Compliance Program Elements

1. Internal Policies & Procedures, Code of Conduct

Warba has developed Internal Policies, Business Code of Conduct and ethics and procedures that address compliance expectations, provide guidance on dealing with potential compliance issues, explain when and how to communicate compliance issues to appropriate personnel, and detail how potential compliance issues will be reviewed and resolved.

2. Compliance Oversight and Management

Warba has established a Compliance Committee and a Compliance & Quality Assurance Manager that will be responsible for implementing the Compliance Manual, carrying out the compliance checks and overseeing Warba compliance program.

3. Training and Education

Warba is committed to providing proper and continuing training to all employees on the Compliance Program, Internal Policies, Procedures and Business Code of Conduct and ethics

4. Monitoring and Auditing

Monitoring and auditing activities are important parts of an effective Compliance Program. The Compliance and Quality Assurance Manager conducts ongoing monitoring and auditing activities to ensure ongoing observation, review and analysis of key activities and risk factors to identify potential compliance breaches and to update the compliance activities based on changes in applicable laws and regulations.

5. Effective Communication

Warba promotes professional excellence and encourages open and honest communication among all personnel.

Warba employees and external stakeholders may report in any of the following ways:

• Compliance Hotline: Directly to the CQAM through the anonymous hotline number at [00964 783 377 9903]

• Website: Anonymous reports can be made through Warba Website: www.warbaco.com at the bottom of the page where it says Report

• Open door policy: Phone calls or face-to-face reports to the CQAM may be made at any time. In all cases, managers or supervisors who get a report will be required to discuss the report with the CQAM

• Open door policy: Phone calls or face-to-face reports to the CQAM may be made at any time. In all cases, managers or supervisors who get a report will be required to discuss the report with the CQAM

6. Disciplinary Guidelines

All employees shall abide by the standard level of conduct and disciplinary described in:

• Internal System and Regulations

• Employment contract and its annexes (Job Description, etc.)

• Warba policies, and any other documents related to standards of discipline that may be adopted by the company.

7. Offenses and Corrective Action

Warba is committed to taking prompt corrective action to address any fraud, waste, abuse, noncompliance, misconducts or any other improper activity identified through internal audits, investigations, effective communications channels made available by Warba, or other means

 



Contacts

Baghdad
Hs.25/2, Av.4,Q 605, Al Mansour, Al Mutanabi, Baghdad, Iraq
T: 00964 7828000160   I   F: 00964 7828000170  I   E: info@warbaco.com

Beirut
6th floor, Ashrafiyah 1020 Bldg.,Abdullah Al Yafi Street, Al Adlieh, Beirut, Lebanon
T: 00961 1 422028  I  F: 00961 1 422557  I  E: info@warbaco.com

Erbeel
Villa No. 113, Bahrika New Road / Lebanese Village, Erbil, Iraq
E: info@warbaco.com

Copyright 2017