1- Preamble

At UCC Holding, we stand firmly behind our core values that shape and guide us in our daily operations and relationships. These simple yet essential values ensure that we conduct ourselves with the utmost integrity, delivering high quality products and services while following all applicable laws, regulations, and standards of business conduct.

We at UCC Holding are committed to meet those expectations, and we in turn trust that all our Third parties will honor the same values. This Third-Party Code of Conduct expresses the expectations we hold for our Third parties and mirrors the standards we set for our Business Groups, Affiliated Companies and Subsidiaries.

2- Scope

UCC Holding has developed this Third-Party Code of Conduct (hereinafter referred as “The Code’) that defines the minimum standards that Third party shall respect and adhere to when conducting business with all Business Groups, Affiliated companies and Subsidiaries of UCC Holding. This code clarifies our expectations in the areas of Business Conduct and Integrity, Workers Welfare and Practices, Occupational Health and Safety and Environmental Leadership and Sustainability.

3- Applicability

The Third Party Code of Conduct is applicable to all suppliers, contractors, vendors, consultants, agents and other providers of materials and services including their parent organization, subsidiary or associated entities and to all personnel employed by or engaged to provide services to all Business Groups, Affiliated companies, Subsidiaries of UCC Holding.

4- Commitment

UCC Holding expects all Third party shall adhere to all applicable Laws, Regulations and the requirements set out in this Code and contractual obligations. We expect that Third party shall show their commitment to the principles defined herein by establishing appropriate monitoring systems and by following-up in case they receive knowledge about any violations.

Third party shall have suitable systems and controls in place to ensure compliance with the Code. Third party shall establish systems and controls that shall also apply to the sub-contractors and suppliers they work with which are directly or indirectly connected with providing materials and services to all Business Groups, Affiliated companies and Subsidiaries of UCC Holding.

5- Compliance

It is the third party’s responsibility to communicate, educate and exercise diligence in verifying compliance of this Code to its employees, sub-contractors and suppliers. Third party shall maintain records of all relevant documentation necessary to demonstrate compliance with the Code and related Laws and Regulations.

UCC Holding reserves the right to verify compliance to this Code by continuously monitoring third party compliance the Code by asking Third party to provide relevant information and by conducting audits and reviews.

Third party shall address any violations of this code that come to their knowledge and take appropriate actions. Failure to comply with this Code shall directly impact the ability of the Third party to conduct business with all Business Groups, Affiliated companies and Subsidiaries of UCC Holding.


This Code sets out the principles and standards of business conduct that UCC Holding expects of any Third party who provides products or services to our Business Groups, Affiliated companies and Subsidiaries.

6- Business Conduct and Integrity

UCC Holding expects Third party to conduct business in accordance with the highest ethical standards. We treat all Third party fairly and equally. Decisions are made objectively in order to exceed expectations for cost, quality, service, as well as integrity and reliability.

6.1- Compliance with Law

All Third party with which UCC Holding interacts and collaborates are obligated to adhere to all applicable Laws, Rules, and Regulations of State of Qatar and in the countries in which they operate.

The Third party must at a minimum, perform all duties and expectations in compliance with all laws and regulations ap¬plicable to their business. Third party shall comply with all flow down terms, conditions, and other provisions as specified in the Purchase Order. When performing international business, or if the primary place of business is outside of the Qatar, third party shall comply with local laws.

6.2- Anti Bribery and Corruption

UCC Holding is committed to abiding by all laws and regulations and if necessary, exceeding them to prevent bribery and corruption wherever we do business and expect the same from our Third party.

Third party shall not engage in any form of bribery, corruption, extortion and embezzlement and shall have adequate procedures in place to prevent any such bribery or corruption in their supply chain or by others acting for them. Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted. Behaviors or actions that may negatively influence, or appear to influence, supply management decisions shall be avoided.

6.3- Fair Competition, Anti-Trust and Competition Law

UCC Holding strictly believes in fair competition and prohibits anti-competitive practices. UCC Holding reserves the right to stop and prevent unfair business practices that are likely to reduce competition and lead to higher prices, reduced quality or levels of service, or less innovation.

We expect our Third party to conduct business in accordance with all applicable antitrust or competition laws and reg¬ulations. This includes avoiding business practices such as entry into arrangements that unlawfully restrain competi¬tion, improper exchange of competitive information, price fixing, bid rigging, or improper market allocation.

6.4- Conflict of Interest

UCC Holding expects Third party to exercise reasonable care and diligence to prevent any actions or conditions that could result in a conflict with the interests of UCC Holding or an UCC Holding client, the appearance of a conflict of interest, or that may compromise the exercise of independent judgment during the execution of work for, or on behalf of PIH.

6.5- Intellectual Property / Disclosure of Information

Third party shall take proper care to protect infor¬mation, including confidential, proprietary, and personal information. Information maintained on electronic systems shall be protected against cyber intrusions and other un¬authorized use or access, through appropriate physical and electronic security procedures.

UCC Holding informa¬tion shall not be used for any purposes beyond the scope of the business arrangement with our company, without prior authorization. Third party shall respect intellectual property rights and protect confidential information by safeguarding it against misuse, theft, fraud or improper disclosure. The use of any UCC Holding intellectual property including trademarks and/or any copyright materials is strictly prohibited unless written consent / authorization has been obtained from PIH.

6.6- Financial Responsibility and Records

We expect our Third party to conduct all business and commercial transactions are conducted in a transparent manner and accurately recorded. Actual or attempted money laundering is strictly forbidden.

Third party shall ensure that all records, disclosures and communications to UCC Holding are full, fair, accurate, timely and understandable. The true nature of any transaction shall never be hidden, altered, falsified or disguised, nor any endorsements, approvals, or authorizing signatures for any payment forged. Records or disclosures Third partie knows (or should reasonably know) to be false or misleading shall not be submitted, entered, processed or approved and shall be reported to Third party’s business contact at UCC Holding immediately upon discovery.

6.7- Diversity and Inclusion

Based on our principles of respect and collaboration, UCC Holding is committed to diversity and to equal opportunity in the workplace. We seek to provide a work environment where all persons can reach their full potential and contribute to UCC Holding success.

As part of our commitment to fair inclusion of all persons, as well as our commitment to diversity, third party shall prohibit discrimination based on race, color, age, religion, sex, gender or under any other category protected under the laws.

6.8- Tax Evasion

UCC Holding has a “Zero Tolerance” approach to engaging in or facilitating tax evasion. Third party shall prohibit all forms of tax evasion or facilitation of tax evasion. At all times, third party’s business should be conducted in manner such that the opportunity for and incidence of tax evasion is prevented.

6.9- Legal Matters

Third party shall inform UCC Holding of any criminal investigations or charges, regulatory investigations, fines, penalties or citations, as well as any other claims or litigation against it or any of its affiliates or employees so that UCC Holding can assess its interests and the potential impacts of such investigations, claims, charges or litigation. Third party shall report all such legal matters to UCC Holding management.

6.10- Gifts and Hospitality

All UCC Holding employees are prohibited from offering or receiving gifts, cash, or any other incentive that could influence a business decision. We formally expect complete respect and compliance with this policy from our Third party.

7- Workers Welfare and Practices

UCC Holding is committed to supporting workers’ rights both as part of our commitment and in accordance with the State of Qatar and International Labour Organization Laws. we seek to respect and uphold the fundamental workers’ rights and freedoms of everyone who works with us and of the people and communities where we operate.

We expect our Third party to share this commitment and to respect and uphold the workers’ rights especially in Third party’s workforces, its supply chain and the communities in which it operates. UCC Holding expects its Third party to have adequate procedures in place to ensure they are not directly or indirectly through their supply chain involved in any form of involuntary or forced Labour

Third party will identify and avoid as far as possible any adverse impacts caused or contributed to by their operations or activities. UCC Holding will cease doing business with a Third party who engages in abusive labor practices or exploits vulnerable worker groups. In addition to treating all persons with dignity and respect, third party will provide workers with safe and humane working conditions.

7.1- Freedom of Association and Employment

Third party shall not participate in the exploitation of workers and shall not use forced, bonded or involuntary labor. All members of Third-party workforce shall be free to leave the workplace and the right to terminate their employment as per State of Qatar Laws. No workforce member shall be required to surrender passports official identity documents or work permits as a condition of employment (except for temporary processing or legal requirements) and the retention of such document shall not be used to bind workers or restrict their rights and freedoms.

7.2- Child Labor

Third party shall not employ any person under the minimum legal age for employment as prescribed by the State of Qatar Laws. Legitimate workplace apprenticeship programs which comply with all laws and regulations are acceptable.

7.3- Non-Discrimination

Third party shall not practice any form of discrimination in hiring and employment practices including access to training, promotions and rewards on the grounds of race, color, religion, gender, sexual orientation, age, physical ability, health condition, nationality, social or ethnic origin or marital status.

7.4- Ethics

Third party shall treat all workers equally, irrespective of their nationality, gender, ethnicity, race or religion and shall strictly prohibit compulsory Labour or imposition of any work on workers as disciplinary action or threat of harassment and intimidation against all workers.

7.5- Recruitment Practices

Third party shall treat all job applicants equally and fairly in providing access to employment, training and opportunities for promotion irrespective of their age, nationality, disability, ethnic or national origin, gender, race, religion or belief or marital status.

7.6- Compensation and Benefits

Third party shall pay all workers in accordance with the Wage Protection System implemented under the Qatar Labor Law. Any deductions from wages shall only be made strictly in accordance with the requirements of Law.

7.7- Harassment

Third party shall not tolerate any form of harassment or discrimination. Harassment or discrimination includes without limitation, behavior, comments, jokes, slurs, email messages, pictures, photographs, or other conduct that contributes to an intimidating or offensive environment. Prohibited behavior includes but is not limited to bullying, initiation activities, or hazing (regardless of the other person’s willingness to participate).

7.8- Grievances

Third party shall ensure that their workforce is able to openly communicate and share grievances with management or regulatory authorities regarding working / living conditions and management practices without fear of retaliation, intimidation or harassment.

7.9- Workplace Violence

UCC Holding has a “zero tolerance” policy for workplace violence. Acts or threats of physical violence are not allowed, including but not limited to physical abuse, corporal punishment, intimidation, coercion, stalking, bullying, or similar activities

7.10- Medical Insurance

Third party shall provide comprehensive medical insurance to workers and shall be liable for the payment of workers’ medical insurance premiums. Third party shall provide regular medical examinations to workers who are exposed to occupational hazards as per the recognized protocols at the cost of the company.

7.11- Food Safety

Third party shall ensure that their Food Safety programs are accredited to International standards on Food Safety Management System (ISO 22000:2018) and HACCP Codex Alimentarius. Acquiring Food Handler License from Health Authority shall be mandatory for all personnel employed to work on kitchens, cafeterias, food outlets and mess halls.

8- Occupational Health and Safety

UCC Holding expects all Third party to understand the health & safety risks of their activities and apply good health & safety management systems, training and practices in all they do. Third party are expected to work safely and in compliance with all applicable safety, health and environmental related laws, standards, procedures, rules and with this Code, and with any additional requirements as set forth by the Regulatory Authorities.

Basic safety and health expectations and requirements are set forth below. Additional requirements specific to the work undertaken by a Third party may be specified in contractual documents.

We expect our Third party to comply with applicable safe¬ty and health laws, regulations, policies, and procedures and to provide for the health, safety, and welfare of their workers, visitors, and others who may be affected by their activities.

8.1- Public Safety

Third party shall ensure that there are no potential public safety or health hazards associated with any activity, service, product or equipment/tool supplied to or deployed in the execution of a service for or on behalf of PIH.

Where potential hazards cannot be eliminated, they shall be clearly identified and controlled in accordance with a formal risk assessment that is designed to put in place controls that meet acceptable regulatory limits and recognized industry best practices.

8.2- Worker Safety

Third party shall provide its workforce a clean, safe and healthy work environment in compliance with legally mandated standards for workplace health & safety where they operate, and good industry practices. Identify, monitor and manage workforce exposure to safety hazards via risk assessments, job safety analysis and other appropriate procedures.

Hazards shall be eliminated, controlled or mitigated appropriately. The Third party shall provide its workforce with appropriate safety training and adequate personal protective equipment (“PPE”). As critical partners in achieving our goal of zero workplace injuries, third party are required to report all unsafe conditions, unsafe acts, near miss events and all injuries/illnesses, regardless of severity, as soon as practical.

8.3- Fitness for Work

Third party shall have a process in place for ensuring members of their workforce are safely able to perform the essential requirements of their job without risk to self, others or the environment, and to ensure that they are not impaired by drugs, alcohol, or fatigue.

8.4- Occupational Injury and Illness

Third party shall develop and implement procedures and systems to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and d) facilitate return of workers to work.

8.5- Emergency Preparedness

Third party shall identify potential emergency situations and events and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.

8.6- Industrial Hygiene

Third party shall identify, evaluate and control worker exposure to chemical, biological and physical agents. Engineering and administrative controls shall be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.

8.7- Physically Demanding Work

Third party shall identify, evaluate and control worker exposure to the hazard of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks.

8.8- Machine Safeguarding

Third party shall evaluate safety hazards for production and other machinery. Physical guards, interlocks and barriers shall be provided and properly maintained where machinery presents an injury hazard to workers.

8.9- Food, Housing and Sanitation

Where applicable, members of Third-party workforce shall be provided at a minimum, with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage and eating facilities. Where dormitories or other housing accommodations are provided by the Third party or a labor agent, these shall be maintained to be clean and safe and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space.

9- Environmental Leadership and Sustainability

UCC Holding is aware of its responsibility to minimize impact on the environment through the effective management of our business activities. UCC Holding strives to embrace its values and promote these values within our sphere of influence. UCC Holding is committed to be an environmental leader and demonstrating this through our actions by conducting its business in full compliance with all applicable local and international environmental laws and regulations and operating in an environmentally sensitive manner consistent with our values, approach and policies.

We expect our Third party to operate in a manner that actively manages risk, conserves natural resources, prevents pollu¬tion, and protects the environment. We expect our Third party to apply environmental management sys¬tem principles in order to establish a systematic approach to the management of risks/hazards and opportunities associated with the environment, including potential risk from regulatory non-compliance, reputational loss, as well as opportunities for business growth through operational and product stewardship.

9.1- Compliance with Environmental Legal Requirements

Third party shall comply with all applicable environmental laws, regulations and standards. Third party will also comply with any additional environmental requirements specific to the products or services being provided to PIH, as called for in design and product specifications and contract documents.

Third party shall obtain, keep current, and comply with all required environmental permits and licensing requirements. Third party shall comply with the reporting requirements of applicable permits and regulations

9.2- Pollution Prevention and Resource Preservation

Third party shall identify and implement opportunities to reduce or eliminate waste and pollution at its source and to continually improve resource and materials use efficiency. Third party shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous and nonhazardous waste.

Third party shall prevent unauthorized discharges and spills from entering the environment generally. Further, third party shall manage and responsibly control noise and air emissions from its operations that pose a hazard to the environment or health.

9.3- Environmental Management

Third party shall be compliant with local environmental laws and practices including but not limited to those pertaining to waste disposal (proper handling of toxic and hazardous waste, segregation where regulated, etc.), air emissions, pollution, discharges, etc. QF Third party shall submit evidence of compliance with the local laws and regulations or best practices (e.g. ISO 14001 certification or local counterpart).

9.4- Environmental Permits and Reporting

Third party shall obtain all required environmental permits (e.g. discharge monitoring), approvals and registrations. These permits, approvals and registrations shall be maintained and kept current and their operational and reporting requirements shall be followed.

9.5- Hazardous Materials

Third party shall identify and manage safe handling, movement, storage, use, recycling or reuse and disposal of all chemicals and other materials that pose a hazard, if released to the environment

9.6- Wastewater and Solid Waste

Third party shall monitor, control and treat all wastewater and solid waste generated from operations, industrial processes and sanitation facilities, as required, prior to discharge or disposal.

9.7- Air Emissions

Third party shall monitor, control and treat all air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting c chemicals and combustion by-products generated from operations, as required, prior to discharge.

10- Protected Information and Intellectual Property

Third party shall maintain and protect the confidentiality, integrity and availability of information entrusted to it by PIH, except when disclosure is legally mandated or is authorized by PIH. “Confidential and Protected Information” is UCC Holding proprietary information or third-party information intended for use within UCC Holding that, if disclosed to, or modified by, unauthorized individuals, could result in the risk of financial loss, productivity loss or damage to UCC Holding reputation.

Confidential and Protected Information includes without limitation, client information, legal documents, contracts, proposals, information about a specific client or employee, intellectual property and trade secrets. Unauthorized disclosure of Confidential and Protected information is a violation of this Code.

11- News Media

No Third party shall represent itself to the media as speaking on behalf of UCC Holding unless expressly authorized to do so by PIH. Any media inquiries relating to UCC Holding shall be immediately referred to your UCC Holding management

12- Social Media

Third party shall have processes in place to ensure that the use of social media by Third party, their workforce or representatives / agents does not negatively affect UCC Holding reputation. Third party processes should specifically ensure against the following:

  • • Representation of any content in any social media regarding UCC Holding without prior written approval.
  • • Posting content about UCC Holding staff or personnel, shareholders, customers, vendors, affiliates or competitors that is derogatory or in contravention of any standards in this Code.

13- Use of UCC Holding Name or Brand

Third party shall not use the UCC Holding name or refer to UCC Holding in any of its marketing or promotional materials/websites without prior written approval, including:

  • • Making unauthorized business commitments involving PIH
  • • Using photographs, videos of either UCC Holding or UCC Holding client projects or operations without prior written approval;
  • • Using UCC Holding logo, trademarks or proprietary graphics in any way, without prior consent

14- Codes of Conduct and Sub-Tiers Third Party

Commensurate with the size and nature of their business, we expect our Third party to have management systems in place to support compliance with laws, regulations, and expectations related to or addressed expressly within the Third-Party Code of Conduct. We encourage our Third party to implement their own written code of conduct, and to flow down the principles of a code of conduct to the entities that furnish goods and services to the Third party.