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the way we do business
Our Methodology
at AGSTN, we believe business should be personal. How can you build trust and long lasting relations if it was not personal ? ... Our approach in conducting business is driven by Three Pillars: the first is the individual behavior, the person himself and his level of integrity and ethical awareness, the second is work environment itself, and how much guidance and support it may offer to foster ethical competition, the third is our business approach: the principles that guidance us to make the right decision.
Our Code of Business Conduct applies to our entire environment: top from our stakeholders, investors, partners, employees, directors, leadership, and down to the business and companies which we invest or we may support. Everyone is bounded by those principles, and we all reflect one image to protect our brand name and reputation.
code of conduct
The Individual
Each individual of our team, shareholders, partners, and affiliated companies which we may invest with, are and should be behaving and reflecting ethical believe and quality.
The Environment
The work environment in our offices, and in the companies we invest in shall foster and support ethical quality to protect our staff and people around us. The environment shall guide, educate, support, prevent, and eventually hold accountable, to protect our people and society
The Approach
We understand the complexity of our work and how dynamic it moves variables around us. Our Code was designed to help and guide our people to make the right decision during those difficult times. We compete aggressively, but we remain human and ethical to everyone, even to our competitors.
Everyone is Accountable !!
You may report your concerns to our Ethics Committee. Your report is not going to reach one person: it will reach number of induvial in our committee, and it will be actioned seriously
The Individual
Our Values
Anti-Corruption, Anti-Bribery & Facilitation Payments
Quality of Work
Each induvial shall believe and act according to our values: Trust, Humanity, and Value Creation. Those are guiding our decisions and behavior
- Trust: the public trust, and the trust between each one of us, and between us and third-party
- Humanity: we act like good humans, we respect and we support,
- Value Creation: to our business, stakeholders, and society
Quality of Work
Anti-Corruption, Anti-Bribery & Facilitation Payments
Quality of Work
Along with our integrity, the quality of the work conducted are the most critical drivers of our reputation. The work provided should meet best international and professional standards known across industries. The focus on the customer expectations and perception is equally important to the actual need and demand. The customer perception of results should always be taken in consideration.
Anti-Corruption, Anti-Bribery & Facilitation Payments
Anti-Corruption, Anti-Bribery & Facilitation Payments
Anti-Corruption, Anti-Bribery & Facilitation Payments
Our associate shall not offer, promise or grants (personally or through others) any employee or agents of another organization or a third party a financial or other benefit in return for the latter treating (as an organization or individuals) preferentially in relation to others (competitors or whatsoever) without an appropriate reason. The same applies to associates employees or agents of any organization who may ask for or accept such benefits.
Gifts & Entertainment
Government Officials & Politics
Anti-Corruption, Anti-Bribery & Facilitation Payments
We compete fairly on the basis of quality and values. Our associates shall not offer gifts or inappropriate payments regardless of the cause, even if that was not in return of any benefit. Our team complies with “Government Officials & Politics” guidelines at all times, including when working with none-government officials. Any gift represent the individual and his personal relations; it should not be linked to any benefits and should not represent the association.
Government Officials & Politics
Government Officials & Politics
Government Officials & Politics
We love and support those who bring value to our society and cities, however, we do not do business with any government official, we do not support political parties, and we do not campaign for anyone against other.
our associates have their own personal and independent opinion and are encouraged to vote and speak-up to what they support. they represent themselves and not the company. and our offices shall remain free from political talk.
Conflict of Interest
Government Officials & Politics
Government Officials & Politics
Our associates, as professionals, are involved on daily basis in decision making process, directly for the association, or for our customers. We understand that in some occasion, a possible conflict between the personal interests may arise against the association or the customer interest due to various reasons, including personal, social, financial, political or other interests that could interfere with our responsibilities as professionals. Our associates are responsible and accountable to remain free of influence, or the appearance of influence, while making their decision or sending their recommendations.
The Work Environment
Mutual Respect
We have zero tolerance for corruption of any kind, and we expect the same from our contractors, suppliers and customers. We work in a socially responsible and ethical manner and continuously seek to improve the way we conduct business. All our suppliers, contractors and agents must be reviewed and managed in accordance with our policies. We shall not do business with those who are not fully aligned with our business conduct practices.
Anti-Slavery
Global Citizenship: We actively promote health and education in our local communities. We encourage efforts in controlling diseases, and to socially develop communities by supporting initiatives that may improve youth education and living conditions. We foster the economic development of these communities by sharing knowledge with who may work around us. We endorses the aspirations of the International Bill of Rights and encourages work that augments the contributions that business can make to preserve and respect human dignity. Our associates are expected to treat one another professionally and with mutual respect, which is extended to customers, contractors, competitors and others around our work environment. We treat everyone with fairness, respect and dignity. We expect those we work with to act in a way that is consistent with our sense of fairness and equal opportunity. We do not tolerate any form of harassment or other offensive action or abuse. This includes actions that can reasonably be considered as offensive, intimidating or discriminatory, as well as any form of sexual harassment. We believe in diversity of all kinds and backgrounds, people, ethnic groups, gender, age, skin colour and we work together to achieve common objectives. We encourage fair employment practices and offer equal opportunities to everyone within our team, customers and contractors.
Compliance with Local Law, and International Codes
Our associates are obliged to comply with the local laws and regulations of where they operate. Additionally, we shall comply with our customer’s procedures and policies related to our work, including but not limited to Conflict of Interest, anti-corruption, financial reporting, and any other policies that might affect the quality and the integrity of our work. Moreover, we are bounded by the international codes and laws that may come in effect during the execution of any work.
Due-Care, citizenship, laws and relations
We are subject to the laws and customs of different countries. Sometimes these laws vary from place to place and could even conflict. We are responsible for knowing and following the laws and regulations that apply where we work. Whenever there is a conflict between the local laws or common practices, or our customers’ policies, or if one of them was not as strict as our code, then our associates shall comply with the most restrict practice or law applicable to their environment, location or work.
Relations with our Partners & Suppliers
Our suppliers and business partners are essential to our ability to do business and meet our customers’ expectations. We shall choose carefully and use an objective selection process. We seek to work with others who share our commitments to safety, ethics and compliance. We communicate clearly our relevant expectations to our suppliers and business partners, agreeing contractual obligations where applicable. And, we take appropriate measures if they do not meet those expectations or obligations. We shall report any indications that a supplier or business partner is not complying with applicable laws or their contractual obligations. We make sure both parties know and follow the key business conduct and international requirements that may apply to the scope of work, including government contract requirements and joint venture requirements.
Relations with our Competitors
Our associates are competitive and shall compete aggressively, but fairly. We do not secure business or maintain customer relationships by acting illegally or unethically. Each of us must deal fairly and openly with customers, suppliers and competitors. We must not take unfair advantage of a business situation through abuse of confidential information, misrepresenting material facts or deliberately doing anything that may be viewed as unfair. Any kind of agreement or understanding with our competitors to restrict full and fair competition is prohibited. We will not enter into agreements that may fix or control prices, allocate markets, or limit competition. Whenever we are involved in trade association activities or in other situations where there is communication among competitors, customers or suppliers, we must be especially alert to ethical and legal requirements.
Speak freely, encourage reporting and refrain from retaliation
Each of us has a responsibility to speak up if we see something unsafe, unethical or potentially harmful. If you have a question, need help or want to raise a concern you have to speak to the Board of Directors, or reports this via available channels.
The Code of Conduct is written and designed to educate and foster an atmosphere where open communication of ethics and compliance inquiries and issues is encouraged, and to provide all of our associates and people around us with a reasonable understanding of how to identify and report potential violations. Each one of us is responsible for appropriately addressing potential fraudulent, illegal, or unethical issues that may come to attention. Should anyone of our associates or those who are working around us observe or become aware of a potential unethical act, or a violation of this Code of Conduct, whether committed by a person within the association or customer, partner, contractor/supplier or an alliance within the association, or when doing business with us, or with one of our customers, then there is an obligation and responsibility to report any concern through our different appropriate reporting channel. All reports are subject for review and investigation by the Board of Directors. Reported incidents are documented and reviewed with proper action items to control future activities and reduce risk. Any associate who fails to report or provide further information about a violation will be subject to disciplinary action.
Our code prohibits retaliation for good faith reporting of a potential or actual violation of our Code of Conduct, or our internal requirements and applicable laws. However, any report who intentionally reports false information will be subject to disciplinary action.
Our Approach
Health, Safety, Security and Environment
Nothing is more important to us than the health, safety and security of our associate and the communities in which we operate, and behaving responsibly towards our shared environment. We must be vigilant, disciplined, and always looking out for one another. Threats, intimidation, aggressive or abusive behavior and violence will not be tolerated. Explosives, firearms, or other weapons, whether legally permitted or not, are not allowed in our facilities.
Each of us is a role model for safety, who is responsible his or her own safety, and the other colleagues and mates at our work environment. We are obliged to speak up if we observe an unsafe or unhealthy working environment, and shall listen to others who speak up. We shall report any accident, injury, illness, or unsafe condition immediately. We shall never assume that someone else will or has already reported and shall report our own risk or concern. We are obliged to know the emergency procedures/plans that may apply to our workplace. We are obliged to identify risks and put measures to control and mitigate to reduce severity and likelihood; in our workplace, roads, transportation, customers’ business or society.
We are committed to providing a safe working environment for everyone around us. We are expected to discharge our responsibilities and perform our duties in a professional manner at all times while conducting our work, or living our lives. Our customers, and the entire public expect us to provide quality, professional services while being free from the effects of drugs, alcohol, or other substances that may hinder job performance or our judgment. The illegal use, sale, dispensing, distribution, possession, or manufacture of illegal drugs or other controlled substances by any of our associates is prohibited and could lead to disciplinary action. Our associate will ensure that performance is not impaired, by a lack of sleep, poor fitness, alcohol, or any drugs, including prescription or over the counter medication.
We will not undertake work that we are not qualified to perform, and we shall stop work, our own or others’, if considered unsafe. We will protect our environment and take a personal commitment to make it a priority. We expect and will encourage our partners and contractors, as well others with whom we work to comply with sound and effective applicable safety requirements.
Prevent Money Laundering
Money laundering is the process of running ill-gotten gains from criminal acts through a clean financial systems (business) to disguise the illegal origins and make the amounts appear to be legitimate and, therefore, spendable funds. Money laundering can be linked to any crime that generates significant proceeds such as drug trafficking, arms smuggling, extortion, fraud, racketeering, insider trading, tax evasion and other crimes. Additionally, some laundering techniques may also utilized to illegally hide perfectly legal funds, like inherited amounts or divorce cases.
There is a duty and an obligation that our people take and operate through to prevent and reports such illegal activities and amount. Should any of the associate became aware of a suspicious deals, fund or amounts that might be linked to similar activities then those deal and transactions should be immediately reported to the Board of Directors or government agencies.
Our associates shall comply with laws and regulations related to AML (Anti-Money Laundering), including proper financial reporting as per international practice, Bank Secrecy Act and United Arab Emirates laws and regulations:
- The regulations and announcements made by the National Committee for Anti-Money Laundering in the Kingdom,
- Saudi Law No. (3) of 1987 Concerning promulgating Penal Code,
- 1988 Vienna Convention recommendations
- The Central Bank of the UAE, Circular No. 14/93 containing comprehensive customer identification requirements and article no. 5 of the circular.
- Central Bank of the UAE regulation, Notice No. 163/98 hich; the obligation to report certain types of suspicious transactions concerning the deposit of cash or third party cheques
- The Proceeds of Crime Act 2002 that requires reporting Suspicious Activity to as per the UK law. Also, the UK Money Laundering Regulations 2007 apply to related activities.
Additionally, The United States Patriot Act, which amends the Bank Secrecy Act (BSA), that intended to strengthen measures to prevent, detect, and prosecute international money laundering and the financing of suspicious activities. These efforts include anti-money laundering (AML) tools that impact and control the banking, financial, and investment activities of our businesses. As a result of the Patriot Act, activities such as futures commission merchants (FCMs), introducing brokers (IBs), commodity pool operators (CPOs), and commodity trading advisors (CTAs) are subject to investigation and verification, reporting suspicious activity, identity of dealers, and applying enhanced due diligence to certain types of accounts involving foreign amounts and persons.
Comply with Immigration and Visa Regulations
Our business may involve international movement of people. We must ensure that the travel, transfer, employment and residence of our team comply with applicable immigration and employment laws. This requirement extends to dependents of our associates and to their contractors. We are each responsible for our immigration and employment status in the countries where we work and live. And therefore, we shall comply with all immigration and employment laws in the places where we operate. Our associates shall take responsibility for their immigration and Visa status. We expect that all of our associates’ dependents and direct contractors personnel to abide by immigration laws. We shall maintain immigration compliance programs to ensure that correct procedures are followed with our customers while operating to their interest in new countries or locations.
Comply with Trade Control Regulations
We may provide services or knowledge in many countries worldwide, where certain customs laws may come in effect, including additional trade controls that may govern the import, temporary import, export or re-export equipment, software or information, including knowledge and methodologies. Our experts shall work direct with our customers to comply strictly with all trade control laws and regulations that may apply to our work, or us as individuals, wherever we do business. And therefore, we shall comply fully with all applicable trade control laws and regulations, and maintain, especially mindful of technology transfers. We shall review our own shipments for compliance before shipping or releasing. We expect all associates to consult our customers’ trade control compliance, or third party expert on any questionable import or export matter. We comply with Anti-Trust requirements when dealing with customers and competitors as defined in our Due-Care Policies.
Proper Use of Assets, Information and Resources
We are all responsible for protecting our business's and customer’s assets. Assets include facilities, property and equipment, computers and IT systems, information, opportunities and funds.
We are conscientious and shall act appropriately to ensure assets are not damaged, misused, or lost. Our associates understand that assets are provided for business purpose and shall not be used for personal benefit, including internet access. We will protect information, when handling confidential and secret information, we shall be especially careful, and shall protect (by encrypting or other means), and will share only with authorized parties. We shall not share information in public forums or on social media. We are vigilant against cyber-attacks and scams such as phishing and report immediately any incidents, including potential or actual losses of customer information or assets, or of our business.
Intellectual Property & Copyrights
We investment in technology, process and invention. This commitment requires strong protection of the resulting intellectual properties or our own associates or competitors.
Our Intellectual property is created when one of our associates makes a new discovery or conceives of an idea, technique or process that is related to our industries. The invention becomes a joint property of the association and the associate. In our organization, joining the association will mean sharing the knowledge and the ideas among the team to create a concept of creativity and invention within the entire team. Therefore, our association will protect the individual intellectual property and confidential information by using the appropriate documents before using or giving third parties access to any critical information.
Our associates respects copyright and trademark laws and observes the terms and conditions of licenses (including software) and agreements. Never make unauthorized copies of software, publications or other copyrighted material. Likewise, never use trademarks without proper authorization. All the software, copyrighted material or trademarks we use must be properly licensed or owned by the association. We must comply with restrictions on the installation and use of third-party software.
Records, Tractability, Accuracy and Transparency
Our associates are obliged to maintain accurate records at all times. Complete and accurate records are required for regulatory purpose, taxes or financial reports, as well as meeting the customer expectation and requirements. Records, such as (including, but not limited to) time, expenses, billing records, regulatory, or other financial reports) has responsibility to be truthful, accurate, legible, complete, and completed on timely manner and in accordance with policies, law, contractually and all legal and professional standards and regulations.
Destruction of records is completely forbidden at all circumstances, especially, when it comes to hide truth, prohibited by law, or when there is knowledge of (or anticipation of) a subpoena or other request for documents, a regulatory investigation, or a lawsuit.
All Rights Reserved.
Copyright © 2025 - AGSTN
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