A.G. Vision Construction Nigeria Limited (“A.G. Vision”) has established this Anti-Human Trafficking Policy to ensure that human trafficking or forced labor is not taking place within our business.
Human trafficking means the recruitment, harboring, transportation, provision or obtaining of a person for labor or services, using force, fraud, coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery and sex trafficking. Forced Labor means knowingly providing or obtaining the labor or services of a person by the threats of serious harm to, or physical restraint against, that person or another person; by means of any scheme, plan, or pattern intended to cause the person to believe that, if the person did not perform such labor or services, that person or another person would suffer serious harm or physical restraint; or by means of the abuse or threatened abuse of law or the legal process.
We are committed to always acting ethically, with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of human trafficking.
This Policy is applicable to all directors, employees, and subcontractors of A.G. Vision.
The prevention, detection and reporting of human trafficking in any part of the Company’s business is the responsibility of all employees and those under the Company’s control. Everyone is required to avoid any activity that might lead to a breach of this policy.
If you believe or suspect a breach of, or conflict with, this policy has occurred or may occur, you must notify your manager or the Legal & Compliance Officer or Senior Management or report it through the Company’s helpline. You are required to raise concerns about any issue or suspicion of human trafficking in any part of the Company’s business as soon as possible. If you are unsure whether a particular act, the treatment of workers or their working conditions within any of the Company’s business constitutes any of the various forms of human trafficking and forced labor, please raise it with your manager or the Legal and Compliance Officer.
A.G. Vision aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if their concerns turn out to be misplaced. The company is committed to ensuring no one suffers any detrimental treatment or victimization as a result of reporting in good faith a suspicion that human trafficking or forced labor is, or may be, taking place in any part of its business.
Any employee who breaches this policy will face disciplinary action, up to and including termination of employment.
A.G. Vision Construction and its affiliates has come a long way in our quest to be a leading provider of top-notch civil construction and engineering services, dredging, storage, haulage, and general contracting to our clients everywhere. The hard work, devotion, and commitment that our staff shares every day with our clients, our sub-contractors, our vendors, our trading partners are the foundation of the company. Yet, from time to time, people can be confronted with tough choices, tight deadlines, conflicting objectives, and just plain difficult decisions; that is how the real world is.
This Integrity Compliance Program is intended to capture in writing our core values, including our commitment to fair and ethical business practices, so that this document can serve as an important resource to us when questions arise. While no document can anticipate every eventuality or circumstance, the guidance and ethical principles set forth in this Program can and should inform us in our work.
In addition, this Program provides us a common framework for raising questions and opening conversation with each other about these important topics. I hope that this will be a document around which thoughtful conversations can be framed.
As you review this document, I invite you to reflect on issues you might have been confronted with in the past, and how we can embrace this Program to help us continually improve in all we do.
Elie Abou Ghazale
A.G. Vision Construction Nig. Ltd.
This Program of Business Conduct and Ethics (“The Program”) describes the commitment by A.G. Vision Construction to a set of aims, values, and policies setting out how A.G. Vision Construction and staff will act and conduct their business. Some of these principles cover A.G. Vision Construction’s commitment to laws and regulations; some cover A.G. Vision Construction’s commitment to its employees; some cover A.G. Vision Construction’s commitment to working relationships with clients and vendors; and some relate to A.G. Vision Construction’s strong commitment to ethical business practices.
In each case through this Program, A.G. Vision Construction is communicating its formal commitment to these standards. At times, like any other organization, we might fall short, but A.G. Vision Construction further commits to be transparent about its errors, learn from its mistakes, and to strive to continually improve and grow.
A.G. Vision Construction considers this to be a “living” document, and it will be regularly reviewed and updated to ensure that it properly reflects our approach to doing business, changes in the law or regulations, or to address specific issues that may impact our Program and how we conduct business.
The Program should be used in conjunction with A.G. Vision Construction’s other policies and procedures. It is a collection of high-level principles, policies and priorities that form a set of overarching standards for A.G. Vision Construction.
It is vital to A.G. Vision Construction’s success that everyone who works at the company conduct business and behave in accordance with the Program. In addition to the policies and standards in the Program, it also presents our ethical foundation on which all A.G. Vision Construction’s business behavior is based. Employees should regularly refer to the Program to refresh their understanding.
The reputation of any business centers on many things: the popularity of its services, its image, its policies and practices, integrity, and the quality of services it provides. Yet people often form an opinion of a company based on an experience with a single staff member.
Each person who works with the company is a representative to our customers, potential customers, vendors, suppliers and the public generally. Likewise, many people will get their first and most lasting impression of A.G. Vision Construction through you. Behaving ethically, courtesy, helpfully, being knowledgeable and being good at what you do influence the public’s attitude toward you and A.G. Vision Construction.
A.G. Vision Construction is deeply committed to providing exceptional services and craftmanship to our clients and maintaining a healthy and mutually beneficial relationship with our employees, sub-contractors, business partners and vendors. A.G Vision Construction is fully committed to the concept of Corporate Social Responsibility in the management and execution of projects; adherence to international best practices in safety and environmental standards, universal work ethic standards, and involvement in our host communities.
A.G. Vision Construction provides a safe and reliable work environment for our personnel across all levels of the organization; helping them excel at delivering excellent work while demonstrating high quality workmanship on the job. We strive to uphold ethical business practices in our interactions with clients, suppliers, contractors, subcontractors, and all professional associates.
AG Vision Construction aims to provide the highest quality of civil construction and engineering services, dredging, storage, haulage, and general contracting.
A.G. Vision Construction’s Legal & Compliance Officer (“LCO”) is responsible for developing and implementing, training and communication programs to familiarize A.G. Vision Construction’s personnel with their requirements under the Program. The LCO is also responsible for investigating ethical issues or violations that are brought to the attention of A.G. Vision Construction. The LCO is available to consult with all A.G. Vision Construction’s employees to discuss any ethical issues or concerns and to help you understand this Program. A.G. Vision Construction’s Senior Management is responsible for approving any corrective action plans or any modification to this Integrity Compliance Program after due consultation with the LCO.
One of the most important responsibilities each of us has as an A.G. Vision Construction employee is the obligation to raise a concern about a possible violation of our policies, a contract, or the law. Sometimes it may seem difficult to raise such a concern. Some of us may feel it is a breach of personal ethical standards or of our loyalty to a coworker to do so. If you experience such doubts, it is important to remember the serious harm that not raising a concern can cause, including:
These are reasons why A.G. Vision Construction requires that we not sit silently when we have reasons to believe that an action or decision may be improper. The point of raising a concern about such actions or decisions is not to get a friend in trouble, but to protect a colleague and our company from potential harm.
It is A.G. Vision Construction’s policy to strictly comply with all applicable government laws, regulations, contract terms and conditions, and related policies governing ethics and business operations. One way that we can ensure compliance with these authorities is to review and investigate possible improper conduct. The act of investigating does not mean improper activity has occurred but indicates that the company takes compliance seriously and will ensure that all employees act ethically and lawfully. As a company, A.G. Vision Construction relies on managers, employees, and others to raise concerns within our organization so we can evaluate the conduct in question, and where appropriate we can initiate and adopt corrective actions.
Corrective Actions could include enhanced training, adopting or changing company policies and procedures, possible employee discipline, termination of party contracts or restitution or refunds of contract overpayments. In some cases, we may be required to report the conduct to our government customer or other authorities. Therefore, it is the duty of every A.G. Vision Construction staff member to:
The contact details of the LCO, the Executive Director, and Human Resources are provided below. In addition, A.G. Vision Construction has established an anonymous reporting Helpline. Details on how to access the Helpline are also provided below.
No employee who, in good faith, brings forward an allegation of a violation of the Program will suffer retaliation or an adverse employment action because of his report. Any employee, including a manager or supervisor, who is found to have retaliated against an employee who makes a good faith report will be subject to disciplinary action, up to and including termination of employment.
If you are involved in negotiating or executing government or public international institution prime contracts or subcontracts, you must ensure that all statements, communications, and representations to the customer representatives are accurate and truthful. The government and public international institutions have special rules on accounting for costs, proposal and bidding procedures, pricing, and time charging, and these rules must be followed. All information regarding specifications, quality control, and testing for government and public international institutions projects must also be reported accurately. The rules may apply whether A.G. Vision Construction is performing as a prime contractor or as a subcontractor.
This Program applies to working with any client and their representatives, including working with any government or quasi-government agency. Working with them, we must always be aware that government representatives are public officer, subject to specific regulations governing their positions. There can never be any inappropriate behavior involving any public agent.
We take very seriously any effort to bribe or influence public officers or employees of Public International institutions.
Regardless of whether or not it would be considered a bribe, the giving or transfer of any item of value (gifts and presents) to public officials or authorities/public international institution employees is generally prohibited at A.G. Vision Construction. Any exception to this policy requires the prior written approval of the LCO and the Managing Director or Executive Director as the case may be. A written copy of any approval of such exception shall be maintained in the files of the LCO. Our specific policies governing Gifts, Hospitality and Entertainment is described below.
As a company, A.G. Vision Construction competes on the basis of the quality and value of our services. We must not encourage current or future clients to favor us over other vendors by improper or illicit means. To that end, there are restrictions that are applicable when dealing with public contracts and government/international agencies. Laws, regulations, and policies limit, and in some cases prohibit the giving of gifts to government employees and officers and employees of public international institutions.
What constitutes a “gift” is broadly defined as any item or service of value. The following are included as examples of what might constitute a gift:
Similarly, the definition of a government employee or public officer is also viewed in very broad terms and can include the following:
The definition of public international institution employees includes the following:
Also, government or public international institution employees who can influence a purchase-making decision are in particularly sensitive positions and there are often specific restrictions by government or public international institutions on what government or public international institution employees can or cannot receive from vendors such as A.G. Vision Construction. A.G. Vision Construction employees must be aware of and honor such restrictions.
Importantly, you should never give a gift as an inducement or reward for a government/public international institution purchase or other official action. See the Section on Anti- Corruption below. Even if the gift is otherwise permitted, it is never permissible to give a payment or gift that is intended to induce or reward a government/public international institution purchase or other official action.
As a result, in every such situation where a gift or payment for entertainment involving a government official or public international institution employee may take place, it is important to
always consider the importance of ethical conduct to avoid even the appearance of any impropriety, including avoiding any reputational damage to A.G. Vision Construction and its clients. Also, be aware that even if a gift is permissible, it may be necessary for the government or public international institution employee to publicly disclose the gift and its donor.
The consequences of a failure to abide by applicable gift laws can be severe, both for A.G. Vision Construction and for the public officer or public international institution employee. To avoid and prevent any negative consequences to the government/public international institution employee— and to A.G. Vision Construction and its reputation— all A.G. Vision Construction staff and any sub-contractor working on A.G. Vision Construction’s behalf must comply with the rules described above.
A.G. Vision Construction employees may exchange gifts, meals, entertainment, and other business courtesies with non-government/non-public international institution employees if they are reasonable, infrequent, modest in amount and are provided as a token of esteem, courtesy or in return for hospitality.
Non-government employees may be subject to monetary limitations (e.g., gifts not to exceed N20,000.00) on the value of such business courtesies that may be given or received. A.G. Vision Construction employees must never offer or accept such courtesies under circumstances where they could affect or appear to affect decision making. A.G. Vision Construction employees must present or receive any gifts openly with complete transparency.
In all cases where gifts or entertainment are permissible and made, for any gifts or entertainment that you provide to current or potential clients, all A.G. Vision Construction’s employees must:
You should immediately report to the LCO any gift you have been offered or received if you question whether that gift might be a violation of our policy. If you have any questions about gifts and entertainment, you should seek assistance from your manager or the LCO.
You are expected to follow both the letter and the spirit of this policy. Any action taken to circumvent or violate this policy may result in disciplinary action up to and including termination of employment. Additionally, A.G. Vision Construction will not provide reimbursement for expenditures that are contrary to this policy.
A.G. Vision Construction has a no tolerance policy meaning that we will not tolerate any inappropriate or illegal behavior.
Some of A.G. Vision Construction’s work sometimes involves the use of vendors and subcontractors to perform work on our clients’ behalf, and A.G. Vision Construction works with
different types of contractors, vendors, and suppliers. A.G. Vision Construction commits to performing and documenting the requisite background checks and reviews of third parties before
entering any business relationship, and to continue to monitor their eligibility status throughout their time working with A.G. Vision Construction.
Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest (or even the appearance of a conflict of interest).
An actual or potential conflict of interest occurs when an employee can influence a decision that may result in a personal gain for the employee or for a relative as a result of business dealings. For the purposes of the Program, a relative is any person who is related by blood or marriage or whose relationship with the employee is similar to that of persons who are related by blood or marriage.
If employees or their relatives have any business interest or employment relationships with any of A.G. Vision Construction’s vendors or sub-contractors, or an employee has any influence on A.G. Vision Construction transactions involving purchases, contracts, or leases with which they also have a financial relationship, it is imperative that they disclose to the LCO as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.
All employees have an obligation to promptly disclose any actual or potential conflict of interest to the LCO in all situations.
Employees choosing to work outside A.G. Vision Construction may do so if it does not create a conflict of interest or interfere with their work schedule or performance at A.G. Vision Construction. Outside employment that affects an employee’s attendance, work performance, productivity, or conduct, either directly or indirectly, or that creates a conflict of interest of any kind, is not allowed. Please note that schedules will not be adjusted, and special considerations will not be made for employees who have outside employment.
Unless authorized, outside employment that is restricted includes:
Construction’s premises, using A.G. Vision Construction’s property or at any time while performing services on A.G. Vision Construction’s behalf.
Employees must report in writing any outside work, jobs (part-time or full-time), consulting, etc. to the LCO.
A.G. Vision Construction permits the employment of qualified relatives of employees if such employment does not, in the opinion of A.G. Vision Construction, create actual or perceived conflicts of interest. For purposes of this policy a “relative” is a spouse, common law spouse, child, parent, sibling, grandparent, grandchild, aunt, uncle, first cousin or corresponding in-law or “step” relation. The following guidelines may be followed by A.G. Vision Construction; however, A.G. Vision Construction reserves the right to modify these guidelines depending on particular circumstances and its business needs:
Special restrictions apply to recruiting current or former government personnel and retaining them as employees or consultants. Before you enter such discussions with any individual employed by the government as either an employee or a consultant, obtain the approval of Human Resources. Please refer to A.G. Vision’s Policy on Hiring and Work Assignment for all Former and Current Government Employees for more details.
Nigerian laws prohibit the offering, soliciting, or accepting of any Gratification or kickbacks, as well as including any amount of a Gratification in a contract with Nigeria. A Gratification is defined as any money, donation, gift, loan, fee, reward, valuable security, property or interest in property, any office, dignity, employment, contract of empowerment or services, any payment, release, discharge or liquidation of any loan, obligation or liability, any discount, commission, rebate, bonus, deduction or percentage, thing of value or compensation of any kind which is provided for the purpose of influencing a public officer in the performance of his/her duties.
The “Corrupt Practices and Other Related Offences Act of 2000” also requires each Person to promptly report a violation of the Gratification laws to the nearest officer or the office of the Independent Corrupt Practices Commission or a Police Officer if gratification has been solicited or obtained in violation of the Act. “Person” is defined to include a natural or juristic person or anybody of persons corporate or incorporate.
Public international institutions have similar policies against gratification and kickbacks.
A.G. Vision Construction prohibits employees from engaging in any conduct with Business Partners that may be deemed to be any form of a Gratification or kickback.
Paying, soliciting, or receiving any bribe, rebate or kickback directly or indirectly is unlawful and prohibited. Any employee found to have paid, asked for or received a bribe, rebate or
kickback will be subject to dismissal.
We do not offer or accept bribes or other improper payments of any kind, whether in dealings with government officials or individuals in the private sector. We comply with all anti-corruption laws and policies that may apply to our operations.
Any and all corrupt, fraudulent, collusive, coercive, and obstructive practices are prohibited at A.G. Vision Construction. This includes, but is not limited to:
Everyone at A.G. Vision Construction is responsible for reading, understanding, and following these policies. Paying a bribe at times may seem like an easier way to get things done. In some jurisdictions, bribery may be commonplace, but at A.G. Vision Construction, we do not condone that behavior and we will not change our ethical practices even if we are told “that’s how business is done here”; these are never excuses for paying a bribe or engaging in other forms of corruption. At A.G. Vision Construction, we do not pay bribes, even if it means we may lose money or delay a project. No A.G. Vision Construction employee will suffer adverse consequences for refusing to pay a bribe. We must immediately inform the LCO if anyone demands a bribe from us.
Facilitation or “grease” payments are generally small payments or gifts made to a government officer to facilitate or speed up approval of some type of business transaction or activity. Such payments are strictly prohibited at A.G. Vision Construction except in cases of threatening situations where payment is made to protect against loss of life, limb, or liberty. In all situations, you must immediately notify the LCO if A.G. Vision Construction is solicitated to pay a facilitation payment or facilitation payment is made under threatening situations. The LCO will maintain records of all cases where facilitation payment is solicitated or where payment is made under threatening situations.
Charitable or political contributions may implicate fraud and abuse laws. If any client or prospective client requires that the A.G. Vision Construction make a charitable or political contribution as a condition for obtaining or maintaining the business of that client, the request for the contribution must be denied. An employee of A.G. Vision Construction may not make a charitable or political contribution from his or her personal funds, which has been requested by a potential or existing client as a condition of obtaining or maintaining the client’s business.
There are situations where a request by a client to make a charitable contribution would be appropriate. Any such charitable contribution must be made with A.G. Vision Construction funds and must be approved in advance by the Managing Director or Executive Director as the case may be, the Chief Financial Officer and the LCO. Prior to approval, the LCO must conduct due diligence on all recipients of charitable contributions and maintain records of the due diligence procedure adopted and all approvals granted pursuant to this policy and disclose such donations to the public or respective agencies of interest.
An employee may participate in client-sponsored charitable event if the employee has received advance approval from the Managing Director or Executive Director as the case may be, the Chief Financial Officer and the LCO.
Political contribution of any kind to any local, state, or federal political candidate, legislator, political party, government official or government employee is prohibited. No political contribution may be made by A.G. Vision Construction or any employee in response to a request by an existing or a potential client as a condition of obtaining or maintaining the client’s business.
A.G. Vision Construction may make a charitable contribution under the following conditions:
All A.G. Vision Construction expenses, including expenditures for gifts, travel, entertainment, and hospitality must be accurately documented in A.G. Vision Construction’s books and records. The following rules must be strictly applied:
At A.G. Vision Construction, we pursue our work with intensity, but fairly. We follow all applicable antitrust and competition laws. These laws are designed to protect consumers and competitors against unfair practices and to promote and preserve competition. We grow responsibly and by providing exceptional services and programs – not through prohibited or anticompetitive practices.
Our activities are governed by the following guidelines:
Be accurate and truthful in all dealings with customers and be careful to represent the quality, features, and availability of A.G. Vision Construction programs and services accurately.
To assist in providing a safe and healthful work environment for employees and visitors, we have established a workplace safety program. This program is a top priority for A.G. Vision Construction. Management has the responsibility for implementing, administering, monitoring, and evaluating the safety program.
We provide information to employees about workplace safety and health issues through regular internal communication channels such as supervisor-employee meetings, bulletin board postings, memos, or other written communications.
Employees and supervisors receive periodic workplace safety training. The training covers potential safety and health hazards and safe work practices and procedures to eliminate or minimize hazards.
To be compliant, every A.G. Vision Construction employee must:
Employees who violate safety standards, who cause hazardous or dangerous situations, fail to report or where appropriate, remedy such situations, may be subject to disciplinary action up to and including termination of employment.
A.G. Vision Construction is committed to providing a work environment that is free of discrimination. It is the policy of A.G. Vision Construction that all applicants and employees are entitled to equal employment opportunity regardless of race, color, religion or creed, gender (includes pregnancy, childbirth or related medical conditions), national origin, age, disability, or other protected characteristics as required by Nigerian law.
A.G. Vision Construction maintains a policy of objective and rigorous employment selection process, paying attention exclusively to the academic, personal, and professional accomplishment and the needs of A.G. Vision Construction, and we base promotions on the merit, capacity, and performance of the persons.
A.G. Vision Construction does not discriminate in employment decisions, including, but not limited to hiring, training, orientation, placement, employee development, promotion, transfer, compensation, benefits, educational assistance, leave of absence, layoff and recall, social and recreational programs, employee facilities, termination and retirement. A.G. Vision Construction is an equal opportunity employer.
Any communication from an applicant, employee, government agency, or attorney concerning any equal employment opportunity matter should be referred to Human Resources.
A.G. Vision Construction is committed to providing a work environment that is free of discrimination and unlawful harassment. Actions, words, jokes, or comments based on an individual’s gender, race, religion, national origin, disability, or other protected characteristic will not be tolerated. Likewise, workplace bullying or disrespectful behavior between employees will not be tolerated.
This policy applies to all work-related settings and activities, whether inside or outside the workplace, and includes business trips and business-related social events. It covers harassment or discrimination by employees as well as by other individuals who have a relationship with A.G. Vision Construction where A.G. Vision Construction can exercise some control over the individual’s conduct in places and activities that relate to A.G. Vision Construction’s work (e.g., directors, officers, sub-contractors, vendors, etc.). A.G. Vision Construction’s property (e.g., telephones, copy machines, facsimile machines, the Internet, computers, and other electronic resources) may not be used to engage in conduct which violates this policy. As such, A.G. Vision Construction has a right to search and review any A.G. Vision Construction property at any time for unlawful information or materials.
While this policy sets forth our goals of promoting a workplace that is free from unlawful discrimination or harassment, the policy is not designed or intended to limit our authority to discipline or take remedial action for workplace conduct which we deem unacceptable, regardless of whether the unacceptable conduct satisfies the definition of unlawful discrimination or harassment.
It is A.G. Vision Construction’s policy to investigate all harassment or discrimination complaints thoroughly and promptly. To the fullest extent practicable, A.G. Vision Construction will maintain the confidentiality of those involved. If an investigation confirms that discrimination or harassment has occurred or that this policy was otherwise violated, A.G. Vision Construction will take corrective action. Corrective action may include discipline up to and including immediate termination of employment of the offender. A.G. Vision Construction forbids retaliation against anyone who has reported harassment or discrimination or who has cooperated in the investigation of harassment or discrimination complaints.
Employees may also report any harassment charges via the A.G. Vision Construction Help Line or Human Resources.
Our employees, clients, sub-contractors, and vendors entrust A.G. Vision Construction with important information relating to their activities. The nature of this relationship requires maintenance of confidentiality. In safeguarding the information received, A.G. Vision Construction earns the respect and further trust of our clients. The protection of this confidential business information and trade secrets includes, but is not limited to, the following examples:
No one is permitted to remove or make copies of any of A.G. Vision Construction’s records, reports, or documents without prior written management approval or as appropriate as part of their formal job description.
Employees should not respond to any unauthorized requests for information or surveys without prior approval from Human Resources or LCO.
Because of its seriousness, disclosure of confidential information could lead to termination of employment and where the information divulged results in loss of revenue, business relationship or any incidental detriment to the Company, A.G. Vision Construction may seek legal redress and utilize all available legal option in seeking damages against the employee concerned.
Employees of A.G. Vision Construction have access to a variety of forms of electronic media and services, including computers, networks, electronic mail, telephones, fax machines, printers, and the Internet (including instant messaging technologies). These services are made available to employees to help them perform their jobs as efficiently and effectively as possible. However, all employees should remember that electronic media and services provided by A.G. Vision Construction are the property of A.G. Vision Construction, and their purpose is to facilitate and support the business.
No right of privacy exists for any employee of A.G. Vision Construction with respect to information placed on A.G. Vision Construction’s electronic media systems by the employee. All electronic media systems, including, but not limited to, desktop PCs, laptop PCs, networks, electronic mail, telephone/fax records, printed documents, Internet activity (including instant messaging technologies) and electronic storage stored in A.G. Vision Construction’s offices or remote services are subject to review by A.G. Vision Construction. A.G. Vision Construction has the right to review, audit, interrupt, access or disclose any message created, received, or sent over the electronic media systems of A.G. Vision Construction or its business tools. A.G. Vision Construction, or its authorized designee, reserves the right to review, at any time, all information contained in these systems (even if previously deleted or archived).
Telephones are an integral part of communications within A.G. Vision Construction and with our clients. Personal calls are permitted to a reasonable extent; however, they must be limited, and this privilege not abused.
To ensure effective telephone communications, employees should always speak in a courteous and professional manner.
E-mail is an essential tool for corporate communications, organization, and documentation. All employees are required to use corporate e-mail for official communications. Many important messages and files are sent via e-mail each day. A.G. Vision Construction employees are expected to check e-mail for new messages at least daily and at least weekly on vacation or holiday breaks. Employees in management or leadership positions will be required to check their e-mail more often and as required by business needs. The e-mail system is reserved for business purposes only. Employees should refrain from sending or receiving personal e-mail at the workplace.
Internet usage should be limited to work related purposes only. A.G. Vision Construction may monitor all servers and all computers for misuse of internet or pirated software, unlicensed software, or inappropriate images. Responsible parties will be notified and possibly subject to disciplinary action up to and including termination.
Caution should be used when downloading files. Downloads should be for work related use only and should be from a trusted source. It is the user’s responsibility when downloading programs to A.G. Vision Construction systems to check for copyright or licensing agreements. If there is any doubt, do not copy the program.
The computers and computer files furnished to employees are A.G. Vision Construction’s property and are intended for business use only. Employees should not access a file or retrieve any stored communication without prior authorization from management.
A.G. Vision Construction purchases and licenses the use of various computer software for business purposes and does not own the copyright to this software or its related documentation. Unless authorized by the software developer, A.G. Vision Construction does not have the right to reproduce such software for use on more than one computer.
Employees may only use software according to the applicable software license agreement. A.G. Vision Construction prohibits the illegal duplication of software and its related documentation.
Social Media such as social networking websites (including, but not limited to Facebook, LinkedIn, Twitter, YouTube, Snapchat, Instagram or other interactive social media sites) and blogs can be effective networking or communication avenues. Although A.G. Vision Construction respects employees’ rights to personal expression and speech, employees must understand that the posting of information on blogs and the use of social networking sites in an inappropriate manner can have potentially serious and long-lasting consequences on the lives of our employees, clients, vendors and the operations and reputation of A.G. Vision Construction. Once information is shared through social media, it is difficult (if not impossible) to completely undo.
Although employees may reference their employment with A.G. Vision Construction in connection with a personal social network account, employees may not create social network accounts, postings, webpages, or blogs that appear to be affiliated with or endorsed by A.G. Vision Construction. Absent expressed written consent by an authorized representative of A.G. Vision Construction (such as the LCO), employees are not authorized to speak on behalf of A.G. Vision Construction or to represent that they do.
Employees may not use personal electronic devices (such as a cell phone, smart phone, tablets, etc.) for social media purposes during work hours. During or after work hours, employees should not use A.G. Vision Construction’s computers or other A.G. Vision Construction’s electronic devices for social media.
Please see Human Resources representative if you have any questions.
Violation of this Integrity Compliance Program can result in serious consequences for the Company, its image, credibility, and confidence of its customers, and can include substantial fines and restrictions on future operations, as well as the possibility of fines and prison sentences for individual employees. Therefore, it is necessary that the Company ensure that there will be no violations. Employees should recognize that it is in their best interest, as well as the Company’s, to follow this Code carefully.
The amount of any money involved in a violation might be immaterial in assessing the seriousness of a violation since, in some cases, heavy penalties might be assessed against the Company for a violation involving a relatively small amount of money, or no money at all.
Disciplinary action, up to and including termination of employment, will be coordinated through the Legal and Compliance Officer. The overall seriousness of the matter will be considered in setting the disciplinary action to be taken against an individual employee. Additional information is to be reviewed in the Investigations Policy.
Disciplinary action shall also be taken against supervisors or executives who condone, permit, or have knowledge of illegal or unethical conduct by those reporting to them and do not take corrective action. Disciplinary action shall also be taken against employees who make false statements in connection with investigations of violations of this program.
THIRD PARTY DUE DILIGENCE POLICY
Purpose. It is A.G. Vision Construction Nigeria Limited (“A.G. Vision”) policy to enter business arrangements only with individuals and entities that have a proven track record for legal conduct, excellent performance and who also are committed to operating with integrity. A.G. Vision has adopted a policy prohibiting employment or contractual arrangements with individuals and entities whose names appear on the Nigerian Government or the World Bank Group or any similar list of ineligible firms and individuals. The purpose of this policy is two-fold: (1) to ensure that A.G. Vision engages in business with honest and reputable third parties, that is, entities and individuals not involved in or prone to corruption and (2) to document the due diligence process A.G. Vision follows prior to entering a third-party arrangement.
Scope. This policy applies to all proposed A.G. Vision joint venture partners, as well as any proposed major subcontractor or sales consultant agreement or other arrangement with a third party where the value of the arrangement is expected to exceed N200,000.
Due Diligence Information/Red Flags. Various international organizations dedicated to stopping the spread of corruption/illegal activities have identified certain questions that should be asked before entering a third-party arrangement in order to ascertain whether the proposed business partner is likely to engage in corruption. These questions, as well as certain “red flags,” should be considered as part of A.G. Vision’s due diligence process before entering a business arrangement with a third party. These questions and risks are set forth below and shall be considered by A.G. Vision’s management prior to entering a joint venture, major subcontract, or sales consultant agreement or any other arrangement with a third party.
Type and Method of Compensation
Documentation of the Due Diligence Process.
In consultation with A.G. Vision’s Legal & Compliance Officer (LCO), A.G. Vision’s Procurement Manager and senior management shall use these questions and red flags/risk areas as a guide in conducting due diligence and shall document the information obtained from the third party or other sources during the due diligence process. The Procurement Manager is responsible for obtaining responses to A.G. Vision’s Third- Party Due Diligence Questionnaire for all business relationships covered by this policy and shall maintain appropriate documentation including the due diligence procedures adopted by A.G. Vision and all approvals. In potential high-risk situations, A.G. Vision may consider retaining the services of a professional organization expert in conducting due diligence reviews of third parties. The LCO shall periodically audit the third-party due diligence process and documentation to ensure compliance with this policy. Documentation for this audit shall be maintained by the LCO.
The decisions whether to enter a business arrangement with a third-party covered by this policy shall be made by the A.G. Vision Managing Director or Executive Director as the case may be, with the advice and guidance of the A.G. Vision’s LCO.
For reports on ethical issues on the policies, please call +2349131555444 or send an email to : whistleblowing@hotmail.IoDCCG.com