The new KBZ Code of Conduct applies to staff at all levels including Directors both within the Group and all its subsidiaries. The Group Directors have already signed up to the Code of Conduct and any new member of staff will be required to sign up before starting their job. They will be given training in regards to their responsibilities and rights as part of induction to the company.
Code of Conduct training for the rest of our current staff is being carried out over the next 12 months through training workshops at each company, a training of trainers programme is already in place and an e-Learning software tool is being developed. All staff will be required to have signed up by 1 January 2016. The Code of Conduct will be updated and re-circulated to all staff annually (or more often if required).
The code also applies to all suppliers, vendors, consultants and others providing services to KBZ. In selecting partners to work with, KBZ performs a registration and pre-qualification process before a contractor is approved. Subsequent to that, contractors or suppliers are required to sign a Letter of Declaration (LoD) acknowledging their commitment to work to our Code of Conduct. We work closely with our suppliers and contractors, monitoring activities and giving guidance to ensure compliance with our Code of Conduct.
The KBZ Code of Conduct and related Stand-alone policies encompass 11 core strands. We believe that these constitute the structure, along with our monitoring and reporting processes, by which we can ensure organizational transparency and responsible business practice:
- Anti-corruption & Bribery – We have a zero tolerance policy towards corruption, bribery or facilitation payments
- Health, Safety & Environment – We are committed to creating a safe, healthy and conducive environment for all our employees
- Environment - 'Greener ways of doing business' is core to our company ethos. We are constantly looking for opportunities to reduce our carbon footprint and ensure the environment remains healthy for future generations
- Legal Compliance – KBZ acts in compliance with all prevailing laws relevant to all our areas of jurisdiction
- Whistle-blowing – We support and actively encourage any member of staff to let us know whenever there might be an act or suspected act contrary to our Code of Conduct. The company expects all employees to exercise judgment and perform their duties with integrity, accountability and openness
- Grievance – We take staff concerns seriously. We have systems in place for all our staff to report complaints anonymously and without fear of reprimand
- Employment – KBZ is committed to providing staff with just and fair remuneration enabling us to recruit and retain the highest caliber of staff
- Human Rights – Respect for the Human Rights of our staff and other stakeholders is of paramount importance. We do not tolerate child labor, bonded labor or forced labor and strive to comply with the highest international standards
- Procurement – We have an official policy in place for procurement procedures to ensure we carry out purchases in an ethical and cost effective manner
- Land Acquisition – Our policy regarding any land acquisition transactions is set to ensure that all stakeholders concerns are taken into consideration and all parties concerned are satisfied with the outcome
- Social Media – Our social media policy is designed to help protect our staff, our Group and all our stakeholders from reputational risks or risks to personal safety
- CSR Policy – We carry out all our projects with the greatest sincerity to try to utilize our position and strengths to contribute positively in a manner that benefits all stakeholders.
RESPONSIBLE BUSINESS PRACTICE
KBZ Group of Companies is committed to performing as an exemplary corporate citizen. In order to do so, we have a structure in place to implement best practice.
Our core values as an organization determine the way in which we behave. On that basis we have set out a Code of Conduct to which we expect all our staff, suppliers, contractors or other engaged parties to adhere. More detailed group policies derive from the principles outlined in the Code. Finally these guidelines are adapted by each of our subsidiaries to ensure all relevant factors are incorporated.
UN GLOBAL COMPACT
Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and
Principle 2: make sure that they are not complicit in human rights abuses.
Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labor;
Principle 5: the effective abolition of child labor; and
Principle 6: the elimination of discrimination in respect of employment and occupation.
Principle 7: Businesses should support a precautionary approach to environmental challenges;
Principle 8: undertake initiatives to promote greater environmental responsibility; and
Principle 9: the development and diffusion of environmentally friendly technologies.
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.
IMPLEMENTATION OF THE CODE OF CONDUCT AND OTHER POLICIES
KBZ Group of Companies has introduced a structure where the MD or an appointed alternative has been selected in each of our subsidiaries to champion the implementation, reviewing and reporting on all aspects of our Code of Conduct and other policies. She or He is responsible for allocating tasks as appropriate to responsible individuals or committees. We will produce an annual report on our performance based on the feedback from our team.
We have carried out training across our Group initially through Board Members and MDs across the subsidiaries to cascade knowledge throughout our organization. Our first major training session took place at the KBZ Bank AGM on 10th February 2015. This proved to be a success with the support of outside consultants and the support of the Myanmar Centre for Responsible Business (MCRB). Subsequently all KBZ Bank staff have signed up to the Code of Conduct.
On the back of this success, MDs of our subsidiaries (or representatives thereof) have attended a similar training on 12th June 2015. They are responsible for training their teams and ensuring full compliance of staff within their spheres of authority.
We take this process seriously and want to ensure all members of staff truly understand the Code and other policies before putting pen to paper. We want all our staff to fully understand what we expect from them, what their rights are and the direction in which we are heading.
STAKEHOLDER MAPPING AND ENGAGEMENT
At least one individual in each of our subsidiaries and/or their sub-sets is responsible for identifying and engaging with our stakeholders. These will vary according to the nature of the operation, but will include, but not be limited to:
- Local Communities
- Suppliers & Contractors
Annual reports will be published on our Group website putting information about all issues covered in our Code and Policies into the public domain. We welcome feedback from all stakeholders. Our first annual report regarding Transparency, Anti-Corruption and Bribery and Human Rights is attached below.
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AUDITING, MONITORING AND REVIEWING
At KBZ we constantly try to improve our performance. We are implementing ever-better auditing and monitoring processes to help us to meet or exceed the highest international standards. We will engage both internal and external auditors to assess our performance over the coming reporting period to monitor our activities and analyze where we can improve our performance in all our areas of operation.
For a full copy of our Code of Conduct, please download the attached pdf file of
Code of Conduct Myanmar Version
Code of Conduct English Version