Commitment to Legal Compliance and Ethical Conduct

SNMEC expects all employees to comply with applicable laws and maintain the highest ethical standards of business conduct. This policy is a supplement to the general provisions of Business Conduct and aims to help employees adhere to Iraqi laws related to bribery and corruption.

Scope and Applicability of the Policy

This policy applies to all SNMEC employees, directors, officers, and construction site staff, as well as interactions with public and private sector partners. Corruption risks may arise in both commercial and governmental interactions.

Roles and Responsibilities of the Compliance Officer

Ensuring Accountability and Investigative Oversight

Outlining the core duties of the compliance officer in maintaining integrity across the organization.

  • Collection of evidence.

  • Summoning witnesses and collecting their statements.

  • Interrogation of suspects.

  • Submitting final reports to management.

  • Verifying backgrounds of new applicants for any past corruption cases.

  • SNMEC fosters a culture of continuous improvement by identifying weaknesses and developing procedures that ensure optimal results in the most efficient manner.