Khalifa University (鈥淜U鈥�) maintains the highest ethical standards in all of its activities and expects the same from its Partners. Acting ethically means complying with all applicable laws and regulations while conducting all activities in an ethical manner.
KU can only fulfill this commitment to integrity and compliance if our Partners share this commitment. The Khalifa University Partners Code of Conduct (鈥淐ode鈥�) sets forth minimum expectations for the Partner when performing activities for or on behalf of KU.
PURPOSE AND SCOPE
This Code aims to establish the expectations and standards of conduct for Partners in order to maintain the integrity and reputation of KU, ensure compliance with applicable laws and regulations, and promote ethical and responsible behavior in all interactions with KU. This Code serves as a framework for promoting and upholding high ethical standards, maintaining transparency, and fostering a culture of mutual respect and trust between the KU and its Partners.
This Code applies to all Partners that KU engages with. The principles set out in this Code must also apply to any contractor or subcontractor engaged or employed by a Partner to perform activities for or on behalf of KU.
OUR EXPECTATIONS
Khalifa University expects all Partners to be alert to any potential violations of law or this Code in the context of their relationship with KU. Partners are required to cooperate with the Ethics & Compliance Office of Khalifa University in the resolution of any concern, including making relevant documents, information, and employees available when requested and by maintaining the confidentiality of any such request. In particular, Partners must immediately inform the Ethics & Compliance Office if they are notified by a regulatory authority or any other external party of an audit, investigation, lawsuit, or other inquiry regarding KU, if not prohibited from doing so. KU strictly prohibits retaliation of any kind against anyone who reports a concern in good faith and requires the same of our Partners.
By engaging with Khalifa University, Partners are deemed to have read and agreed to comply with this Code. Failure to adhere to these standards may reflect negatively on the Partners鈥� relationship with KU.
For disclosure or reporting concerns purposes, Partners can:
- Use the ethics reporting form on KU Official Website;
- Reach out to the Ethics & Compliance Office at +971 2 312 5555, or ethics@ku.ac.ae; or
- Meet with a representative from the Ethics & Compliance Office.
STANDARDS OF CONDUCT
RESPECT
- Human Rights: Partners must abide by applicable national and international human rights principles.
- Employment Practices: Partners must comply with all applicable laws, rules and regulations in relation to employment practices. As a minimum, pay fair wages and observe reasonable and safe working hours and conditions.
- Fair Treatment: Partners must treat all employees and contractors fairly, with dignity, respect, and integrity. Do not discriminate, harass, intimidate, threaten, humiliate, or abuse employees.
- Child & Forced Labor: Partners must not use, employ, or seek to exploit in any way the services of child, under-aged, slave or trafficked labor. This includes any form of indentured servitude, such as use of physical punishment, confinement, and threats of violence.
- Healthy & Safe Workplaces: A healthy and safe working environment must be provided to all employees. As a minimum, this includes safe drinking water, adequate lighting, temperature, ventilation, and sanitation. All facilities and housing conditions, if provided, must be constructed and maintained in accordance with the standards set by applicable laws and regulations.
INTEGRITY
- Anti-bribery & Corruption: Khalifa University has zero tolerance for any form of bribery or corruption. Partners must comply with applicable anti-bribery and anti-corruption laws, and behave ethically in all their dealings for or on behalf of KU.
- Improper Transactions: Partners are prohibited from offering, promising, giving, requesting, or accepting improper transactions, e.g., a bribe, a 鈥渒ickback鈥�, or anything of value (including gifts, meals, entertainment, etc.) directly or through a third party in an attempt to improperly gain or retain or influence a decision. Partners should not make any form of payment to government entity employees to expedite the timing of activities that the government entity employee is required to perform (e.g., process visas, customs declarations, etc.) except if it is an official express service offered by them.
- Gifts & Entertainment: Because gifts and entertainment may be used to disguise bribery and corruption, KU requires that Partners only offer or accept gifts or entertainment that are reasonable, directly related to a proper purpose, and in accordance with local laws governing such activity. Cash or cash equivalents are not permissible. Any offer of a gift or entertainment to a KU personnel during an open bidding process in which the Partners are involved is strictly prohibited. If there is any doubt with respect to what KU personnel may or may not offer or receive with respect to gifts and entertainment, do not hesitate to reach out to the Ethics & Compliance Office directly for clarification.
- Supply Chain: Partners must carefully scrutinize, select, and monitor the third parties, contractors, agents, representatives or subcontractors they use to act for or on behalf of Khalifa University. Both Partners and KU are potentially responsible for the conduct of these third parties, contractors, agents, representatives or subcontractors when they are working for or providing services or goods to KU. Failure to fulfil this responsibility may lead to fines, loss of necessary operating authorizations, restrictions on government entity contracts, and other legal penalties.
Partners must conduct appropriate diligence and background checks on these third parties, contractors, agents, representatives or subcontractors. KU requires, as a minimum, that Partners gather, analyze, manage, and monitor information to ensure that any third parties, contractors, agents, representatives or subcontractors that Partners use have a shared commitment to abiding by applicable laws. This would include checking the legitimacy and background of third parties, contractors, agents, representatives or subcontractors before they commence a relationship with Partners and monitoring them throughout the course of that relationship. Third parties, contractors, agents, representatives or subcontractors should only be selected based on merit and competitiveness. Partners are responsible for ensuring that their own third parties, contractors, agents, representatives or subcontractors comply with this Code with respect to activities conducted for or on behalf of KU.
- Competition: Partners are expected to comply with the competition laws in the countries where they operate, sell or provide products and services. Partners must not coordinate market conduct with competitors or their own third parties, contractors, agents, representatives or subcontractors in a way that improperly restricts competition. Partners must not discuss internal or material non-public information, such as prices, discounts, pricing policy, profits, market share, production levels, customers, or sales territories with a competitor, particularly concerning activities performed for or on behalf of the KU.
TRANSPARENCY
- Conflicts of Interest: Partners must avoid any activity that creates a conflict of interest or the appearance of a conflict of interest that brings into question their relationship with KU. This includes conflicts of interest that may result from financial interests, employment, time commitments, outside directorships, stock ownership, friends/family relationships, Sponsorships or honorariums, and use of confidential information. Partners acknowledge that they will not use their position to profit personally at the expense KU.
- Books & Records: Accurate and transparent books and records should be maintained at all times and demonstrate compliance with applicable laws and regulations. Partners must be watchful for, and report, any irregular payments, suspicious transactions, or suspected money laundering.
- Audits & Assessments: Partners are expected to cooperate with internal and external investigators and auditors. Partners must notify the Ethics & Compliance Office of any ethics and compliance concerns they have with respect to any dealing they have with KU or KU personnel. In addition, KU and its external representatives have the right to inspect and audit Partner鈥檚 books, records and accounts relating to work activities done for or on behalf of KU, as well as conduct operational audits, upon the provision of reasonable notice.
SUSTAINABILITY
- Khalifa University is committed to preserving the environment, complying with all applicable environmental laws and regulations, demonstrating continual improvement in its environmental performance, and following industry practices to do so. Partners are obliged to minimize wastage of energy, water, and other resources, prevent discharge that would have an adverse impact on the environment, and recycle whenever possible.
CONFIDENTIALITY
- Confidential Information: Partners must safeguard KU confidential data and follow relevant data protection, privacy, and information security laws and regulations. In doing so, Partners agree only to acquire, or seek to acquire, confidential information or personal data through proper means. That information must be kept secure and accessible only to those with a legitimate need to access it. Partners will not discuss, disclose, transfer, release, or share any confidential information or personal data concerning KU without prior written consent from KU.
- Competitive Information: Partners will not seek to obtain or use insider, material, or confidential information that belongs to competitors or other third parties. Partners will return any materials mistakenly, or otherwise, received containing such competitive information to the Ethics & Compliance Office.
