Introduction
Every organization needs a code of conduct for the smooth operations of its activities. Code of conduct contains the underlying rules, norms and ethical standard in an organization. The code of conduct is crucial for an organization’s operation because it helps in easy decision-making at all the levels and department in an organization.
The code of conduct also reduces the ambiguity and the confusion that might arise between the management and the employees, as it defines the ways of engagement in an organization. In addition, it describes the behavior expectations in all the stakeholders in an organization. One such country in the UAE that has a comprehensive and elaborate code of conduct policy is the Emirates Nuclear Energy Corporation (ENEC).
ENEC is a company dealing with nuclear energy and it has the responsibility of ensuring that the whole of UAE enjoys safe and efficient nuclear energy. The case study, therefore, focuses on the code of conduct policy at ENEC, with specific focus on the policy development, embedding and enforcement.
Case Study Template
Company Name: Emirates Nuclear Energy Corporation (ENEC)
Headquarters: Abu Dhabi, United Arab Emirates
Sector: Energy, nuclear energy
Number of Employees: 1200
Annual Gross Revenue: $ 5 billion
Status: Government owned
Name of the Company Executive Interviewed: Mohammed Humdan Al Fuhali
Position: Senior Project Manager, Executive Council
Email: info@enec.gov.ae
Phone Number: +9712-659-5556
Date of Interview: 25th May, 2015
Company Description
Emirates Nuclear Energy Corporation (ENEC) is a company that supplies nuclear energy in the whole of UAE and the company is owned by the government. The company’s main objective in the energy sector is to provide clean and sufficient nuclear energy to the whole of UAE. The company was established due to the ever increasing demand for energy in the UAE, which was growing at 9% annually.
Therefore, the company was tasked by the government to ensure that it provides safe and sufficient nuclear energy to UAE to support the country’s social and economic growth and development. The company is located in Abu Dhabi city, UAE, along Muroor Road (East Road). Currently, the company has about 1200 employees that helps it in fulfilling its mandate to the UAE residents Emirates (“Nuclear Nuclear Energy Corporatio”, 2015).
ENEC was established in 2009 by the president of the UAE, His Highness Sheik Khalifa Bin Zayed Al Nehyan, through a decree. The company was mandated with the responsibility of enforcing the nuclear energy program in the whole of the UAE. The corporation has the mandate of producing electricity, assist in enhancing economic growth and development.
The specific tasks of the company is to ensure deployment, ownership and the running of nuclear nuclear energy foe the UAE residents. ENEC, therefore, specializes in the provision of nuclear energy within the UAE. However, the company is not limited to the above core function, as it plays other functions that are related to nuclear energy.
The company is headed by H.E. Khaldoon Khalifa Al Mubarak, who is the company’s chairperson. The CEO of the company is Muhammed Al Hammadi, and he is the one responsible for the operation of the company. The CEO is assisted by six other members of the Board of Directors, including the chairman of the company. In addition, it is the Board of Directors and the top management that ensures that the company’s code of conduct is developed and implemented.
Description of the Company’s Code of Conduct
The company holds the highest level of ethical standards and integrity of its top management and employees, including key stakeholders of the company. The company values the trust bestowed on it by the UAE government and its people and it is therefore the responsibility of the every ENEC employee to ensure that the company maintains its reputation and integrity.
However, in order to maintain its reputation and integrity, the company developed a code conduct guide. This code of conduct acts as a guideline to regulate the behavior of both the management and employees, including other stakeholders that are directly involved in the daily operation of the company.
The ultimate aim of the ENEC code of conduct guide is to ensure that all its employees and stakeholders conduct themselves impartially and ethically while abiding by the company’s set rules and regulation. All employees and other stakeholders must ensure that they subscribe to high integrity all the time. The code of conduct guide directs the employees and other stakeholders of the company where to seek help in case of any code of conduct issue.
Head of Employees is charged with the responsibility of handling all the ethical issues related to harassment and discrimination. Any employee who would wish to reveal some crucial information like whistle blowing seeks help from the General Counsel or compliance department (“Emirates Nuclear Energy Corporation”, 2013, p. 4).
Chief Nuclear Officer is tasked with the responsibility of receiving issues and complaints related to security and safety. Other issues that the above officers and department are tasked to handle include fraud, misconduct, conflicts, and gifts related issues. The code of conduct guide addresses the following specific issues.
Company Values
- Safety: safety and security are the top values that the company cherishes and hold dearly. The company strives to safeguard the safety of its employees, the surrounding environment and the general public.
- Integrity: The company is accountable to the work it is doing, all its stakeholders and the public.
- Transparency: The company is open and it communicates all its information to the public, including the financial information and the safety measures it has put in place.
- Efficiency: The company is efficient and effective in all is operations and it always strives to improve effectiveness.
Workplace Behavior
It is the responsibility of the ENEC’s top management to ensure that it provides conducive and safe working environment to all its employees without any form of discrimination and unfairness. However, it is the responsibility of every employee to treat one another with respect and with a lot of courtesy. All employees also must respect the diversity in the organization with respect to culture, gender and the divergent opinion of others.
Any form of harassment, including sexual harassment, verbal abuse and any form of threat is prohibited in the organization. All employees should not engage in any form of violence within the organization. In addition, every employee is expected to uphold professionalism all the time. Any employee who violates the above codes of conducts and ethical standards must be disciplined and may end up losing his/her job.
Use of the Company Assets
All ENEC employees should use all the assets belonging to the company responsibly and should report any damage when it occurs to the concerned authority on time. With regard to computers, information technology and any other electronic devices belonging to ENEC, the company has the right to access and to reveal any information contained in those devices as par the company’s laws and regulations. All employees using the electronic devices like computers must safeguard the password used in the information technology systems.
The company allows all the employees to use its computer systems, however, the employees should be aware that the use of the company’s computer system is not private. The company can access the private information or data contained in its information technology systems. But the company must follow the set rules and regulation in accessing such private data and information.
Communication
It is the responsibility of every ENEC employee to safeguard the confidential information of the company all the time. Confidential information information about the company is the information that can cause irreversible harm to the company or the information that can give the company’s competitor advantage. Some of the information that the company regards as confidential include sensitive nuclear information and any employee who would wish to share such information must seek permission from the concerned authority. In addition, all the employees who access the Export Controlled Information (ECI) must handle such information with a lot of integrity and should only share such information with the approved parties.
Conflict of Interest
ENEC consider conflict of interest as a situation when an its employee uses his or her position to influence the results of the business decision on behalf of the company for his or her own benefit, and not that of the company. An employee is also considered to be having a conflict of interest when he or she is associated with the parties that are in the company’s transactions, or if such an employee is related to one of the senior officers engaged in the company’s transaction.
Any employee that may have any conflict of interest in any of the company’s transaction must should consult first with the concerned authority before doing any transaction or making decisions on behalf of the company. Employees are always reminded of the importance of the company’s reputation and they should understand that conflict of interest can have a negative effect on the company, sometimes for the employees too. Any case of conflict of interest should be reported to the Legal Division of the company as soon as possible.
Entertainmen and Gifts
Employees are not denied the opportunity to receive gifts from any individual or party doing business with ENEC. However, employees are advised to take precaution when receiving gifts from the organization and individuals that the company is doing business with, including like suppliers. Employees are discouraged from receiving excessive gifts, which may damage the reputation of the company.
Excessive gifts can also compromise employees, leading to subjective decision or unfair judgement. Therefore, employees are discouraged from taking excessive gifts from any partner of the organization because they can interfere with the reputation of both employee and the company.
Every employee should ensure that he/she knows the intention of the person offering the gift and the gift should comply with the ethical standards of both the parties. Employees should also desist from taking repeated gifts from the company’s suppliers, even if they are not excessive because the repeated gifts may compromise the decision and judgement of employees. Employees should also be cautious when invited for events, which are expensive and luxurious with the organization ENEC is doing business with. Therefore, employees should consult the Legal Division before receiving any gift from the company’s suppliers.
Health and Safety
ENEC values and safeguards the safety of its employees. The company takes care of the safety of all the employees in their working stations. However, it is the duty of every employee to be aware and abide by the safety and health policies and procedures that are provided by the company. Employees are always reminded to put on protective and equipments when visiting danger zones or potential danger zones. Employees should also take safety and health precautions when exercising their duties to prevent any form of accident. In case of any accidents, employees are always advised to report the incident to their respective managers. Alternatively, they are advised to visit Safety and Health Department or dial the 777 number for assistance.
Substance Abuse
ENEC is a drug-free zone and any use of hard when an employee is on duty is strictly prohibited. All employees should not report to work under the influence of any drug. However, the use of a prescribed drug is allowed within the company’s facility, but only if the prescribed drug does not impair the judgment of the user. In addition, the possession and the distribution of illegal drugs are not allowed within the company’s premises and employees are not allowed to use such drugs when transacting the company’s business, even outside its premises. Any employee that disregards these rules and ethical conducts must face the disciplinary and may be expelled from the company.
Reporting of Incidents
All ENEC employees have the personal responsibility of reporting any violation of the set rules and regulations. They also have the obligation of reporting any misconduct or fraud that they have either seen or the ones they suspect. However, employees reporting such incidents must be ready to be probed to prove the authenticity of the information and the evidence that they have. It is the responsibility of ENEC to protect and conceal the identity of the persons revealing such information. Employees are therefore encouraged to report such incidence and cases to the concerned authorities because the company will protect their identities.
Corruption and Bribery
ENEC employees are cautioned never to accept any kind of bribery from any kind of source. ENEC also strictly prohibits any form of corruption and any person that engages in either bribery or corruption must face the full law and must be prosecuted. The ENEC’s ethics of conduct also compel any employee that has any kind of information regarding bribery or corruption to report to the concerned authority. Any employee who fails to report such cases can also face disciplinary and may either be suspended or expelled.
Dealing with Suppliers
ENEC always insists on the mutual highest ethical standards when transacting business with the suppliers. The company is determined to be fair when dealing with its suppliers and always encourages supplier to report any case that violates the rules of engagement. ENEC employees have the obligation of staying objective and transparent when carrying out any transaction with any of the company’s suppliers. In return, any supplier that violates the set rules of engagement will be shunned by the company. Suppliers are also encouraged to observe health and safety standards of the their supplies.
Discipline
An employee who fails to comply with the ENEC’s code of conduct must face the full consequences. First, employees must face disciplinary committee, and the committee decides whether they should be suspended or expelled from the company. However, the cases that violates the national laws are referred to the national legal system to prosecute such employees. In cases where the employee is not sure of the action to take, the ENEC encourage such employees to consult their respective managers. The employee also has the alternative of approaching the HR department.
Policy Development
Description of the Policy
In order to define behaviors and code of conduct of all its stakeholders, ENEC developed Ehical Conduct and Integrity Policy. The policy was developed immediately after the company was formed in the year 2009 by the UAE government. The policy sets out the standards that it expects its employees and other important stakeholders like suppliers to follow when transacting any business with the company.
The policy clearly documents the company’s values, code of conduct of employees, the ethical standards of engaging with other players. In addition, the policy gives direction on how the ethical conduct and integrity issues should be dealt with and the consequences one is likely to face by violating the ethical code of conduct. This policy was ratified by the ENEC’s Board of Directors and its top management and therefore it applies to all the employees and the stakeholders, dealing either directly or indirectly with ENEC.
Process of Developing the Policy
The preparation of Ehical Conduct and integrity policy took seven basic steps. First, the company identified and defined the Issues. The main reason why the policy was developed was to define the behaviors of employees and other key stakeholders. The company values integrity and it was the basis of the development of this policy. Safety of employees also was the foundation of the development of this policy.
The next stage of this policy development involved the identification of the people and individuals that were to be involved in this policy development (Sabatier, & Weible, 2014, 12). The policy was first discussed by the Board of Directors and the top management. Other individuals that were included later were Compliance Officer, HR Manager, the General Counsel and the Head of Employee Relation.
The team also invited the International Advisory Board (IAB), which comprised of experts on nuclear safety and security. Some of the resources that were used in developing the policy included the information technology like software programs, a number of databases, consultant studies, various safety and experts.
The third stage was the consultation of stakeholders. The company carried a wide consultation with all the relevant stakeholders. The main stakeholder was the government because the company to make the policy that was in line with the UAE national laws. Other stakeholders that were consulted included local governments, Trade Union leaders, local and international experts on nuclear safety and security and special interest groups. The group that was extensively engaged were the employees because they were the group was to be mostly affected by the policy.
After wide consultation, the company adopted the policy. The final draft was prepared by the committee that was spearheading the formulation of the policy. The policy was communicated to the relevant stakeholders that were to be affected directly by the policy, including employees and suppliers. Several copies of the final copy were made and distributed to various departments in the company for the employees to read and internalized. The same copies were sent to various stakeholders. The Ethical Conduct and Integrity policy, therefore, became part of the ENEC many policies.
The level of engagement in the development of this policy was horizontal. The policy was initiated by the top management. After it was discussed by the top management and the Board of Directors, the level of engagement was lowered to the middle management. At this level, other stakeholders were also engaged like the UAE national government, local government, the surrounding, trade union leaders and special interest group (Halpin & Binderkrantz, 2011, p. 202).
Embedding the Practice
The company used various ways to embed the policy with its systems for its employees and other key stakeholders to feel part of the policy. First, the policy was made available to all the stakeholders through the Company’s website where everyone, even the public, could access the policy. The company also held the departmental forums where employees were educated about the policy.
Finally, there was a week that was dedicated to the training of employees. During this training week, various experts were invited to teach employees about the various technical aspects of the policy like like security measures to be taken by the employees while handling dangerous chemicals.
Implementing the practice received some resistance from some employees, especially on the issues touching on employees’ rights. However, the thorny controversial issues were ironed out through open forums with employees. The organization also faced the challenge of providing the protective equipment for all the employees as per the policy requirement. This challenge was due to the high number of employees that the organization had. The challenge was overcome by acquiring the addition protective equipments through credit that was paid later.
Identification and Reporting on Issues
In order to identify and report the emerging issues out of the policy, the company put in place a help desk. The company developed an IT help desk where everyone could easily report any issues. The help desk was set in such a way that the user of the help desk had to select and submit a ticket through an email to the to monitor.
Then the help desk team received the notification of the new ticket, which one of the team members take over and handle. The system was made in such a way that the sender of the ticket and the team were able to interact. The team then sorted out the issues and then submitted them to the various departments. The company preferred this method because it acted as a central pool of identification and reporting of issues.
Enforcement
The department that was responsible for enforcing this policy included, the Head of Employee Relations, the General Counsel and the Compliance officer. The Head of Employee Relation was handling issues that were arising from discrimination and harassment of the employees or any other stakeholder.
Any issue that was coming from the help desk was directed to the General council to handle those that were emanating from the safety and security were enforced by the Chief Nuclear Officer. The remaining issues, including special issues were handled by the compliance officer (McDaniel & Prakash, 2001, p. 5).
Lessons Learnt
The following lessons were learnt from the above case study
- It is important to engage all the stakeholders when coming up with any policy. The stakeholders that a company might take for granted may be the one with the greatest input in the policy development. The seemingly less important stakeholders are in touch with what happens on the ground and they always give practical situation, not from a theoretical perspective.
- It is important to address the controversial issues at the early stages for the smooth flow of a policy formulation
Conclusion
ENEC is one of the companies in the UAE that values integrity and that has worked towards achieving the integrity of both the company and the employees. It has been able to achieve this because of the effective and efficient code of conduct practices that it put in place when it was first conceived in 2009. The code of conduct takes cares of the interest of both the employees and the company. The mutual benefit made it easier for the company to implement the Ethical Conduct and Integrity policy.
References
Emirates Nuclear Energy Corporation (2013). ENEC Code of General Business Principles and Ethics Reference Guide
Sabatier, P. A., & Weible, C. (Eds.). (2014). Theories of the policy process. Westview Press.
McDaniel, P., & Prakash, A. (2001). Method and system for determining and enforcing security policy in a communication session.U.S. Patent Application 10/006,552.
Halpin, D. R., & Binderkrantz, A. S. (2011). Explaining breadth of policy engagement: patterns of interest group mobilization in public policy. Journal of European Public Policy, 18(2), 201-219
Emirates Nuclear Energy Corporation. (2015). ENEC. Retrieved 29 May 2015, from http://www.enec.gov.ae/index/