CODE OF CONDUCT POLICY

Naivas Code of Conduct

1. Introduction

Naivas is committed to conducting business with honesty, integrity, and in compliance with all legal and regulatory requirements. This Code of Conduct sets forth the core principles and expectations for all employees to uphold the highest standards in their professional duties.

2. Core Values

At Naivas, our customers are at the heart of everything we do. We prioritize:

• Providing quality products and value for money.
• Treating employees, colleagues, and stakeholders with honesty, integrity, and respect.
• Creating a strong value proposition for our employees, partners, and customers.

3. Compliance and Ethics

Legal Compliance: All employees must adhere to applicable laws and company regulations to protect Naivas’ reputation and avoid penalties.

Business Integrity: Employees must conduct business ethically and transparently, avoiding actions that could harm the company’s reputation.

Personal Integrity: Employees should be accountable, uphold company values, and perform their roles with professionalism.

4. Business Practices

4.1. Conflicts of Interest

Employees must act in Naivas’ best interests and avoid situations where personal gains conflict with company objectives. Any external business relationships must be pre-approved in writing.

4.2. Anti-Bribery and Corruption

Naivas strictly adheres to the Kenya Anti-Bribery Act. Bribery, in any form, is prohibited. Gifts from suppliers or stakeholders are discouraged unless expressly approved.

4.3. Corporate Opportunities

Employees may not use company resources, information, or position for personal gain or to compete with Naivas.

4.4. Supplier and Service Provider Relations

Procurement decisions must be made fairly, transparently, and in Naivas’ best interests without favoritism.

5. Employee Relations

5.1. Employment and Workplace Culture

Naivas fosters a work environment characterized by respect, teamwork, and fairness. Discrimination and harassment are strictly prohibited.

5.2. Equal Opportunity

Employees are hired based on merit, without discrimination regarding race, religion, gender, disability, or any protected category under the Employment Act 2007.

5.3. Employee Growth and Development

Naivas supports employee advancement through training, education, and career development opportunities.

5.4. Health and Safety

Naivas is committed to maintaining a safe, drug-free, and healthy work environment. Employees must comply with health and safety regulations, and smoking is restricted to designated areas.

5.5. Employment of Relatives

Hiring decisions must be merit-based. Employees cannot be in direct supervisory relationships with relatives, and hiring committees must exclude family members of candidates.

5.6. Workplace Relationships

To maintain professionalism, supervisors are prohibited from engaging in romantic or sexual relationships with their direct reports. Any such situations must be reported to HR.

6. Workplace Conduct

6.1. Solicitation and Distribution

Solicitation for non-company-related causes is not allowed during work hours unless explicitly authorized.

6.2. Political Activity

Employees are free to support political causes personally, but such activities must not take place on company premises or involve company resources.

7. Protecting Company Assets

Employees must protect Naivas’ property, confidential information, and intellectual assets from loss, damage, or unauthorized use.

8. Reporting Violations

Violations of the Code of Conduct may result in disciplinary action, including dismissal. Employees are encouraged to report unethical behavior through the appropriate internal channels.

This Code of Conduct reflects Naivas’ unwavering commitment to ethical business practices, customer satisfaction, and employee well-being.

DATA PROTECTION POLICY

Purpose:

This policy provides guidance on how NAIVAS will handle the data it collects.

It ensures compliance with data protection laws, safeguards the rights of data subjects, and mitigates risks associated with data breaches.

Policy Statement:

NAIVAS is committed to adhering to all relevant Kenyan legislation and applicable global data protection regulations.

The company acknowledges that lawful, legitimate, and responsible processing and use of personal data is a fundamental human right.

NAIVAS will ensure that the rights of data subjects are protected and that any data collected or processed aligns with legal requirements.

All NAIVAS employees must comply with this policy. Any breach may result in disciplinary action.

The Board is responsible for ensuring that adequate and effective systems and processes are in place to safeguard data.

Implementation & Compliance:

NAIVAS will implement measures to securely collect, store, and process personal data.

Employees will receive training to ensure awareness and compliance with data protection laws.

Any suspected data breaches must be reported immediately to the relevant authorities within NAIVAS.

Regular audits will be conducted to assess adherence to this policy and identify areas for improvement.

Review & Amendments:

This policy will be reviewed periodically to reflect changes in legislation and best practices in data protection.

SEXUAL HARASSMENT POLICY

1. Introduction

Naivas is committed to providing a safe and respectful workplace free from any form of sexual harassment. This policy aims to safeguard employees of all sexes and gender identities from unwanted sexual advances, provide guidelines for reporting incidents, and outline how complaints will be handled. Naivas operates a zero-tolerance policy for sexual harassment and will take all allegations seriously, investigating them promptly and acting against offenders.

2. Policy Statement

Naivas will not tolerate any form of sexual harassment in the workplace.

All complaints of sexual harassment will be taken seriously and treated with respect and confidentiality.

No employee will face retaliation for reporting an incident in good faith.

Employees found guilty of sexual harassment will face disciplinary action, up to and including dismissal.

3. Definition of Sexual Harassment

Sexual harassment in the workplace includes, but is not limited to, the following unwelcome acts or behaviors:

Unwanted contact and advances (verbal, written, or physical).

Making sexually colored remarks.

Showing pornography or other visual material of a sexual nature.

Requesting or demanding sexual favors.

Any other sexually oriented conduct, including unwelcome verbal, physical, or non-verbal behavior.

Sexually explicit jokes, verbal abuse, or unwanted communications (calls, emails, letters).

Unwelcome flirtations or over-familiar behavior.

Conduct of a sexual nature that interferes with an individual’s work performance or creates a hostile work environment.

Promises of preferential treatment in exchange for sexual favors.

Threats of detrimental treatment or changes in employment status based on sexual conduct.

Any attempt to conceal or justify the above-listed behaviors.

4. Investigations Committee

The Investigations Committee is responsible for handling sexual harassment complaints. The committee will:

Receive and document complaints, including statements from the complainant, respondent, and witnesses.

Conduct prompt and impartial investigations and submit a report with findings and recommendations to HR.

Ensure timely resolution of cases while maintaining confidentiality.

Keep all cases confidential to the extent possible under the circumstances.

5. Complaint Process

The Chief Human Resources Officer (CHRO) shall be the first point of contact for all complaints.

Complaints may be made formally or informally.

The Sexual Harassment Contact will:

Interview the complainant and advise them on possible actions.

Conduct an investigation in confidence, involving relevant witnesses and employees.

Recommend appropriate corrective or disciplinary action based on findings.

Allow the accused employee the right to appeal in accordance with the Naivas disciplinary policy.

6. Non-Retaliation

Employees will not be penalized for reporting sexual harassment in good faith.

Any form of retaliation against a complainant is strictly prohibited and will result in disciplinary action, including termination.

7. Malicious Allegations

Any malicious false allegations of sexual harassment will be treated as gross misconduct and may result in summary dismissal, as per Naivas’ disciplinary policy.

SAFETY AT WORK POLICY

Health and Safety Policy Statement

Naivas considers employee health, safety, and environmental protection as essential aspects of its management process. The company encourages all managers and employees to address health and safety issues systematically by identifying hazards, planning improvements, taking action, and monitoring results. Health and safety needs will be met through locally allocated budgets as part of daily operations.

Naivas recognizes its obligations under the Occupational Safety and Health Act (Cap 514) and is committed to:

Providing adequate control of health and safety risks arising from work activities.

Consulting employees on matters affecting their health and safety.

Providing and maintaining safe equipment.

Ensuring safe handling and use of substances.

Offering relevant information, instruction, and supervision.

Ensuring employees are competent through adequate training.

Preventing workplace accidents and work-related illnesses.

Maintaining safe and healthy working conditions.

Reviewing and updating this policy regularly.

Responsibilities:
While the overall responsibility for health and safety lies with Naivas, all employees must take reasonable care of their own safety and that of others. Employees are expected to:

Read and adhere to health and safety notices.

Cooperate with the company on health and safety matters.

Refrain from interfering with or misusing safety equipment.

Avoid any actions that may endanger themselves, colleagues, customers, or the public.

Familiarize themselves with first aid procedures and fire evacuation protocols.

Any safety concerns should be promptly reported to a manager.

Occupational Safety and Health

Employees must wear the required protective gear in high-risk areas.

Employees should ensure their own safety and that of colleagues by avoiding risky behavior.

Health and safety guidelines for each work area will be displayed on notice boards and must be strictly followed.

Any violation of safety regulations constitutes gross misconduct and may lead to summary dismissal.

If unforeseen environmental, health, or safety (EHS) issues arise, the EHS Manager or designee will assess the risks and allocate appropriate resources to address them.

Training

EHS training will be integrated into the company’s scheduled training programs.

Training needs will be identified and planned systematically alongside other professional development initiatives.

Accident Reporting

Employees must immediately report any workplace incidents to their manager or the Health & Safety representative.

Managers and Health & Safety representatives must ensure that all incidents are documented and reported to the Health & Safety office for follow-up.

Managers must facilitate medical assistance for injured employees.

Alcohol and Drug Abuse Policy
Naivas aims to maintain a workplace free from alcohol and drug abuse. Employees should be aware that reporting to work while intoxicated may result in dismissal. The presence of intoxicated individuals poses a safety risk and affects the company’s high-performance standards.

Guidelines

No one under the influence of intoxicating substances will be allowed on Naivas premises.

Employees suspected of intoxication will be managed according to the Alcohol and Drug Abuse Procedure.

Employees must not operate company or work-related vehicles while impaired by alcohol or drugs.

Possessing intoxicating substances or unlawful drugs at work is a serious offense and will be dealt with per the Employment Act 2007, OSHA Act 2007, Labour Relations Act 2007, and Naivas Disciplinary Code.

Employees using prescription drugs that may impair performance must inform Naivas to ensure safety measures are in place.

Employees may drink socially at Naivas or client functions but must remain within legal limits.

Alcohol may be provided at Naivas functions only with senior management approval.

Employees seeking assistance for alcohol or drug-related problems may receive support under the Alcohol and Drug Abuse Procedure, but continued assistance depends on full cooperation.

Handling Intoxicated Employees

Step 1: Ask the employee if they are under the influence.

Step 2: If there are contradictions in accounts, conduct a visual assessment for signs such as slurred speech, stumbling, alcohol odor, red eyes, or erratic behavior.

Step 3: Obtain a witness statement to corroborate observations. The statement must be signed and include the date and time.

Step 4: Conduct a breathalyzer test. If further confirmation is needed, escort the employee to a police station for alcohol testing or to a Naivas-approved medical facility for a drug test. Naivas will cover testing costs if initiated by the company.

Step 5: Take immediate action. If intoxication is confirmed, send the employee home to prevent further issues. Do not engage in arguments or threats. If they refuse to leave, security personnel or the police may be involved. Inform HR/payroll about lost work hours to adjust pay accordingly.

Step 6: Initiate disciplinary action. On the employee’s return to work, issue a written notice for a disciplinary hearing.

Naivas reserves the right to assess an employee’s state of sobriety and take appropriate corrective action if there is reasonable suspicion of impairment. The outlined steps also apply to non-employees on company premises who appear intoxicated.

This policy ensures a safe and professional workplace for all employees.