racist or any other inappropriate remarks. (e.g. cartoons).
• Do not subscribe to electronic services or other contracts on behalf of General Machinery Limited unless you have express authority to do so.
• If you receive any offensive, unpleasant, harassing or intimidating messages, inform your Head of Department or the Group Head of
• Any important or potentially contentious communication should be printed and a hard copy kept. Where important, you should obtain confirmation that the recipient has received your message.
• To prevent computer viruses from being transmitted through the system, there will be no unauthorized downloading of any software (except recommended anti-virus software).
• The Company's equipment should not be used for personal use, gain or profit, to represent you as someone else, or to post or download messages which contain political views.
• To access, download or transmit any indecent, obscene, pornographic, racist, defamatory or inappropriate materials is gross misconduct with potential criminal liabilities.
• According to applicable copyright law, persons involved in the illegal reproduction of software can be subject to civi{ damages and criminal penalties including fines and imprisonment. Gmach does not condone the illegal duplication of software. Afl Gmach employees who make, acquire, or use unauthorized copies of computer software shall be disciplined as appropriate under the circumstances. Such discipline may include disciplinary procedures being implemented as defined in the Human Resources Policy. Any doubts concerning whether any employee may copy or use a given software program should be raised with the ICT Department or Head of Department before proceeding.
• Employees who come across any misuse of software, hardware or related documentation with Gmach, shall notify their Head of Department, the General Manager or the Managing Director and the ICT Department
• Employees are discouraged from visiting social networking sites during working hours as this leads to wastage of valuable time and resources, including under
• When an employee terminates employment with Gmach, all Company property, such as keys, computer, mobile telephone and other assets/property, will immediately be returned by the employee to the Group Head of HR.
• Fair, Accurate, Timely and Understandable Disclosure

It is of paramount importance to Gmach that all disclosures in reports and documents that the companies associate with or submit to any stakeholder be made in full, accurately, and in a timely and understandable manner.

Employees must take all the necessary steps to assist the institution in these responsibilities consistent with their role.

Any attempt to enter inaccurate data or fraudulent information into the Company systems will not be tolerated and will result into disciplinary action, up to and or including termination of employment.

• Conflict of interest

Employees of Gmach have the right to engage in outside personal, financial and business transactions or other activities that do not interfere with the performance of their duties for or that could act against the interest of the Company. Activities should not involve the misuse of Company property, facilities, influence or other resources. All employees shall comply with the Gmach’s Conflict of Interest policy and shall sign a compliance undertaking annuâlly.

3.5  Dishonesty and Theft

• No employee shall knowingly:
1. Engage in fraud or embezzlement of company property,  funds, securities or

Other assets.

1. Nor damage or destroy property or material belonging to the Company, its employees, customers or other people, least they be subjected to a disciplinary
• No employees shall without proper supervision and authorization;

a)

b)

Remove/ solicit property, material or money from any Company, its employees or customers for personal gain, personal use, resale or to give to another party. Receive property, materials or money belonging to Gmach, its employees or its customers for personal gain, personal use, resale or to give to another party. Utilize Gmach’s equipment or property for non-company purposes or activities. Access, remove, publish, destroy or after private or confidential information existing in physical records or electronically stored information;

Remove, publish, destroy or alter other physical Gmach records or electronically stored information affecting Gmach, its employees or customers;

Copy, reprint, duplicate and recreate in whole or in part, computer programs or related systems developed or modified by Gmachs personnel, or acquired from outside vendors.

Acts involving  embezzlement,  theft,  improper  purchase,  pilferage,  commercial

bribery, improper disbursement or reimbursement, wrongful reporting, improper use of electronically stored information, conflict of interest or other internal fraud should be reported immediately to the Head of Internal Audit, General Manager or the Managing Director. In the event that such acts involve these proposed reporting lines, the reporting should be done to the Chairman of the Board of Directors.

3.6 Anti-trust Laws/Anti-competitive practices

Gmach will fully comply with the applicable anti-trust or competition laws in all jurisdictions in which we conduct business.

Among the types of activities which are prohibited are:

1. Conspiracies and understanding between Gmach and its competitors regarding prices, bids, customers, territories and other competitive matters. Precautions should be taken to avoid giving even the appearance of such conspiracies or understanding in industry meetings, discussions, correspondence and other communication with competitors.

b) Agreements or understandings with competitors or customers not to deal with a particular customer or supplier in an unfair manner.

1. Use of deception, intimidation, disparagement, bribery, and misappropriation of trade secrets to gain an unfair advantage.

In addition to being inconsistent with the Company standards of business practices, violation of anti-trust laws can result in lawsuits and substantial civil and criminal penalties, including imprisonment of the parties involved. Decisions and transactions that raise antitrust issues should be reviewed for compliance by the Company's legal advisor.

• Duty to Maintain Confidentiality of sensitive and proprietary information

As an employee, you may have access to both;

1. material non- public information about Gmach or about customers with whom

Gmach does business with, including suppliers, related entities and

1. other information that, while not material, may nonetheless be sensitive, confidential and/or proprietary information, which includes trade secrets, competition-sensitive data, computer programs and other technical business and financial information regarding the affairs and business of Gmach, employee records, personnel and medical records and other records, files and

This information must be used solely for legitimate Gmach business purposes and employees are prohibited from using such material, non-public information or other sensitive or confidential information for personal gain or advantage.

Material information is any information that a reasonable person would likely consider important in making a decision, such as; to buy, hold or sell shares, follow up on something personal with the party whose information has leaked etc.

While JI is not possible to list alt types of information that might be regarded as “material”, information relating to the following subjects is often regarded as material:

• Financial information, including the Company's operational and financial
• Financial projections, forecasts or budgets of the Company and its
• Mergers, tenders, offers or acquisitions of other companies or major purchases or sales or assets.
• Awards or cancellation of major
• The profit or loss of a significant customer or
• Changes in Senior
• A change in dividend policy, the declaration of a stock split or an offering of additional securities.
• Major litigation, investigation or the threat
• Write -down or restructuring changes and major transactions or negotiations with other companies, customers, regarding joint alliances or licensing
• Bank balances
• Health, Safety and Environment protection

Employees are expected to resolve safety concerns that are within their control and to escalate issues that are not within their control to Senior management for resolution before proceeding with any work in question. “Safety, health and environment” is a basic value of Gmach and must be top priority. There is no job to be done or service to be performed that is so urgent for a staff not to take the time to recognize hazards and use the proper personal protective equipment and processes

to do their work safety. All employees and consultants are expected to comply with the Gmach health and safety initiatives on-premises to maintain an awareness of worksite hazards, to maintain the worksite and the facility in a safe working condition, to understand and strictly comply with all safety rules and safe work practices and to perform each task in a safe manner.

It is the duty of Gmach to provide an accessible, safe, clean, neat, orderly and healthy workplace for employees and all must act in a manner which ensures:

• Compliance with all occupational safety and health
• Maintenance of office premises and all equipment in safe working
• Encouragement of the safety and health of our employees through the activities of

a safety program.

• That our employees, Heads of Department, Senior Management and the Board of Directors have ownership responsibility and the ability to be proactive in safety to maintain a safe and healthy workplace and to take appropriate action to prevent accidents and injuries.
If an employee has any questions about safety work practices or rules, he should consult the Team leader Health and Safety.

It is a fundamental obligation of all Gmach employees to perform their duties and responsibilities efficiently, courteously, openly, and honestly with high levels of integrity. Internal cooperation and goodwill build the foundation for both our internal and external customers.

4.0 Smoking

Smoking is strictly prohibited in all offices and common areas of Company premises.

4.1 Drug and Alcohol Policy

Gmach is committed to maintaining a drug-free workplace and a workforce that is unimpaired by drugs, including alcohol. Unlawful distribution, possession or use of a controlled substance on company premises or while conducting company business is absolutely prohibited and may lead to disciplinary action up to and including summary dismissal. The company recognises that drug or alcohol abuse or dependency can affect an employee's job performance and/or health. Employees desiring assistance with alcohol or drug addiction challenges are encouraged to contact the Head of Human Resources. Employees may be requested to submit urine and/or blood samples if any suspicions are detected.

(a)     They appear unfit for duty and Management bias a reasonable suspicion that drugs and /or alcohol are causing the condition or

(b)    Management believes that drugs and/or alcohol may have caused an accident.

Whlle an employee wlll not be required to consent to a urine and/or blood test, refusal to provide such consent does not restrict the Company from commencing disciplinary action, up to and including termination, if management has a reasonable suspicion that drugs and alcohol are causing an employee to appear unfit for duty, or may have caused an accident at work.

Therefore, any employee unlawfully possessing, distributing, selling or under the influence of drugs/ alcohol on the company property or while conducting Gmach business, will be subjected to disciplinary action, up to and including termination.

Any employee under the influence of alcohol while conducting business such that his/her ability to perform the necessary duties of the job is impaired shall be subjected to disciplinary action, up to and including termination.

Supervisors and managers are responsible for monitoring their areas of jurisdiction and taking action in any situation involving alcohol or drug possession or usage on Company premises.

Gmach recognizes the corporate responsibility to respect human rights, including labour rights, and at a minimum fully respects and complies with applicable laws and regulations. Gmach respects internationally recognized human rights as expressed in the International Bill of Human Rights.

Gmach is committed to conducting business activities based on respecting the following human and labour rights

• Equal Employment Opportunity

The fundamental basis for human resource policies of Gmach is that there shall be equal treatment and opportunity for all employees and applicants for employment within Gmach without regard to age, race, colour, religion, creed, sex, national origin, ancestry, physical or mental disability, medical condition, marital status, sexual orientation, or any other class protected by law.

Gmach has been and will continue to be committed to the policy of considering each individual on merit and potential and will not unlawfully discriminate in any employment decision. Gmach shaft ensures that both the spirit and the intent of laws prohibiting discrimination are fully implemented in alt working relationships.

5.1 Harassment

Gmach prohibits the harassment of any of its employees. Ethnic slurs, racial epithets (names), and derogatory jokes are considered harassment.

Gmach provides a workplace that is free from any form of harassment, including verbal, physical, mental and visual harassment;

Harassment also includes unwelcome requests for sexual favours or other conduct of a sexual nature.

Sexual harassment may include explicit sexual propositions, sexual insinuations, suggestive comments, sexually-oriented “jokes” or “teasing”, foul or obscene language, displays of sexually provocative items or printed material and physical conduct among others.

Violators of this guideline will be subjected to disciplinary action up to and including termination. If an employee believes that they have been the victim of sexual harassment or any other type of harassment, they should immediately report the matter to the Head of HR, the General Manager, the Managing Director and/or the Chairperson of the Board of Directors. Retaliation or reprisal towards any party involved in reporting harassment is prohibited and will result into disciplinary action up to and including termination of employment.

An investigation will be promptly undertaken for all reports of harassment. The confidentiality and privacy of all employees will be respected during the investigation. To ensure that the harassment stops, Gmach will take corrective action, up to and including termination of employment of the offender.

5.2 Workplace violence policy

It is the goal of Gmach to provide a safe and secure working environment for its employees that is free of violence or potential threats.

Workplace violence includes but 1s not limited to:

1. Physically harming or attempting to harm another or oneself, or a Gmach customer, or customer/third party property etc.
2. Threatening to harm another or oneself, or Gmach or customer/third party
3. Harassment, intimidation, coercion or stalking of
4. Shoving, pushing, grabbing and all forms of non-consensual physical
5. Bringing dangerous tools and products, firearms or weapons into the workplace (this excludes inappropriate use of issued tools, equipment and products necessary to do certain jobs).
6. Acts, gestures or threats of reprisal for another's compliance with this
7. Threats or any other statements or conduct that would cause a reasonable person to believe violence is imminent or may occur.

If an employee is confronted with workplace violence, the employee should avoid confrontation, immediately retreat to a location of safety and report the incident to the Head of Human Resources, the General Manager, or the Managing Director or a member of the Board.

Employees who are the recipients or observers of workplace violence should contact the Head of Human Resource their Head of Department. In case where immediate law enforcement assistance is needed, the employee may contact law enforcement, his/her HOD, a member of the Senior Management Team, or the Company's legal advisor.

Reports of workplace Violence will be investigated as quickly as possible. Information obtained or discovered during the investigation processes will be kept strictly confidential.

Substantial acts of workplace violence will be met with appropriate corrective action, up to and including discharge. Failure to report instances of workplace violence could subject an employee to disciplinary action. Retaliation or reprisal towards any party involved in reporting an incident is prohibited and will also result in disciplinary action up to and including termination of employment.

• Freedom of association:

Respect employees' rights to freely associate, organize and bargain collectively in accordance with applicable laws and regulations;

• No forced or child labour:

Not tolerate any form of forced or child labour;

• Fair employment practices:

Comply with applicable laws and industry norms on employees' pay, work hours and conditions. Provide fair and competitive compensation commensurate with the employees' position; •A safe and healthy workplace: Provide and maintain a safe and healthy work environment for every employee, on-site contractor and service provider;

Members of the Board, Employees, consultants and other stakeholders who violate the law, the Gmach code of conduct or Gmach policies may be subjected to disciplinary action, up to and or including termination. If necessary, employees may be suspended from their employment during an investigation into an alleged breach. Additional actions may include reassignment of work duties and limitations on future job opportunities. Violation of the law may be referred to local law enforcement authorities for possible prosecution.

Members of the Board, Employees, consultants and vendors shall endeavour to comply and to cause Gmach to comply with applicable government laws, rules, and regulations of the jurisdictions in which Gmach conducts its business. In addition, each employee shall promptly report any information concerning evidence of a material violation of other laws, rules or regulations applicable to Gmach Management or the Board of Directors.

Gmach will not intentionally retaliate in any manner against any employee who wilfully provides factual information to Gmach line managers, the General Manager and/or the Managing Director. Persons who retaliate may be subjected to a disciplinary process, civil, or criminal and administrative penalties, including termination of employment.

Employees who deliberately withhold information concerning another employee's violation of the law or Gmach policies may also be subjected to appropriate discipline. To avoid such discipline, employees may report violations of policies to a member of the Senior management or a member of the Board of Directors, anonymously if they are concerned about retaliation.

If an investigation determines that the alleged violation(s) or events of non-compliance of the code of conduct occurred, then the Company shall determine the appropriate corrective actions to deter wrongdoing and to promote accountability for adherence to this code of conduct. This may be disciplinary action up to and including termination of employment.

In the event that an employee, Board member, consultant or service provider believes that another Gmach employee, Board Member, contract worker, consultant or service provider or subcontractor is violating the law, the Gmach code of conduct or the Gmach policies or is engaged in activities on behalf of the company that may damage its reputation, he/she should bring his concerns to a member of the Senior Management team or Board Member or the Company's appointed legal advisor.

In all cases, confidentiality will be maintained to the fullest extent possible. Retaliation or reprisal toward any party involved in reporting an incident is prohibited and will also result into disciplinary action up to and including termination of employment.

Note: The employee reporting a suspected violation may, but is not required to provide their identity. If he/she chooses to do so, management will ensure that confidentiality is maintained.

It is the Company's aim to provide staff with a fulfilling role and therefore It is unusual for staff members to engage in outside employment.  If, however, one engages In outside employment before or after their regular working hours, the

The company may object in particular circumstances, such as; e.g.

• When the outside job adversely affects one's performance on the
• When the outside employment might lead to a conflict of
• When you are conducting the employment on the company

A staff member is required to inform their Line Manager or respective Head of Department of any employment he wishes to undertake outside Gmach.

In addition to complying with statutory requirements, Gmach recognizes an obligation towards employing people with disabilities. Gmach may provide, where possible, suitable opportunities for people with disabilities to join any group company and develop within the Institution.

Where job requirements allow, Gmach is committed to providing procedures designed to ensure fair consideration of disabled applicants.

Where employees become disabled after joining any of the companies, steps will be taken, where feasible, through retraining and redeployment, to enable them to remain active in employment within Gmach.

Teenagers are responsible for ensuring that this code of conduct is adhered to within their areas of jurisdiction. This policy applies equally to registered and non-registered disabled persons.