EPROM Code of Conduct

We Stand for the Code
At EPROM, we are committed to conducting our business with honesty and integrity. We have established our company based on high ethical and legal standards, as well as respect for each other and those with whom we do business.

Chairman Statement
It is an honor to share EPROM’s success journey of unprecedented success& resilience. We are setting stone for the upcoming years, fuelled by an amazing winning team, spirit creating staff, utilizing amazing technologies, and top notch operations & maintenance techniques that unlocks access to energy for the benefit of all our success partners.
When I look back at our shared successes at EPROM, and see the amazing engagement, positive energy, and joint achievements of our staff, I reflect on the value of our team, where people join us for who we are and make us what we are.
I realize that, indeed, it is all about our people and putting our clients at the center of what we do, seeking to be the operations and maintenance partner of choice. We are striving to contribute to the development of our sector, still adding value to other energy industry segments. On the other hand, and on behalf of my colleagues in EPROM, I extend my sincere gratitude to his excellence Eng. Tarek Elmolla, Minister of Petroleum and Mineral Resources, regarding his exerted efforts supporting EPROM business sustainability plans.
EPROM devotes its commitment towards developing petroleum sector, aligned with the ministry’s strategic transformation and modernization plans, generating an added value for our country in Egypt’s 2030 vision.

  1. Introduction
    EPROM is the largest Operation and Maintenance Management Company in Egypt and in the North of Africa, ranking as the first Egyptian General Petroleum Cooperation “EGPC” owned company to professionally cover both domains of maintenance and operation for oil refineries, petrochemical plants, fertilizer factories, and gas plants as well as the management of marine terminals.
    Since EPROM is a company devoted to developing human potential, we view ourselves as partners with our employees. EPROM encourages its employees to create innovative solutions, outgrow the conventional static approaches and excel in every assignment they are responsible of.
    EPROM relies on all persons in the organization to apply good judgment and to speak up when there are questions or concerns
    It provides requirements and guidance that help not only employees, but also other parties who work on the company’s behalf including suppliers, contractors and partners who carry out their duties professionally and with the highest level of integrity, consistent with our values and Business Principles.
    Employees are the most important element in our integrated entity process to fulfill our commitment to all our contractual obligation with all our customers in the vital field that we excel, Refinery Industries and Petrochemicals as well as EPROM entirety activities that holds added value to EPROM rather than all other Companies affiliated with ministry of petroleum and mineral resources
  2. EPROM Purpose
    EPROM as a customer oriented company is set to attain a leading position as an operation and maintenance contractor, within Egypt, the Middle East and the African continent offering state of-the-art Management techniques.
    EPROM has since its foundation proven its capabilities and competencies in a highly competitive business and achieved a recognizable market share as a modern company providing integral, top notch operation & maintenance management service.
    EPROM ambition is to build a strong regional portfolio and gracefully expand in the African depth achieving the same level of customer satisfaction that we have locally attained since company foundation.
  3. EPROM Core Value
    EPROM Core Values are the foundation for creating sustainable value to the Egypt, our employees and our stakeholders underpin everything we do in EPROM. The Code of Ethics is built upon these Values.
    Safety is paramount and part of our living culture. It means that each of us should return home safely; that we provide a safe environment for everyone; and that we all understand and follow the highest standards of safety rules and procedures.
    EPROM ability to excel depends on the integrity, knowledge, imagination, skill, diversity and teamwork of our employees”.
    EPROM strives for Excellence in everything we do. It means that we are committed to creating a high-performance culture; that we operate assets in an environmentally sustainable and profitable manner; and that we promote innovative technologies.
    EPROM respects our people and care about their future. It means that we create opportunities for our collaborators to progress; that we value the diverse talents of our personnel; and that we develop responsible leaders who create a respectful environment for everyone. We Trust one another. It means that we foster a culture of trust and transparency; that we believe in honesty, loyalty and the reliability of our colleagues; and that each of us is accountable for bearing our values with the highest standards of integrity

  4. Making the Right Choices
    EPROM Company strives for excellence in all areas of endeavor, working with professionalism and due care to maintain high standards of work. The best results are achieved when we work as a team, drawing upon our diversity and when the interest of the company is considered before individual achievement.
    EPROM Company's Core Values embody the key ethical commitments required from employees. Although the Code of Ethics sets out certain indicative behaviors, it is of paramount importance that all employees understand and act in accordance with EPROM’s Core Values and the spirit of the Code of Ethics, rather than the latter. Therefore, business conduct which is contrary to our Core Values or the spirit of Code of Ethics, even if not expressly prohibited or referred to in the Code of Ethics, will be treated as seriously as any other breach and may result in the relevant employee facing disciplinary proceedings.
  5. Staff Development
    We value the unique contribution that each person brings. Employees accomplish more when people from diverse backgrounds and with different talents, skills and ideas work together in an environment that is inclusive of everyone
    • We promote the development of our employees
    • We reward and promote employees based on performance and competence
  6. Fairness
    We respect the rights and dignity of all employees and believe that everyone is entitled to fair treatment, courtesy and respect. All decisions related to hiring, promotion, and other HR policies should be based on merit.
    It is not allowed for employers to make job decisions based on race, color, national origin, religion, and sex.
    EPROM prohibits discrimination based on age, disability, and genetic information allowing individuals to achieve individual and organizational cohesion and ventilate their differences
  7. Harassment Free Work Environment
    Any form of harassment by or toward employees, contractors, suppliers, customers and communities is unacceptable EPROM will take all possible measures to prevent and address harassment in the workplace
    EPROM is committed to a diverse, inclusive and harassment-free workplace, which extends to all interactions with the EPROM community, including third-parties and entrepreneurs.
    EPROM aims to provide a healthy work environment and culture: one where everyone is respected, welcome and included and one free from discrimination, harassment, and intimidation for any reason.
    EPROM requires the highest standards from the team in their general conduct. This includes a zero-tolerance approach to discrimination and harassment, and equal treatment regardless of an individual’s characteristics including age, disability, , race, nationality, ethnic or national origin, religion or belief,
  8. Privacy of Information
    EPROM believes in protecting information, whether it belongs to EPROM or to others, providing a solid foundation to it’s’ reputation and its’ sustainability as a business.
    • EPROM respects the privacy of its’ employees and we will only take an official interest and action in what employees do outside of work if it affects EPROM reputation or legitimate business interest.
    • EPROM will only use personal information when needed to operate effectively or comply with the law
    • EPROM protects the company’s information systems, and in turn the personal information of employees and their dependents by implementing firewalls and information security systems to prevent incursion of viruses and unauthorized access
  9. Political Rights
    Employees can do what they want on their own time regarding political activities, but your workplace policy should limit certain behaviors while on duty. A clear and fairly applied policy can help avoid not only the loss of productivity, but discrimination and harassment claims as well.
    Handling political activity can be especially tricky because, while you can restrict employees' behavior during work time, some employees' off-duty conduct may reflect negatively on your business.
    Your ability to control those activities is limited, and in fact many conversations are protected by the First Amendment. While you can't prevent an employee from expressing his or her beliefs, you can focus on the fact that your workplace may not be the appropriate forum for such conversations.

    EPROM does not prohibit free speech and political activities. Employees are freely allowed to participate in the political events either by voting or volunteering for campaigns.
    EPROM does not permit the company name to be used in any political activity without your approval.
    Require employees to ensure that their participation in political activities does not reflect unfavorably on the company.
  10. Human Rights
    • EPROM complies with and respects international standards on human rights, and does not engage in any conduct that hinders or infringes human rights.
    • EPROM will not engage in and will not tolerate or work with parties that:
      • Engage in employment of children and minors, forced, bonded or compulsory labor
      • Whose employees are not free to leave their employment after reasonable notice or are required to lodge deposits of money or identity papers with their employer
  11. EPROM is Committed to Health, Safety and Environment
    Sustainability is a topic that continues to gain the attention of health, safety, and environmental (HSE) professionals. Typically a board-level issue, sustainable growth strives to balance social, economic, and ecological issues.
    EPROM, through active participation of all employees and subcontractors, is committed to managing HSE risks; protect health and safety of employees, subcontractors, customers, the environment, and the community at large with the goal of preventing accidents, injuries, and occupational illnesses, progressively minimizing environmental impact by reducing discharges and using energy efficiently and producing safe, quality products.
  12. EPROM is Committed to Doing Business Ethically
    EPROM does not obtain a business advantage through bribery, corruption, undue influence, improper payments, preferential treatment or any other illegal means. EPROM has zero tolerance to any form of corruption, fraud or trading in influence. Employees must not obtain any improper personal advantage through their position
  13. General Prohibition on Corruption
    ”We may not do indirectly what we cannot do directly” Therefore, we will never use any third party as an intermediary to commit a bribery or illegal payment or contribution. Ignorance is not an excuse for violating anti-bribery laws; before dealing with any third-party representative or intermediary, we must ensure that it is reputable and agrees to comply with the provisions of this Code and the Anti-Bribery Policy and relevant Anti-Bribery Procedures. Due diligence must be conducted and document the relationship with any prospective third-party representative or intermediary.
  14. Improper Payments
    It is forbidden to make, offer or receive any payment or other form of inducement, which may be construed as an attempt to secure business advantage for EPROM or influence someone´s judgment about EPROM
    Never offer or agree to facilitation payments to “Government Officials” to secure or speed up routine activities, such as issuing permits, visas or releasing goods held in customs, among others activities.
  15. Conflict of Interest
    EPROM understands conflict of interest may arise in the ordinary course of business. Therefore, we must disclose any relationship, activity or position, which could lead to a conflict of interest.
    We are each expected to devote our talent and efforts to EPORM, and to act with loyalty to EPROM, meaning we are not allowed to:
    • Perform or enter into any trade or business in direct or indirect competition with EPROM
    • Use our employment or position in EPROM to derive improper personal benefits, including benefits to third parties
    • Derive revenues or benefits from suppliers, competitors or business partners
  16. ✓ Reporting Conflicts of Interest
    Situations involving conflicts of interest are not always obvious or easy to resolve. Therefore, all is expected to report actual or potential conflicts of interest to your immediate superior, senior management or Ethics Line. If you are unclear whether an activity poses a conflict of interest, talk to your immediate superior, human resources, or legal counsel.

    ✓ What We Expect From Our Employees
    • Preserve EPROM assets, equipment, tools, books, files and other property by making business decisions that maximize their use in the pursuit of EPROM business objectives.
    • Protect EPROM assets and property against unnecessary wear, loss, damage and/or abuse.
  17. Regard for EPROM Integrity and Reputation
    • The Company is committed to making the work environment safe, secure and healthy for its Employees and others. The Company expects each Employee to promote a positive working environment for all. Each Employee should immediately report any unsafe or hazardous conditions or materials, injuries, and accidents connected with the Company’s business and any activity that compromises Company security to the Employee’s supervisor
    • Employees should treat their colleagues, the Company’s shareholders, customers, suppliers, competitors, the governments and the communities in which they operate fairly and respectfully, lawfully and ethically, with honesty and integrity, in a manner consistent with long-term relationships. The Company prohibits abusive or harassing conduct by Employees toward others
    • Members should not engage in disruptive actions; verbally or in writing, that display misconduct; dishonesty against the organization, its leadership, or the way it operates, actions that defame the organization.
  18. Responsibility to the Profession
    • Members shall abide by the instructions, Constitution and Bylaws of Egyptian petroleum association, Egypt, and shall show respect in interactions with the organization.
    • Members shall treat each other with respect when dealing with matters that could affect their professional reputations.
    • Members will abide by EPROM policies which may restrict, or forbid commercial transactions, at certain times or at certain events.
    • Members shall follow standard procedures for the enforcement of this Code as approved by EPROM Board of directors.
  19. Racial Discrimination and Vulnerable Groups
    At EPROM, we are committed to a diverse, inclusive and harassment-free workplace, which extends to all interactions with the EPROM community, including third-parties and entrepreneurs. We aim to provide a healthy work environment and culture: one where everyone is respected, welcome and included, and one free from discrimination, harassment, and intimidation for any reason.
    EPROM requires the highest standards from the team in their general conduct. This includes a zero-tolerance approach to discrimination and harassment, and equal treatment regardless of an individual’s characteristics including age, disability, , race, nationality, ethnic or national origin, religion or belief,
    To create and maintain this culture of respect, this document lays out our expectations and outlines a process for anyone to raise concerns about behavior
  20. Electronic Use and Access
    Telecommunications facilities of the Company such as telephone, cellular phones, intranet, Internet and email are Company property. Use of these facilities imposes certain responsibilities and obligations on all Employees. Usage must be ethical and honest with a view to preservation of and due respect for the Company’s intellectual property, security systems, personal privacy, and freedom of others from intimidation, harassment, or unwanted annoyance
  21. Actions to be Adopted by EPROM:
    The below establishes the procedure and mechanism for EPROM to deal with any violations to the above Ethical Standards, and the rules and regulations that govern the Organization.

    • Should it come to the attention of the EPROM CEO that a Member breached The Code in any manner whatsoever; then the CEO shall report the incident to the Board of directors directly.
    • The Board of directors shall convey the complaint to the Ethics Committee.
    • The Ethics Committee shall receive, initiate, and investigate offensive complaints of contrary to The Code; and recommend to the Board of directors disciplinary actions to be adopted.
    • Disciplinary actions may include, but not limited to, issuing warning, terminating membership, banning from attending certain meetings, etc. The Committee could also be delegated to resolve cases by agreement where appropriate.
  22. Constitution of the Ethics Committee
    • The Board-related Ethics Committee is a standalone Committee, appointed by the Board of directors from time-to-time, and consists of five Members: the Vice President, Membership; the Vice President, Legal Affair; and three EPROM Members.
    • Ethics Committee Members that could have an interest, or relationship to the particular issue that forms the grounds for the disciplinary action being discussed, need step down for this one time, and shall be replaced by another member, if needed
  23. Maintain Accurate Books and Records
    Employees shall maintain accurate accounts and records (“Company’s Business Records”) of all business related dealings, conducted or made for and on behalf of EPROM.
    Company’s Business Records shall accurately reflect EPROM business transactions and the disposition of its assets.
    Employees shall not make any false or misleading entries in the accounts or records of the corporation. Company’s Business Records include, but are not limited to:
    Contracts; purchase orders; receipts; records of all communications with bidders, contractors, and vendors; Minutes of meetings; Records of discussions with bidders, contractors, vendors; Internal committee meeting minutes; presentations; business related documents; and email with or without attachments.
  24. EPROM Complies with All Applicable Laws and Regulations
    EPROM operates in compliance with all applicable laws and regulations relating to our business activities wherever we do business. Where the Code of Ethics contains higher standards than those required under the local laws, rules, customs or norms, the higher standards of the Code of Ethics will apply.
    Employees shall maintain the dignity of their jobs in accordance with the general customs and act with respect inside and outside the workplace.
  25. Competition
    EPROM is committed to the principles of free and fair competition in compliance with applicable competition laws; including but not limited to:
    • Price fixing – agreements or discussions between competitors which relate to cost or pricing information, including sharing of pricing information or fixing the selling price to a customer or the buying price to be paid to suppliers
    • Allocating customers, suppliers or territories agreements between competitors to divide or allocate customers, suppliers or territories among themselves.
    • Any unconscionable or misleading conduct with the intention of gaining an unfair business advantage.
  26. Society and Communities
    We seek to make a positive social impact in every area where we work. We respect the rights and acknowledge the aspirations and concerns of the communities in which we work.
    EPROM operations can affect the social and economic environment of the communities where we operate.
    We engage with local communities, government, business partners and other stakeholders to understand the issues and concerns of the communities in which we work and we seek to make a positive contribution.
    EPROMS’ Corporate Social Responsibility (CSR) Policy is reviewed annually and sets out our commitments and expectations in relation to human rights and local communities.
  27. EPROM is Committed to the Social Responsibility 7 Key Principles
    • Accountability.
    • Transparency.
    • Ethical behavior.
    • Respect for stakeholder interests.
    • Respect for the rule of law.
    • Respect for international norms of behavior.
    • Respect for human rights.