Jazeera Code of Ethics and Conduct
Jazeera Airways is committed to comply with all applicable laws and regulations to ensure the highest standards of business ethics are practiced by the Company. All employees are obliged to comply with the Code of Ethics and conduct and engage in lawful and ethical business practices.

The Code of Conduct applies to all employees of the Company. All employees have an obligation to familiarize themselves with this Code.

All employees have the right to report a violation/suspected violation of the code of ethics.

Diversity & Inclusion
The Company is an Equal Opportunity Employer and is committed to diversity across our business. The Company promotes inclusion and diversity, going beyond age, ethnicity, gender, abilities, marital status, social class, and religion to foster an environment that welcomes all forms of differences.

Equal Opportunities
The Company applies equal opportunity policy with regard to employment, promotions, training and development, transfers, job assignments and pay. This policy prohibits consideration of race, nationality, religion, gender, age, color and relationships in all personnel transactions. Discrimination is prohibited in recruiting, interviewing, selection, hiring, promotion, training, termination; lay off, compensation, benefits, and opportunities for growth and development.

Harassment
Jazeera Airways provides its employees with a workplace that is free from harassment based upon race, color, religion, sex, age, nationality, physical or disability and marital status.

Harassment includes, without limitation:

• verbal harassment (derogatory statements, slurs, epithets)
• physical harassment (assault, physical interference)
• visual harassment (cartoons, drawings, postings, emails)
• mental harassment (innuendo)
• sexual harassment (without limitation, unwelcome sexual flirtations, advances or propositions, verbal abuse of a sexual nature graphic or verbal comments about an individual’s body, sexually explicit or offensive jokes, or physical assault).

Any employee who feels he/she has been subjected to harassment by anyone must bring the problem to the attention of HRD/ Direct Manager as appropriate.

Bullying
Bullying is irresponsible behavior that is directed against an individual or group by another individual or group and is derived from the misuse of power over the target of the behavior. This may include:

Verbal abuse, shouting
Excluding or isolating behaviour
Deliberately withholding information vital for effective work performance
Giving employees unrealistic assignments

Physical abuse
Bullying is unacceptable conduct within the Company and all reported incidents shall be investigated.

Whilst it is the responsibility of all employees within the Company to ensure that premises and facilities are free from harassment, managers have a particular and clear responsibility to meet this requirement. Managers who become aware of serious breaches of policy shall immediately notify the VP - HC.

Substance Abuse
Jazeera Airways is committed to provide a work environment which is free from the effects of alcohol and drug abuse. The possession, distribution, or use of any illegal drugs or alcohol, is strictly prohibited in Jazeera Airways premises. Such activities shall be considered a violation of the Jazeera Airways Code of Conduct and will lead to strict disciplinary action.

Tobacco use is not permitted inside any Jazeera Airways premise or property including company provided transport.

Confidentiality

• Employee Information: Jazeera Airways respects the confidentiality of its employees’ personal information. Access to personal records of employees is limited to authorized personnel only. Personal information is never provided to anyone outside the company without proper legal authorization.
• Customer Information: Jazeera Airways prohibits all employees from sharing or divulging any customer related information with anyone outside the company or within the company without prior authorization. Such information may include (without limitation) customer names, account numbers, addresses, and billing information.
• Company Related Information: Salaries and Incentive payments must be treated as most confidential. Employees should not share any Company related documents or information with any internal or external party without prior written consent from the Head of the Department. Any information exchange with external parties shall require prior written Legal Official approvals from the VP HC who might consult with the Company’s Legal Representative.
• Employees should not (either during or after employment) disclose, without proper authority, any confidential or proprietary information acquired during their employment with the Company.

Disclosure of confidential information could be the basis for legal action against the employee(s) responsible for the disclosure. The preservation and security of such information must comply with Company policies and related applicable Kuwait Labour Law.

Employees have a responsibility to ensure that external financial statements/reports and internal management reports are recorded accurately and promptly and to report any known inaccuracies to DM and/or the Audit and Risk Committee.

Misrepresentations that result from intentional acts that may conceal or obscure the true nature of a transaction are clear contraventions of this Code.

All Board Members and employees with access to sensitive and/or confidential data shall maintain the confidentiality of such data, and shall not pass on such information to any person directly or indirectly by way of making a recommendation for the purchase or sale of the Company’s securities.

It is the responsibility of every employee to take reasonable care to protect confidential information against loss, theft, unauthorized access, alteration, or misuse.

Occupational Safety and Health
The Company is committed to providing a safe and healthy workplace for all employees and visitors however, employees have a responsibility to make the workplace a safe and healthy place for all concerned, as far is reasonably practical.

All employees are responsible for:

• Knowing and complying with the health and safety rules and guidelines
• Working so as not to endanger themselves or any other person by any act or omission
• Reporting all incidents, accidents, injuries and hazards to management for action

Customers, suppliers and guests shall identify themselves and obtain approval from the Department they are visiting to access the Company premises. Visitors shall be escorted by a Company employee at all times while on the premises.

Employees shall ensure that there is no conflict or incompatibility between their personal interests, whether pecuniary or non-pecuniary and the fulfilment of their duties. Potential areas of conflict of interest are referred to below:

• A significant direct or indirect (through a family member, friend, or acquaintance) financial interest in a business or company that deals with the Company (competitor, supplier, customer, dealer or agent). "Significant" shall be interpreted as the ability to influence the management of the business or company in which employees have the interest, or that the interest could influence how employees perform their duties in the Company
• Use of an employee’s position with the Company to obtain personal benefit for self or family and friends
• Financial involvement or undertaking that could directly or indirectly compromise or undermine the performance of their duties or the Company objectives or activities.
• If an employee becomes aware of the potential for conflict of interest, they shall notify their Direct Manager of the potential or actual conflict of interest. The Company expects employees to:
  o    Declare any likely conflict of interest to Managers; and

        o    Avoid any detrimental outcome as a result of a conflict of interest.

In any situation, where the concerned employee is not sure if his/her actions might be unethical, he/she shall refer the matter to, or consult his/her Head of Department or the VP-HC.

Company Assets
Employees shall not deliberately misuse Company equipment and/or assets. When using Company equipment, employees are required to follow the instructions provided in order to avoid personal injury and/or maintenance and replacement costs.

Examples of misuse include:

• Copying computer software programs regardless of whether or not the programs are protected by copyright
• Use of the Company letterhead paper or postage when corresponding on personal or other matters not directly related to the Company
• Unauthorized use of the Company logos
• Falsifying, manipulating or destroying business records without specific authorization
• Using the Company equipment for personal commercial gain

Employees provided with vehicles (private or commuter use) are expected to use them in accordance with the Company policy and guidelines.

Use of Social & Online Media

• Employees are encouraged to like and re-post/re-tweet any content on Jazeera Airways social channels to help us get our messages to a wider audience. 
• Employees cannot post on their own social accounts, or other social accounts, comments and content about Jazeera Airways business or people without permission from the VP Marketing & Customer Experience.
• Employees must not denigrate or criticize Jazeera Airways through their own social media accounts, or on other social media channels, websites, forums and blogs.
• Failure to comply with the above could lead to disciplinary action. 

Gifts

• Employees are strictly prohibited to encourage or solicit any gift, gratuity, or any other personal benefit or favour from a current or prospective supplier, vendor, agent, consultant, customer or competitor of Jazeera Airways.
• Gifts include anything of value, including money, merchandise and products, and discount on personal services and purchases.
• Employees may, however, accept unsolicited non-monetary gifts that are of nominal value and do not go beyond common courtesy and accepted business practice.
• Gifts that are beyond the nominal value, and unsolicited, must be reported to the HR Department. The HR Department may suggest the employee to accept the gift and fill a declaration form describing the details of the gift received and from whom.

Bribes
Employees shall neither offer, authorize, give/transfer, nor encourage, solicit, accept any form of kickback, bribe, rebate or other improper payment, in connection with any business transaction, including but not limited to sale/purchase of goods, contracts/vendor agreements.

Outside Employment
Taking up a second employment, out of working hours, is not permissible as per policy. If a staff member wishes to take up employment outside the Company, he must seek the prior written approval of the Department Head and VP HC. The approving authority should consider whether the outside employment would give rise to a conflict of interest with the employee’s duties or the interest of the Company.

Social and Political Activities

• While you may participate in activities of a social or political nature during non-working hours within the parameters of the applicable local laws, no Jazeera Airways facility or resources can be used for this purpose unless explicit written approval is obtained from the CEO.
• Jazeera Airways’ employees also may not campaign actively or act in any manner which impinges on their ability to work in a professional and fair manner in the interest of Jazeera Airways.
• Jazeera Airways shall not be responsible for consequences of employees participating in any social or political activities.

Racial and Religious Vilification

Racial and religious vilification is conduct that incites hatred against, serious contempt for, or revulsion or severe ridicule against a person or group on the grounds of racial identification or religious belief or activity. Racial and religious vilification is a form of harassment and discrimination and is unacceptable conduct in the Company.

Records Management

• Employees need to be aware of their record keeping responsibilities and are reminded there is a legal requirement to adhere to proper records management practices and procedures.
• All employees shall therefore ensure that the Company documents are not placed in unofficial or private filing systems but place such documents in official files.
• Employees shall not remove documents from official files. They are controlled records, and shall be complete, up-to-date and capable of providing organizational accountability when officially scrutinized.
• Employees shall not damage, dispose of, or in any other manner, interfere with official documents or files. The destruction of records may only take place in accordance with a disposal and retention schedule, which has been approved by the Chief Executive Officer.

Personal and Professional Behaviour

Employees are required to undertake their duties in a professional, responsible, conscientious and ethical manner and to act in the best interests of the Company. They are expected to act honestly in all of their duties when dealing with clients, suppliers, contractors and fellow employees.

Employees shall perform the duties associated with their position to the best of their ability, diligently, impartially and conscientiously. In the performance of their duties, employees shall:

1. Comply with Country’s Laws
2. Comply with Company’s Policies and Procedures
3. Strive to keep up to date with advances and changes in the knowledge and the professional and ethical standards relevant to their areas and expertise
4. Maintain adequate documents to support decisions made
5. Treat all persons with courtesy and sensitivity to their rights and provide all necessary and appropriate assistance
6. Not take or seek to take improper advantage of any official information gained in the employment with the Company
7. Not harass or discriminate against employees or in work practices on the grounds of sex, pregnancy, race (including color, ethnic background or national identity), marital status, disability, sexual preference, political or religious belief, or age
8. Act responsibly when becoming aware of any unethical behavior or wrong doing by any employee. Such information shall be forwarded to the CEO
9. Continuously improve work performance.
10. All employees shall actively pursue quality improvements
11. Employees shall take all possible care when using the Company property, goods, intellectual property and services and ensure they are used efficiently, carefully and honestly.
12. Unless otherwise agreed, the Company retains the copyright of work produced by the employee during employment with the Company.
13. Employees are expected to be punctual and regular in their attendance.
    Employees shall conduct themselves professionally at external events and act in the best interest of the Company.
14. Staff may only use e-mail and web browsing for work related purposes and that all e-mail and web access logs shall be monitored for compliance with the staff position.
15. Not make disparaging remarks about other employees
16. It is the employee’s responsibility to provide updates, if any, to their personal information (for example marital status, family member details, updated certificate/qualification) to HR as and when there is a change in such information or when requested by HR. Failure to update such changes within 3 months of applicability which qualify employees for certain benefits, will lead to loss of such benefits for the year. Employee may be granted entitlement to such benefits from the start of the following calendar year.

Dress Code
Employees must maintain a standard level of appropriate business attire at all times. All clothing should be of an appropriate size and laundered to present a neat, clean appearance.

All employees should avoid wearing clothing and accessories that would demote the professional image of the company. Clothing must cover tattoos during official working hours and, when the employee is present on company premises.

Male employees may wear suits (during summertime jackets are optional), dress slacks, shirts, ties (mandatory when jackets are not worn), socks, shoes. Ties, when worn, should be tied appropriately. Local National attire is allowed if worn in full (Ghotra/Eqal).

Female employees are required to wear business dresses, suits, and dress skirts at knee length, slacks, blouses, sweaters, jackets, and shoes. Appropriate hosiery shall be worn when wearing a dress or skirt. Sleeveless shirts or dresses with wide open top & shoulders are not allowed. Female staff must ensure that their dresses or skirts are not shorter than knee length and must refrain from wearing shorts.

Hats, caps or other headgear should not be worn in the office and all employees should maintain a clean and groomed appearance. Hairstyles, hair color, beards, moustaches, sideburns, and other appearance-related items should present a neat and professional style.

Cologne, perfume and aftershave should be delicate. Employees should take into consideration that some of their colleagues may be sensitive to, or have an allergic reaction to certain fragrances.

Thursdays have been designated as Casual Day for employees working in the office premises; employee participation in Casual Thursday is optional. Employees scheduled for an official business meeting must wear business attire. A polo shirt with a collar and proper jeans or khakis are acceptable on casual days. This shall apply for Business or Leisure travel on all Jazeera flights.

Torn denim jeans, training suits, shorts, t-shirts with inappropriate drawings/ statements are not allowed when in office or while utilizing the Employee Travel Privilege.

Exceptions will be allowed for medical conditions or for religious purposes or to honor cultural or racial traditions consistent with business necessity.

Crew and other employees working outside office locations (Airport Terminal, for example) should wear the uniform during duty hours as required. On days where they are not assigned such duties, they should adhere to the above dress code.

Breaches of the Code
The company employees shall understand and adhere to the company code of conduct, company policies and procedures and applicable company charters in addition to the applicable laws and regulations. Where a breach in any of the above has been identified, a response to the breach may result in:

• Counseling and/or disciplinary action
• Termination of employment
• Suspension
• Criminal charges or civil action

Employees who have knowledge or are suspicious of any non-compliance with the Company Code of Conduct shall discuss the situation with their immediate Supervisor /Manager/Department Head or HR or may share their concern via email to ethics@jazeeraairways.com.

CODE OF ETHICS DECLARATION FORM

The Company’s Code of Conduct (the Code) outlines the most fundamental obligations of the employees.

In the unlikely event that the Code conflicts with any other Company policy, practice or work rule, the Code takes precedence. The Code does not constitute an employment contract. The Company reserves all rights to change or modify this Code at any time to the extent permitted by law.

I understand and agree to adhere to the conditions contained within this Code and to maintain the contents in full confidentiality.

I hereby acknowledge having read and understood the Company’s Code of Ethics and Conduct and agree to follow it at all times until departure (resignation/termination) from the Company.