Data Protection Policy

Data Protection Policy

INTRODUCTION

The Data and confidentiality Protection is handled and maintained in all aspects in accordance with the Constitution of the Republic Sudan which guarantees that all citizens are allowed freedom of communication and correspondence. Confidentiality is guaranteed and no communication or correspondence may be observed or recorded except as provided by law. In its Article 37 the Sudan Constitution provides for: “The privacy of all persons shall be inviolable; no person shall be subjected to interference with his/her private life, family, home or correspondence, save in accordance with the law”.

Data Protection Policy — Purpose Statement about the use of Personal Information

This policy outlines the guidelines for handling and the purposes for which we hold personal data about our employees, consultants, agents and others who work for us. As part of our Compliance Management System this Policy has been introduced to be part of our internal policies. The Personal Data is being dealt with subject to the constitution and the other relative enactments and legislation and should be kept and handled always subject to law, accordingly:

  1. We will collect, hold and process information consisting of personal data including sensitive personal data about all our employees, applicants for employment, self-employed contractors, consultants, agency workers, and others who work for us, who are referred to in this policy as ‘Data Subjects’.
  2. The purpose for which we hold any information about Data Subjects is solely for administrative and personnel management purposes.
  3. The policy defines ‘Sensitive Personal Data’ as personal data consisting of but not limited to information as to nationality; religion; sex; age; date of birth; health condition; marital status; dependent details; qualifications; residential address; the commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed, including the disposal of such proceedings or the sentence of any court in such proceedings.
  4. The purpose for which we hold Sensitive Personal Date about ‘Data Subjects’ is solely for monitoring equal opportunities, or the provision of specific services to individuals, including but not limited to: suitability and fitness for work, sick pay and sick leave, safe environment and obligations in respect of the employment equal opportunities.
  5. We will establish and adhere to standard retention times for the various categories of information to be held on the records of workers and former workers and the retention times on business needs taking into account relevant professional guidelines. [Normally information about applicants for work and employees, including references and recruitments documents, will not be kept for longer than any period during which claims might be brought against us in connection with which the information may be needed.
  6. The purpose for which we hold any information about ‘Data Subjects’ after the end of our contractual relationship is solely for meeting any residual contractual related matters including, but not limited to the provision of references, processing applications for re-engagement, matters relating to retirement benefits and allowing us to fulfill contractual or statutory obligations.
  7. In addition to the above purposes, we may collect, hold and process data including Sensitive Personal Data if it is necessary to do so for the sake of compliance with any
  8. If necessary for the above purposes we may transfer personal data to our subsidiary and associate companies, insurers, bankers, legal, medical and other professional advisers, administrators of Social Insurance and Pension scheme or pension provider and other companies to which we have contracted work relating to any of the above purposes for which the personal data are to be used. The transfer of personal data is always subject to confidentiality undertaking by recipients. Data may also be disclosed to others at employee’s or data owner request.
  9. Subject to the extent Permitted by Law, we monitor electronic communications by our consultants and employees, within our Information Technology System including access to websites, to ensure that these systems are being used in accordance with our internet policies.
  10. The Data Protection Policy and the relevant enactments set out eight enforceable principles of good practice, to which we will make all reasonable efforts to adhere. These principles are that the data must be: – Fairly and lawfully processed; – Processed for limited purposes and not in any manner incompatible with those purposes; – Adequate, relevant and not excessive; – Accurate; – Not kept for longer than is necessary; – Processed in accordance with individuals’ rights; – Secured; – Not transferred without adequate protection.
  11. Each of our staff and to whom the data subject belongs shall have a right to request access to, and to request correction of, his personal data in relation to our employment agreement. Those who wish to exercise

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  1. Each of our staff and to whom the data subject belongs shall have a right to request access to, and to request correction of, his personal data in relation to our employment agreement. Those who wish to exercise these rights can contact the Human Resources Manager who is the person accountable for Data Protection and Privacy.

Sanctioned and Approved by the Board of Directors this Day of 150 March 2017.

Osama Daoud Abdellatif.

Chairman of Board of Directors DAL Group.

Anti-Corruption Policy

INTRODUCTION

DAL GROUP, based on its mission and philosophy, has set a number of fundamental principles and values which it believes are the foundation of sound and fair business practise and as such are important to uphold. One such principle is a zero tolerance position in relation to corruption, wherever and in whatever form that may be encountered. This document is intended to build on our Ethics Policy and to clearly state the standards and principles required to ensure conformance to legal requirements within Sudan and the countries in which DAL GROUP operates.

LEGAL OBLIGATION

It is DAL GROUP policy to comply with all laws, rules and regulations governing anti bribery and corruption law, in Sudan and all the countries in which DAL GROUP or any of its subsidiary companies operate. We believe it is a fundamental principle of good business practice to respect local laws and customs when operating internationally. However, as Sudanese company, DAL GROUP is also bound by the laws of the Sudan, which governs our conduct both at home and abroad.

Under Sudan law, bribery and corruption is punishable for individuals, and if the company is found to have taken part in corruption it should face punishment. It can easily be seen why DAL GROUP takes its legal obligations in this area very seriously. Under Sudan law the payment, or offer to pay bribes, or provision of or offer to provide gifts or anything of value for improper purposes to obtain or retain business or any other benefit, is prohibited and punishable with imprisonment for a term not exceeding (2) years, in addition to fine and all cases the forfeiture of the property obtained by reason of the offence. Such payments or gifts are also forbidden under the terms of this policy and may result in immediate dismissal for those involved in their payment or receipt.

DAL GROUP is required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

POLICY

This policy applies to all DAL GROUP employees. Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for DAL GROUP or another party. Further guidance as to what is regarded by DAL GROUP as unethical (which includes corrupt) payments can be found in the Code Of Conduct and Gift Acceptance Policies in the HR Manager’s Policies& Procedures Manual.

No bribes of any sort may be paid to or accepted from customers, suppliers, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions.

This policy does not prohibit the following practices provided that they are customary in a particular market, or are proportionate and are properly recorded:

  • Normal and appropriate hospitality (given or received)
  • The giving of a ceremonial gift on a festival or at another special time

DAL GROUP recognises that market practice varies across the international arena in which it does business and what is normal and acceptable in one place may not be in another. DAL GROUP also appreciates that to refuse a gift in certain circumstances and/or countries would offend our trading partners. The test to be applied in all circumstances is whether the gift or entertainment is reasonable and justifiable. What is the intention of the gift? Special care must be taken in accepting or giving gifts/entertainment and these are not

Acceptance of Personal Gifts Policy

DAL GROUP ACCEPTANCE OF PERSONAL GIFTS POLICY 03
1.0 POLICY

It is essential that the professional duties, responsibilities, and work activity conducted by DAL GROUP employees incorporate consistent ethical standards and reflect the commitment to secure and maintain a high degree of trust. DAL GROUP employees are requested to avoid any influence in the performance of their duties. This includes decisions made with regard to purchasing goods; commodi-ties or services; awarding contracts; selecting vendors and contractors; and the-recruit-ment-of-staff.

2.0 PROCEDURES

a) Whenever a vendor offers to give an employee a personal gift of any kind, the employee should politely decline the offer.
b) All business gifts other than items of token value (such as pens, diaries and calendars and promotional materials) should generally be refused.
c) Employees should not accept any gifts from individuals or organizations with whom they have contact in the course of their work as an inducement or kickback to do or not do something in their official capacity.
d) Gifts of promotional items without significant value that are routinely distributed by vendors are acceptable.
e) Ordinary business courtesies, such as payment for a lunch or dinner, are also acceptable.
f) Gifts of money, whatever the amount, cannot be accepted at any time, and should be returned immediately.

HSE Policy

We at DAL Food Company are committed to demonstrate leadership for adopting, implementing and maintaining reliable Occupational Health, Safety and Environment systems (OHSE), and to create value to its interested parties.
DAL Food policy is to:
1- Comply legally with international & national requirements of the Environmental Management System (EMS ISO 14001:2015), Occupational Health and Safety Assessment Series – (OHSAS 18001:2007) and Occupational Health and Safety (OHS ISO 45001).
2- Continually improve Occupational Health, Safety and Environment systems (OHSE) performance by developing objectives, key performance indicators, procedures, work instructions and required programs.
3-Maintain OHSE Management System that defines responsibilities and accountabilities at management, employees and contractors levels and provide required resources for the same.
4-Identify and assess work-related risks, environmental aspects, implement proactive measures to control such risks and prevent / control environmental emissions.
5- Protect Occupation, Health & Safety of employee and assets, and prevent/minimize environmental impacts, work-related death, injuries and occupational ill health through maintaining the Lost Time Incident Rate within the international rates.
6- Develop HSE competency for employees and contractors, encourage worker participation and their positive engagement and consultation in developing HSE performance.
7- Promote OHSE culture and required awareness, trainings and instructions.
8- Consider the principles of sustainable development and sound environmental practices in planning and conducting its business;
9- Monitor, review and evaluate the safe systems of work, controls and processes to ensure HSE integrity and compliance;
10- Develop and maintain emergency response plans to manage the emergency incidents with the aim of preserving life, preventing injuries and preventing losses of properties.

Ihab Daoud
Managing Director
November 2017