Employment Practices Policy

The success of Gazyk depends on its ability to attract, develop and retain a highly competent diverse workforce, and on the creative, effective and productive work life of all Gazyk employees. We believe that talent exists across all population groups, and diversity of employees is a key business objective of Gazyk. We will conduct our business with due regard to the human dignity and innate worth of each individual.

Gazyk policy follows and encourages nondiscriminatory employment practices worldwide. All decisions and actions regarding employment matters, including such things as hiring, development, compensation, promotion, transfer and termination must be taken in an objective, honest and nondiscriminatory manner. We realize that business decisions should include family considerations whenever possible. Respect for each individual must be maintained and everyone must be able to work in an environment free from sexual or any other form of harassment. Each employee must be secure in confronting issues without fear of retaliation.

Gazyk is an international organization operating throughout the world. It is expected that all employees work together in the spirit of equality and mutual respect. Gazyk normally does not hire close relatives of an employee such as spouse, father, mother, son, daughter, brother or sister. In the judgment of Gazyk, the hiring of relatives may cause conflict of interest or give rise to problems with respect to supervision, safety, morale and/or security. The decision to hire a spouse must be made on a managerial assessment of Gazyk’s need and the abilities of the spouse. The decision that is made must be in the best interest of the company. Gazyk normally does not rehire employees who have resigned or who have been terminated for any reason.

Any violation of this Policy may subject the employee to disciplinary action.

Driving Policy

Driving is the activity that presents the greatest potential risk for accidents in Gazyk. To minimize this risk and ensure that worldwide standards for driving qualification and practices are followed, this driving policy applies to all Gazyk organizations. This policy also provides the foundation for building a driver improvement program. The following shall be implemented in all locations. Journey management and driving standards shall document details of the requirements in each program. For helping organizations be compliant with this policy, management shall produce a time-bound implementation plan.

Driver training and qualification

Only approved personnel and contractors are allowed to drive vehicles on behalf of Gazyk, including company-owned or leased vehicles, vehicles rented for business purposes, and when claiming kilometer/mileage allowance. Approval is granted to drivers who have taken defensive driving training every three years and commentary driver training annually. These training programs must be documented.

Seat belts

As a condition of employment, all employees and contractors must wear seat belts at all times when driving a vehicle, and they must ensure that all other vehicle occupants are also wearing seat belts.

Journey Management

All locations shall have in place an active journey management program that complies with the applicable standard. Each location’s journey management program shall address all local driving conditions and identified risks.

Substance abuse

Driving a vehicle while under the influence of alcohol or any drugs or narcotics is strictly prohibited and subject to disciplinary action including termination as stated in the Gazyk Substance Abuse Policy.

Driver improvement monitors

An approved driver improvement monitor shall be installed in all vehicles designed for road use that are owned, leased, or subcontracted by Gazyk. All locations shall adopt a program for regularly reviewing the data gathered by the monitors and using that data to continually improve driver skills. Management must be actively involved in the implementation of this program.

Cellular phone

Drivers should neither initiate nor answer a cellular phone call or message while driving a vehicle, regardless of whether a hands-free device is available or not. Cellular phones may be left on during a trip to alert the driver of an incoming call or message; however, the vehicle must be brought to a complete and safe stop before responding.

Disciplinary action 

Violations of this policy can result in disciplinary action.

Information Security and Confidentiality Policy

Information is the foundation of our business. Protection of confidential information, whether belonging to Gazyk or to others who have entrusted such information to us, is essential to our reputation and to the survival of our business.

This information can be in many forms-physical, electronic, and intellectual (such as knowhow), and can relate to any part of the businesses of Gazyk. Common examples include tool designs, application source code, smart card personalization data, marketing plans, clients’ reservoir information, information kept in the Corporate Directory, operating results, financial information, ongoing research planning, inventions, and techniques. While the technology applications we use and the other confidential information we develop usually belong exclusively to Gazyk, at times, we may also be entrusted with highly confidential information of others, including our customers.

It is vital to the business success of Gazyk that we maintain confidentiality to all such information. All business, financial and technical conversations, notes, manuals, and papers and other forms of confidential information, whether physical or electronic, must be protected and Gazyk employees are not to disclose confidential information to any unauthorized person, either intentionally or by accident.

Unintentional disclosure of confidential information can be just as harmful as intentional disclosure. Gazyk employees must be careful to avoid accidental disclosure-whether through careless conversations or the improper handling of documents, data, and software. Employees are to be adequately trained and are then expected to protect confidential information by adhering to the Information Security standards and procedures related to their use, administration, or support of information technology resources. Information Security will publish and update standards and procedures that apply to all employees and operations. The Quality and HSE function will continue to participate in information security risk identification and mitigation processes at operational sites. Personnel remains responsible for properly initiating new and terminating exiting user accounts, as well as the deployment of employee education, supported by the Information Security function. The ultimate responsibility for information security lies with the line management of each Product Line. They are to ensure it is addressed as a critical business issue by providing the leadership and resources required in their respective organizations. Management should ensure the organization’s compliance to the Information Security Standards through regular measurement of security results and audit of risk mitigation activities.

Any violation of this Policy may subject the employee to disciplinary action.

Non-Disclosure Agreement Policy

A Non-Disclosure Agreement (“NDA”) or Confidential Disclosure Agreement (“CDA”) generally provides that the receiving party will hold information in confidence and will not use that information for any purpose other than as permitted by that Agreement.

It is Gazyk policy not to enter into negotiations concerning NDA’s unless appropriate prior management and legal approval has been obtained. In our business we can distinguish three categories of NDA’s:

  1. Unilateral NDA’s that protect Gazyk information
  2. Unilateral NDA’s that protect the other parties’ information
  3. Bilateral NDA’s that protect both parties’ information

For example, NDA’s are necessary when:

  • Gazyk decides to outsource goods, work and/or services; or
  • Gazyk decides to sell part of its business; or
  • Gazyk decides to bid for goods, work and/or services for which it requires Customer’s information and/or specifications; or
  • Gazyk receives confidential information for the purpose of determining whether such information could be used in developing a new product or service; or
  • Gazyk is interested in purchasing a business (or part thereof) from a third party; or
  • An outside party and Gazyk decide to jointly develop technology.

In negotiating an NDA, the definition of what constitutes confidential information and the permitted use of such confidential information must be described in detail. The actual exchange of information should be carefully organized, documented and monitored. Employees authorized to have access to such information must be clearly identified and limited to those who have a “need to know.” Each person with access to such confidential information must strictly comply with the provisions of the agreement.

Any violation of this Policy may subject the employee to disciplinary action.

Personnel Policy

In Gazyk, we believe that the creativity, energy and expertise of our people is the foundation on which we build our success. Therefore, our ability to attract, develop, motivate and retain outstanding individuals is essential to the future of our business.

Management and the Personnel Function are responsible for supporting our people and inspiring them through effective leadership, based on the following Personnel Principles:

  • Recruit where we work
  • Promote diversity of nationality, culture, gender and thought
  • Train and develop people continuously throughout their careers
  • Manage by objectives
  • Promote from within, based on performance and potential
  • Offer borderless career opportunities
  • Respect and care for individuals and their families
  • Offer a competitive compensation and benefits package

These are the underlying principles that have helped to shape our company culture and which create limitless opportunities for personal growth. It is the combined offering of these elements that makes every career with Gazyk a unique and highly rewarding experience.

Personnel Security Policy

Gazyk recognizes that exposure to violence, blackmail, threats, kidnapping, conflicts or civil unrest exists worldwide and there exists the possibility that our personnel can be exposed to or involved in such events.

It is Gazyk’s policy therefore, to conduct its worldwide businesses in a low profile and professional manner, which provides for optimum protection of its personnel and assets in events of political or criminal aggression.

Although we believe that personal security is the responsibility of each one of us, Gazyk’s Personnel Security Policy acknowledges, particularly for those personnel who are in unfamiliar environments, the need for the company to provide critical support to the individual efforts.

The Policy consists of the following actions that will be implemented across the company:

  • Guidelines on good security practices to our employees and their families
  • Assessment of potentially hazardous situations jointly with our customers
  • Definition of risk level and performance of security audits by a third party, if required
  • Preparation of relevant protection and evacuation plans
  • Coordinated Response in the event of security related incidents.

Management is responsible for the implementation of the Personnel Security Policy with the support of the QHSE and Risk Management organization in cooperation with our customers and national authorities.

In each country where a potential risk exists, Gazyk Chief Security Officer shall be in charge of coordinating the implementation and execution of the Personnel Security Policy.

Quality, Health, Safety, Environment and Quality (QHSE) Policy

The Gazyk Policy on Quality, Health, Safety and Environment applies across Gazyk and is instrumental for the continued business success of Gazyk, by protecting people, the environment and helping our ability to continually improve the quality of our services and products. The Gazyk QHSE policy is aligned with our Values and General Business Principles on how we operate, involving people and communities where we live and work.

Our policy and commitment reflects the integrated way we work across Gazyk in the areas of Quality, Health, Safety and Environment (QHSE). This commitment is in the best interests of our customers, companies, contractors, employees, stakeholders and the communities close to our operations.

In Gazyk, we are committed to:

  • Pursue the goal of protecting the health, safety and security of our people;
  • Protection of, and minimizing our impact on the environment;
  • Efficient usage of material and energy including natural resources, to provide our products and services;
  • Respect and contribute to the societies in which we operate;
  • Strive for elimination of HSE accidents and Quality non-conformances;
  • Systematic approach to QHSE management designed to achieve continuous performance improvement
  • Set QHSE targets for improvement and measures, appraisals and performance reports;
  • Plan for, respond to and recover from any crisis, emergency and business disruption;
  • Manage QHSE matters as any other critical business activity;
  • Communicate with our contractors and stakeholders to ensure an understanding and to manage QHSE in line with our policy and standards;
  • Promote a culture in which all Gazyk employees share this commitment

This policy shall be regularly reviewed to ensure ongoing suitability. In this way we aim to have a QHSE performance we can be proud of, and add value to our customers, stakeholders and society.

Risk Management Policy

People, property, earning capacity, and reputation are key determinants of Gazyk’s future. Their development, preservation, and security are essential for growth and long-term survival. Gazyk seeks to protect and preserve both its tangible and intangible assets from loss or damage that could materially affect its ability to fulfill its commitments and discharge its responsibilities to its customers, employees, shareholders, and the communities in which it operates. Gazyk also seeks to assume and manage risk associated with strategic business opportunities that may leverage its domain knowledge and its intellectual, technical, and financial capital.

Effective implementation of the risk management process improves the quality of decisionmaking in the face of uncertainties. The risk management process should operate efficiently and consistently so that appropriate and reliable reporting of risk management practices can be made when so required.

Gazyk engages in a process of risk management to

  • Identify and assess risk and opportunities associated with Gazyk’s business activities
  • Identify and use appropriate risk management tools, training, and techniques that facilitate and enhance the quality of decision making
  • Select and implement cost-effective risk control measures to avoid or reduce undesired exposures to loss or unwanted volatility
  • Encourage a spirit of entrepreneurship such that natural tendencies toward risk aversion are tempered by awareness that measured risk assumption is a significant component of improved profitability
  • Implement appropriate risk financing and risk transfer strategies (including, but not limited to, insurance) to offset the effects of any losses or unwanted volatility, so that the lowest sustainable cost of risk is obtained over the long term.

Commitments to acquire new businesses, to allocate resources to geographically or politically challenging zones, to launch new business activities, or to accept atypical or onerous contractual terms and conditions must be supported by reasoned and reportable risk analyses – to support the appropriate management approval process.

GeoMarket managers and Area business managers have the primary responsibility and accountability for identifying and assessing operational risk. They also have the primary responsibility for implementing appropriate risk control measures where the cost/benefit has been demonstrated. Evaluation of risk control options is performed in close liaison with the business support functions, notably, QHSE, Risk Management, and Legal and Contract Management. The Risk and Insurance Management Team and the Finance Function have the shared responsibility for designing, proposing, and maintaining appropriate risk financing and risk transfer strategies.

Sexual Harassment Policy

A basic element of the business strategy of Gazyk is to develop a global culture in which men and women of all backgrounds and nationalities can build on the strengths of diversity while they work together as a team for the success of Gazyk. Respect for each individual is an essential part of this process. Sexual harassment is contrary to Gazyk values and against everything we are working for. It will not be tolerated.

Sexual harassment can include such things as:

  • Unwelcome sexual advances or propositions;
  • Any verbal or physical conduct of a sexual nature which unreasonably interferes with another person’s ability to work or creates an intimidating, hostile or offensive work environment;
  • Personnel decisions such as hiring, promotion, compensation and continued employment, which are based on an employee’s acceptance or rejection of sexual advances;
  • Inappropriate attempts at sexual humor.

Anyone believing in good faith that she or he has been subjected to sexual harassment by anyone in Gazyk, or anyone with whom Gazyk does business, should immediately contact her or his supervisor, Personnel Manager, or any other Gazyk manager. Complaints and questions regarding possible sexual harassment will be treated in a confidential manner, and all complaints will be investigated.

There will be no retaliation for making complaints or asking questions under this policy, or for responding to questions during any investigation of these matters.

All Gazyk business units are responsible for the establishment and communication of effective policies and procedures consistent with this basic principle.

Substance Abuse Policy

Gazyk has the responsibility to maintain a safe and productive work environment free from the adverse effect of alcohol, controlled substances and drugs. Employees who work while under the influence of alcohol, controlled substances or drugs present a risk to co-workers, Gazyk assets, the community and themselves. Therefore, it is Gazyk policy that any person impaired by the use of alcohol, controlled substances or drugs is prohibited from entering Gazyk facilities, engaging in Gazyk business or operating Gazyk equipment. Also, trading and illegal or unauthorized use or possession of alcohol, controlled substances and drugs is strictly prohibited while on Gazyk premises or engaged in Gazyk business.

Exceptions

This policy does not apply to:

  • The use of prescribed drugs provided these do not affect the person’s ability to perform his/her duties in a safe and productive manner
  • The moderate and responsible consumption of alcohol on non-operational premises or at Company business or social functions or in connection with business travel or entertainment if local law and customs permit, and if allowed by, and under the control of Management.

Searches and Tests

Gazyk reserves the right to conduct at the work site or at the point of departure to, or return from, the work site, in an appropriate manner and without prior announcement, searches of the personal effects, lockers, vehicles and quarters of any person subject to this policy and/or tests of employees, agents and subcontractors.

In particular, such searches or tests shall be conducted under, but not limited to, the following circumstances:

  • Pre-employment or re-employment
  • After an accident
  • Reasonable suspicion
  • Compliance with law or regulation
  • Under a client program
  • After a rehabilitation program

Employee Assistance Program

Gazyk offers employee access to a substance abuse Employee Assistance Program (EAP). It is a self-referral program and operated on a strictly confidential basis through the Gazyk medical organization. In order to avoid disciplinary action, the EAP must be requested prior to discovery of possession or a positive test.

Disciplinary Action

Anybody who refuses to submit to a search or test or is found in violation of the above policy shall be subject to applicable lawful disciplinary action and/or removal from Gazyk property.

Laws and regulations

This policy must be administered and enforced in accordance with applicable laws. In the event of a conflict between any provisions of this policy and applicable laws, the applicable laws shall apply.

Supply Chain Services Policy

An effective and efficient supply chain is essential to the success of Gazyk. Our overall objective is to maximize value for the company through best in class planning, sourcing, procurement and delivery. This is achieved through the rigorous use of systematic and integrated processes to select, develop and manage our supplier base. We work with our suppliers in a socially responsible and ethical manner and continuously seek to improve the way in which business is conducted. Our focus is to procure and deliver products and services when required, with no defects, and at the lowest total cost of ownership.

The Gazyk Supply Chain encompasses the core activities of demand planning and of identifying, selecting, developing, collaborating and managing sources of supply and delivery of goods and services. The Supply Chain organization is responsible to ensure that:

  • Gazyk procures goods and services that meet requirements and are delivered on time while minimizing the total cost of ownership.
  • Security of supply and delivery of the required goods and services is assured.
  • Supply chain processes are continually reviewed, improved and consistently followed in accordance with other Gazyk policies.
  • All suppliers and contractors providing goods and services are formally approved, regularly reviewed, and managed in accordance to all relevant Gazyk policies and standards.
  • Suppliers are actively managed in order to continually improve quality, delivery and costs of their

goods and services.

  • A cross business perspective is taken to highlight opportunities, identify synergies and make best use of Gazyk’s purchasing power.
  • Training is proactively managed to develop a top performing workforce.

Performance of the Gazyk Supply Chain is assessed against the criteria of quality, delivery, cost, availability, and customer satisfaction. Defined metrics are used to measure operational performance and identify opportunities for improvement within Gazyk and its supplier base.

All employees are required to conform to this policy as it forms the basis by which we effectively manage our supply chain and contribute to the long-term business success of Gazyk.

Trade Compliance Policy

Gazyk employees must strictly comply with all applicable import and export control laws and regulations in the jurisdictions where the Company does business.

Procedures must be maintained to ensure every import, export, or re-export of goods, services, or technology complies with applicable laws and regulations, and that all necessary Governmental approvals for such transactions are obtained. Management has primary responsibility for developing and implementing programs and procedures that maintain compliance governing the import and export of Gazyk’s goods, services, and technology. The Legal Department, and trade and customs compliance functions are responsible for advising on compliance with, and changes in, laws and regulations that may require modifications to such procedures.

Gazyk employees involved with the import, export, or re-export of goods, services or technology must familiarize themselves with such procedures, receive training proportionate to their job responsibilities, as well as obtain and maintain a working knowledge of applicable trade and customs laws and regulations. In addition, Gazyk employees shall cooperate fully with all import and export control compliance activities, including audits and reviews.

Violation of trade regulations can subject Gazyk and individual employees to civil and criminal liability. Internally, any violation of this Policy may subject the employee to disciplinary action.

Conflict of Interest Policy

All Gazyk directors, officers and employees must avoid situations which involve, or could appear to involve, conflicts between their personal interests and the interests of Gazyk companies or of Gazyk customers. Any personal loans by Gazyk to directors, officers or other employees (or any family members) or any guarantees of obligations, are prohibited, unless approved by Company Founder.

Gazyk employees are expected to put Gazyk business interests ahead of their own. Information about Gazyk business or prospective business must not be used for personal gain or to compete with Gazyk, directly or indirectly, in the purchase or sale of property or other interests. Gazyk employees must not work for a competitor of Gazyk while at the same time working for Gazyk. In addition, Gazyk employees must not be directors, officers, agents, or consultants of companies competing against Gazyk. Sometimes Gazyk employees and members of their immediate families have active interests in other businesses. Relationships between these businesses and Gazyk must be avoided, unless specifically approved by the Founder. Finally, Gazyk property, such as equipment, financial assets or confidential information must be used only for proper Gazyk purposes.

Any violation of this Policy may subject the employee to disciplinary action.

Business Ethics Policy

Gazyk is committed to, and expects from its employees, the highest ethical standards of business conduct and compliance with laws and regulations in the countries and business segments where we operate. The Company obtains business through well-trained and motivated people who are dedicated to customer service through the provision of high quality services and products. Gazyk does not solicit or maintain business through illegal conduct or practices of unfair competition such as price fixing, collusion with competitors, or deceptive trade practices. Employees should not accept (nor provide) gifts of more than token value from (or to) any company or individual that does business with Gazyk, or seeks to do so.

Gazyk expects all employees to raise concerns and to ask questions when issues arise. Employees are encouraged to contact their line or functional manager to resolve issues of concern. Other available options for employees include contacting an appropriate functional representative (in the Personnel, Legal, Finance, or other department). It is the responsibility of line and functional management to make sure that appropriate issues of concern are brought to the attention of upper management.

Any violation of this Policy may subject the employee to disciplinary action.

Anticorruption Policy

Gazyk competes vigorously, but fairly in all countries and business segments in which it operates. This is based on the superior quality, productivity and value of its products, services, and employees. The Company does not obtain any business advantage through bribery, improper payments or any illegal means.

Gazyk, its employees, and persons or entities acting on its behalf are strictly prohibited from offering, paying, or authorizing anything of value to a Government, public or company official to influence or reward any act of an official or to gain any improper business advantage. In addition, the direct or indirect offer, payment, solicitation, or acceptance of bribes in any form is strictly prohibited. Moreover, no contributions of Gazyk funds or assets shall be made to political parties or organizations, or their leaders, or to candidates for any public office.

This Policy also applies to any activities on behalf of Gazyk conducted through a relationship or arrangement with any non-employee that is intended to assist a Gazyk company in obtaining or retaining business. This also applies to anyone acting on behalf or in the interest of Gazyk, including consultants, sponsors, or advisors. Where a country’s law governing corrupt practices requires that certain internal accounting controls be implemented and monitored to ensure compliance, then such controls must be followed by all employees.

Any violation of this Policy could result in the civil or criminal prosecution of Gazyk and the persons involved. Internally, any violation of this Policy may subject the employee to disciplinary action.