Code of Conduct & Business Ethics

FAIR TREATMENT & EQUAL OPPORTUNITIES

Management Responsibilities: 

1.Equal employment opportunity is embraced when drafting Internal and External Job Advertisements and must not contain discriminatory job requirements such as race, disability, and sex orientation. 

2.Promotions, transfers, and appointments are to be based on the best qualified candidate that meets the requirements for the job. 

3.Salary, benefits, and terms & conditions offered for promotion, transfer and appointment to be consistent with the property’s salary, benefits and employment grid. 

Every Employee Responsibilities:

1.Colleagues with concerns about equal employment opportunity are encouraged to speak to their Head of Department or the Director of Human Resources. 

2. Any conduct or action inconsistent with the property’s commitment to equal employment opportunity should be reported to Director of Human Resources and General Manager.

3. Any employee who breaches the equal employment opportunity policy will be subject to corrective or disciplinary action from written warning up to termination of employment, depending on the severity of the violation.

Diversity & Inclusion:

We celebrate a world that is as diverse as our people and our guests. We will have fair, transparent and clear employee policies which promote diversity and equality, in accordance with applicable law and other provisions of this Code.  

Treating people equally and appreciating differences is part of what gives us a competitive edge and produces excellence. 

EMPLOYMENT OF RELATIVES

1. Relatives are defined as: Spouse (first degree relative), Parent, Child/ Stepchild, Sibling, Aunt/ Uncle, In law (mother, father, brother, or sister through marriage), Niece/ Nephew, Cousin.
2. Colleagues may recommend a relative for vacancies advertised through the Internal Job Advertisement or Company Website and are endorsed as valid vacancies providing, they do fully adhere to the procedures set out in the policy.
3. Full disclosure of the relationship with the candidate should be transparently communicated at the time of introducing the candidate to the Company prior to commencement of the recruitment and selection process by filling the declaration form.
4. Failure to notify the company in writing may result in any offer being made by the Company to the relative to be withdrawn and considered invalid based on the nondisclosure and facts of the situation.
5.  Employee must ensure that the candidates that they recommend are in line with the profile requirements of the position and as per the expectations of the Company for that role.
6. Colleagues may not work in a position where they provide the approval signature affecting wages, hours and working conditions of a relative. In this manner, Finance, Security, Human Resources & Executive Office as well as Executive Committee members of the Resort cannot have a relative appointed within the Resort and this is subject to the discretion of the General Manager. 
7.  Colleagues may not also work in positions where they have direct, dotted line or indirect influence on progression, promotion and other conditions of employment in general, directly approve or have significant influence on decisions affecting the compensations hours, performance evaluations, career advancement or working conditions of a relative. 
8. At no time will employee reassignments take place that would result in an immediate supervisor/ subordinate relationship.
9.  To ensure respect and integrity in our working relationships, a relative may not interfere, intervene or make comment upon the position, duties or working activities of their relative and must fully respect the Manager/ Employee relationship, particularly in the unfortunate circumstances under which an Employee is subject to disciplinary action.

• Workplace harassment will not be tolerated, offenders when found guilty will be subject to corrective or disciplinary action from written warning up to termination of employment, depending on the severity of the violation
• Workplace harassment complaint shall be treated with strict confidentiality
• The complainant may report such occurrences immediately to any If necessary, the complainant and the alleged harasser if working in the same department, will be separated during the course of the investigation, through temporary internal transfer or other suitable arrangements.
• During the investigation, the Director of Human Resources together with the legal counsel (if any) or other management colleagues , will interview the complainant, the alleged harasser and any witnesses to determine whether the alleged conduct occurred.
• On conclusion of an investigation, the Director of Human Resources conducting the investigation will submit a written report of the findings to the General Manager. If it is determined that a violation of this policy has occurred, the Director of Human Resources will recommend appropriate disciplinary action.
•  If the investigation is inconclusive or determined that there has been no violation of policy, but problematic conduct may have occurred, the Director of Human Resources may recommend appropriate agreed course of action on the HRD-FOM-ZLQAA1-028-Let's Hear From You as part of the preventive measure.
• The General Manager will review the investigation report and any statements submitted by the complainant or alleged harasser, discuss results of the investigation with the Director of Human Resources and other management staff as appropriate, and decide what action, if any, will be taken.
• Once a final decision is made by senior management, the Director of Human Resources will meet with the complainant and the accused harasser separately and notify them of the findings of the investigation. If disciplinary action is to be taken, the alleged harasser will be informed of the nature of the discipline and how it will be executed.
• The complainant has the option to take legal action against the alleged harasser. Similarly, the alleged harasser may seek legal advice.
• If the findings confirmed that harassment had occurred, provide counselling and support to complainant for closure. 

Confidentiality

2.5.1 Colleagues shall not at any time during (except in the course of your duties) or after your employment disclose or make use of your   

knowledge of any confidential information of the Company and any company which is a parent, subsidiary, employed or affiliated with Zulal Wellness Resort or any of their business colleagues .

2.5.2 Confidential information includes (without limitation) all and any information in any shape or form, whether on paper, electronic means or otherwise, relating to the financial position, market position, business strategy, business plans, maturing new business opportunities, research and development projects, project formulae, processors, inventions, designs, discoveries or know how, sale statistics, marketing surveys and plans, costs, profit or loss, prices and discount structures, technical data, trade secrets, know-how, business methods, the names, addresses and contact details of business contacts, business partners, customers and potential customers, existing and respective clients, 

contractors, and colleagues and any other information related to the Company and/or the Group of a confidential nature received or acquired by you from the Company or any Company of the Group (“Group Company”) during the course ofyour employment; which the Company or any company in the Group or any of their business colleagues treats as confidential.

2.5.3 The restrictions shall not apply to any disclosure of information which is already in the public domain otherwise than by breach of this Agreement; and to any disclosure or use specifically authorized by the Company or required by any applicable laws or regulations or by a competent government authority or court, provided that you undertake (to the extent permitted by law) to immediately notify the Company of any such disclosure requirements and agree with the Company on the disclosure form and content, and to enable the Company from making known

to the appropriate government 

authority or court, the proprietary

nature of the Confidential Information. 

Intellectual Property 

 It is natural that an employee may make, discover or create intellectual property in the course of your duties whilst in employment with Zulal Wellness Resort and agree that in this respect you have an obligation to protect the interests of the Company. 

The Employee undertakes that if at any time during your employment and during this Agreement you make or discover or participate in the making or discovery of any Intellectual Property relating to or capable of being used in the business for the time being carried on by the Company or any company in the Group, without any compensation to the employee in this regard. 

At the request and expense of the Company the employee shall give and supply all such information, data, drawings and assistance as may be requisite to enable the Company to exploit the Intellectual Property to the best advantage and shall execute all documents and do all things which may be necessary or desirable for obtaining patent or other protection for the intellectual Property in such parts of the country it operates as may be specified by the Company and for vesting the same in the Company or any company member of the Group or as it may direct. 

The employee irrevocably appoints the Company to be his/her attorney in the employee’s name and on his/her behalf to sign, execute or do any such instrument or thing and generally to use the employee’s name for the purpose of giving to the   

Company (or its nominee) the full benefit of the provisions of this clause and in favor of any third party a certificate in writing signed by any Director or the Company Secretary that any instrument or act falls within the authority conferred by this clause shall be conclusive evidence that such is the case. 

 Rights and obligations under this clause shall continue in force after termination of the Employment Agreement in respect of Intellectual Property made during your employment under this Agreement and shall be binding upon the employee’s representatives.

 All notes, memoranda, photographic and sound records, intellectual property (or any copies thereof) relating to matters employed with work shall be the property of the Resort/Company. Upon termination of employment, all such matters shall be returned to the Resort/Company.

Any violation of this policy will make the colleagues concerned subject to serious disciplinary action, including termination.

After employment, use of Zulal Wellness Resort intellectual property and other proprietary materials can be subject to legal action. 

The Core Training Program in the property to include Environmental and Waste minimization and recycling. All colleagues to complete this program during their first year of employment.

Human Resources to organize Corporate Social Responsibility (CSR) activities, such as:

i.With designated school/s to educate school children on the basics of protecting the environment, minimize waste and how to create useful products from recycled materials. 

ii.Monthly cleaning day in various locations within the community, on rotation by department.   

Our policy is to make business decisions based on impartial assessment of facts and sound commercial reasoning. 

A conflict of interest may be defined as a situation in which a colleague’s

own personal interests and motivations are influenced by factors to the extent that they impact their objectivity and differ from the company’s own interests. 

Transparency is a key principle for avoiding conflicts, colleagues have a responsibility to avoid situations arising that may be perceived as conflicts of interest and to be transparent in declaring the existence of conflicts to their line management and to HR if they arise or develop. 

Failure to declare the existence of relationships that could be perceived as conflicts of interest or to respond truthfully if asked represent violations of our policies.

Beneficial relationships with third parties: 

Scenarios in which colleagues maintain

relationships through which they receive a direct or indirect financial benefit from an external party

as a result of that party’s relationship with our organisation (for instance, receiving personal commission payments from a particular supplier or service provider) represent a conflict of interest and are strictly prohibited. 

Related parties:

Spouses and members of the same family may be employed by the resort – provided that their recruitment and appointment are based on objective assessments of their qualifications, performance, skills and experience

and the recruitment decision has been taken without reference to the personal relationship and by members of the management team who have no such personal relationship with the candidate.

However, a colleague may not report directly or indirectly to another family member or spouse; or interact significantly in a professional capacity with one of these parties. 

Colleagues are also forbidden from using personal influence to induce our resort to conduct business with

an external organisation in which a spouse or immediate family maintains a commercial interest.

Colleagues need as well to declare if any personal relationship is present at the workplace, please refer to HRD-POL-ZLQAA1-REC-009 Employment of Relatives V1.

At times, colleagues may be offered gifts or entertainment by external parties such as business partners, suppliers or clients. Colleagues have a responsibility to express gratitude and

Politeness when offered gifts by external parties, regardless of whether or not such gifts can be accepted. Please refer to the Finance policy FND-POL-ZLQAA1-067 Corruption & Anti Bribery detail and guidance regarding  the circumstances regarding whether or not gifts or entertainment may be accepted and the appropriate mechanism for declaring gifts. For the avoidance of doubts, product

Soliciting gifts, entertainment or benefits from external parties by any colleague represents a violation of our policies.

Our policy is to make decisions regarding suppliers and vendors objectively and impartially, and to operate without the appearance of influence as a result of colleagues accepting gifts and entertainment from external parties. Colleagues in procurement functions may not accept any gifts from suppliers or vendors apart from advertising or promotional items of nominal value (such as pens, keychains, cups or glasses, or hats).

The colleague has to declare the receipt of any gift, favour, or benefit to her/his line manager. If refusing a gift or benefit is deemed culturally not acceptable, the decision about what to do with it will be taken by the General Manager or Resort Manager if so delegated by the General Manager; in case of the receipt of a gift. In case of receipt of a gift by Senior Managers/Directors themselves, they will proactively notify their own line managers.

In case refusing the receipt of a gift or benefit is deemed culturally not acceptable, the decision maker mentioned above will either politely decline on behalf of the employee or, if the gift or benefit could not be refused without damaging a business relationship, incorporate it into company property or put it to common use for all the colleagues –Ref: HRD-POL-ZLQAA1-EMR-006-Employee Gifts

All colleagues and managers/directors are ambassadors for Zulal Wellness Resort by Chiva-Som, and should be sensitive to the

potential for their conduct outside of the workplace, either online or offline, to impact their professional reputation and by extension the Chiva-Som brand.

All colleagues have a responsibility to refrain from any behaviour outside the workplace – including online behaviour or participation in social media– that may reflect negatively on the organisation.

Please remember that content that published on the internet can remain in the public domain indefinitely and reach global audiences instantaneously. 

Senior leaders in the organisation have a particular role to act as role models in this

respect, as they are ambassadors of the brand in and outside of the workplace.

When participating in events, activities, or online platforms outside of the workplace, colleagues should exercise personal judgement to ensure that their private actions and views are not interpreted by

others as representing our company. 

Unless acting as an approved spokesperson for the company, our policy is that colleagues' communications on social media platforms and other communication channels are personal opinions, which do not reflect the opinion of the company.

If a colleague who is not authorised to speak as a representative of Zulal Wellness Resort by Chiva-Som and its operations

receives a request for commentary or information from a journalist, regulator, Lawyer, investigator or any other unknown person, please consult Marketing & Communication department prior to any

discussion or providing any information.

Publishing or communicating material in professional communications that is obscene, defamatory, profane,

threatening, harassing or abusive represents a serious violation of our policies, and may result in disciplinary action. Individuals may be held personally liable for defamatory, proprietary or libellous material.

We are committed to the protection and proper usage of company and our hotel owners’ assets. Our company possesses and/or operates a variety of physical and non-physical assets used by employees  and guests, which include – but are not limited to guest rooms and offices; furnishing and decorations; equipment and vehicles; tools and machinery; clothing and accessories; food and beverages; financial assets; services such as phone and email facilities; intellectual property; and

electronic data such as messages or information composed, sent, received or stored using company- provided email systems, instant messaging tools such as Teams or other company-provided systems. 

These company assets do not belong to individual members/colleagues– even if we are entitled to use them.

Colleagues are responsible for ensuring company assets are well-maintained and used only for their intended purpose. Usage of IT assets and resources is governed by a specific IT Resources policy. Deliberate destruction, damage, misuse of company assets – or negligence leading to such scenarios – all represent serious violations of our policies. 

Company data and records are considered company assets, and their destruction or removal without authorisation represents a violation of policy. Forms for the approved removal of company assets from company premises and the authorisation procedures required please approach the IT department for further support and guidance.

Confidential information includes (without limitation) all and any information in any shape or form, whether on paper, electronic means or otherwise, relating to the financial position, market position, business strategy, business plans, maturing new business opportunities, research and development projects, project formulae, processors, inventions, designs, discoveries or know how, sale statistics, marketing surveys and plans, costs, profit or loss, prices and discount structures, technical data, trade secrets, know-how, business methods, the names, addresses and contact details of business contacts, business partners, customers and potential customers, existing and respective clients, suppliers and potential suppliers, contractors, and colleagues and any other information related to the Company and/or the Group of a confidential nature received or acquired by you from the Company or any Company of the Group (“Group Company”) during the course of your employment; which the Company or any company in the Group or any of their business colleagues treats as confidential. 

The restrictions shall not apply to any disclosure of information which is already in the public domain otherwise than by breach of this Agreement; and to any disclosure or use specifically authorized by the company or required by any applicable laws or regulations or by a competent government authority or court, provided that you undertake (to the extent permitted by law) to immediately notify the Company of any such disclosure requirements and agree with the Company on the disclosure form and content, and to enable the Company from making known to the appropriate government authority or court the proprietary nature of the Confidential Information. 

Before filing a grievance, encourage colleagues to talk with their manager first. Often, having an informal chat with a supervisor is all that’s needed to resolve a complaint or workplace issue. 

If the grievance is involving an issue with the immediate supervisor, the grievance should be raised to the next level of superiority, until it reaches the Head of the Department (HOD). 

If the grievance cannot be resolved within the department, it should be raised to Human Resources. Have the proper documentation and justification at hand. 

Be prepared to present these documents. The grievance can be either be verbal or in writing. Nevertheless, all important details must be presented and known to the superior/HOD.

Investigation will take place and depending on the severity and type of grievance it will be further evaluated to identify the next course of action. A complicated and sensitive grievance might involve interviewing and assessing other co-workers.

Once all details are clear, decision can be made. This will be made known to the employee who raised the grievance.

Colleagues may also lodge their complaints or disputes to the Ministry of Administrative Development, Labour and Social Affairs (ADLSA). Depending on the kind of dispute, a corresponding process and recommendation shall be followed by both the employer and the colleague.