Governance
ETHICS AND GOOD GOVERNANCE
CONFLICTS OF INTEREST
ANTI-CORRUPTION
An integral aspect of our governance strategy is the robust anti-corruption measures in place outlined in APIC Group’s Anti-Corruption Policy which is communicated to all our employees, in addition to providing training on ethics and corruption prevention to our employees. Our ongoing commitment to transparency involves a systematic assessment of all operations for potential corruption risks, and all board members have formally endorsed the Anti-Corruption Policy, demonstrating APIC’s unwavering commitment.
APIC Group’s Anti-Corruption Policy and Compliance Training
In 2023, APIC Group developed and embedded a robust Anti-Corruption Policy as a cornerstone of its commitment to ethical business practices. This policy reflects APIC Group’s unwavering stance against all forms of corruption, including bribery, extortion, fraud, and other related illegal or unethical activities that could tarnish its reputation or compromise its integrity.
The policy mandates zero tolerance for corruption and applies to all employees, directors, officers, and stakeholders, including suppliers, contractors, and business partners.
Key components of APIC Group’s Anti-Corruption Policy include:
Clear Definitions: The policy begins by clearly defining what constitutes corrupt practices, ensuring that all individuals associated with APIC Group are fully aware of the behaviours and actions that are prohibited.
Reporting Mechanisms: APIC Group encourages a culture of openness and transparency where employees feel safe to report any suspicions of corruption. The policy details the reporting mechanisms available to employees, including the Whistleblowing Platform, to report potential violations without fear of retaliation.
Monitoring and Compliance: The Anti-Corruption Policy establishes strict risk assessment, monitoring, and compliance measures. Regular audits are conducted to ensure adherence to the policy, and any breaches are met with prompt and appropriate disciplinary actions.
Leadership Accountability: APIC Group’s leadership takes responsibility for implementing and upholding the Anti-Corruption Policy. Senior management is actively involved in promoting an ethical culture and ensuring that the policy is integrated into all levels of the organization.
The policy was circulated to all staff, ensuring that every employee, regardless of their position or tenure, has access to and understands the firm’s stance against corruption.
Also in 2023, APIC Group incorporated virtual training on Anti-Corruption that is mandatory for all employees. This training is part of the company’s wider compliance training curriculum and is designed to be interactive, engaging, and informative, enabling employees to recognize potential corruption-related scenarios and respond appropriately.
BOARD OF DIRECTORS CHARTER
REPORTING
SPEAK-UP CULTURE
APIC Group promotes a speak-up culture so employees can share their ideas, opinions, and concerns. We have an internal communication channel and conduct periodic employee well-being surveys. We also provide confidential mental health guidance to employees which helps them navigate and resolve difficult situations, in addition to our Whistleblowing platform, which allows employees to directly access the highest levels of the company in case there are any issues, all are part of our people-centric approach.
APIC Group provides an environment where employees can report concerns without fear of reprisal, all claims are investigated in a timely manner, and have the option to remain anonymous. A clear Whistleblowing Policy is communicated to all employees and the Whistleblowing Platform can be accessed here.
RISK MANAGEMENT
APIC Group conducts group wide risk assessments every three years, which now includes environmental, social and governance aspects such as evaluating potential environmental impact, assessing social responsibility, and scrutinizing governance practices across its diverse portfolio of investments.
SUSTAINABILITY
MATERIALITY
In the year 2023, the Board of Directors and Executive Management, fortified by the expertise of an external consultancy firm based in the UK, engaged in a comprehensive review process. This encompassed a meticulous examination of accumulated company data, invaluable insights garnered from stakeholders, and an extensive analysis of prevailing industry practices. Collaboratively, the Board actively participated in a materiality exercise, a strategic process aimed at discerning and prioritising key issues and focus areas crucial for attaining sustainability objectives in the short to medium term. This rigorous assessment, guided by external expertise, not only facilitated a deeper understanding of the multifaceted challenges and opportunities within the business landscape but also laid the groundwork for informed decision-making in steering the company toward a more sustainable and responsible future. The incorporation of diverse perspectives and industry benchmarks through this collaborative effort underlines the commitment to a holistic and forward-thinking approach in advancing the company’s sustainability agenda.
Ethical business conduct
Revise policies to include ESG commitments
.
Development of Value Chains and responsible sourcing
.
Development of Board of Directors Charter including Conflict of Interest Policy
Economic Performance
Risk assessments include ESG
Customer Privacy
Develop Data Privacy Policy
Ethical business conduct
Revise policies to include ESG commitments
.
Development of Value Chains and responsible sourcing
.
Development of Board of Directors Charter including Conflict of Interest Policy
Economic Performance
Risk assessments include ESG
Customer Privacy
Develop Data Privacy Policy
Diversity and equal opportunities
Increase women›s employment to 30% by 2030
Health and Safety
Conduct regular air quality testing
Marketing and Labeling
Develop Marketing and Labeling Policy
Investing in Local Communities
Community Needs Assessment
Stakeholder Engagement
ESG Communication Plan
Diversity and equal opportunities
Increase women›s employment to 30% by 2030
Health and Safety
Conduct regular air quality testing
Marketing and Labeling
Develop Marketing and Labeling Policy
Investing in Local Communities
Community Needs Assessment
Stakeholder Engagement
ESG Communication Plan
Emissions
Collect data on emissions (scope 1, 2, and 3)
Water
Increase water efficiency
Waste
Hazardous waste generation e.g. electronics
Non-hazardous waste generation e.g., food and domestic waste
Energy
Increase investment in solar powered energy
Emissions
Collect data on emissions (scope 1, 2, and 3)
Water
Increase water efficiency
Waste
Hazardous waste generation e.g. electronics
Non-hazardous waste generation e.g., food and domestic waste
Energy
Increase investment in solar powered energy
Ethical business conduct
Revise policies to include ESG commitments
.
Development of Value Chains and responsible sourcing
.
Development of Board of Directors Charter including Conflict of Interest Policy
Economic Performance
Risk assessments include ESG
Customer Privacy
Develop Data Privacy Policy
Ethical business conduct
Revise policies to include ESG commitments
.
Development of Value Chains and responsible sourcing
.
Development of Board of Directors Charter including Conflict of Interest Policy
Economic Performance
Risk assessments include ESG
Customer Privacy
Develop Data Privacy Policy
Diversity and equal opportunities
Increase women›s employment to 30% by 2030
Health and Safety
Conduct regular air quality testing
Marketing and Labeling
Develop Marketing and Labeling Policy
Investing in Local Communities
Community Needs Assessment
Stakeholder Engagement
ESG Communication Plan
Diversity and equal opportunities
Increase women›s employment to 30% by 2030
Health and Safety
Conduct regular air quality testing
Marketing and Labeling
Develop Marketing and Labeling Policy
Investing in Local Communities
Community Needs Assessment
Stakeholder Engagement
ESG Communication Plan
Emissions
Collect data on emissions (scope 1, 2, and 3)
Water
Increase water efficiency
Waste
Hazardous waste generation e.g. electronics
Non-hazardous waste generation e.g., food and domestic waste
Energy
Increase investment in solar powered energy
Emissions
Collect data on emissions (scope 1, 2, and 3)
Water
Increase water efficiency
Waste
Hazardous waste generation e.g. electronics
Non-hazardous waste generation e.g., food and domestic waste
Energy
Increase investment in solar powered energy
POLICY COMMITMENTS
PROCESSES TO REMEDIATE NEGATIVE IMPACTS
In situations where adverse effects or negative impacts are identified within our operations, our commitment to responsible business practices is underscored by the implementation of structured and proactive processes. These processes are meticulously designed to swiftly and effectively address and remediate any identified issues. Central to this approach is a robust system that enables the
prompt identification and reporting of negative impacts, whether they pertain to environmental concerns, social consequences, or governance shortcomings.
Upon the identification of such impacts, a systematic and transparent escalation process is activated, involving key stakeholders and decision-makers at various levels of the organization. This ensures that a comprehensive understanding of the issue is achieved, taking into account diverse perspectives and insights. Simultaneously, a dedicated remediation plan is crafted, outlining specific actions, timelines, and responsibilities to rectify the identified shortcomings.
Importantly, these processes are not just reactive but are complemented by a commitment to proactive measures aimed at preventing the recurrence of similar issues in the future. Root cause analyses, continuous improvement initiatives, and regular reviews contribute to a dynamic and evolving framework that adapts to emerging challenges and sustains a culture of accountability.
By embedding structured processes for addressing and remediating negative impacts, we exemplify our dedication to not only meeting regulatory requirements but also surpassing them to ensure the sustained well-being of our stakeholders and the broader community. This proactive and diligent approach aligns with our overarching commitment to responsible and sustainable business practices, affirming our role as a conscientious corporate entity within the ever-evolving landscape of environmental, social, and governance considerations.
Siniora Food Industries Company Palestine Compliance Platform
Siniora Food Industries Company in Palestine has recently implemented an innovative automated system designed to monitor and address complaints related to marketing and quality. This sophisticated system facilitates the tracking of complaints originating from diverse sources, including direct contact from complainants, input from agents, and all social media channels. These complaints are seamlessly integrated into the system, directing them to the relevant departments for thorough investigation and the implementation of necessary corrective and preventive actions to avert their recurrence. The system ensures that all complaints, along with their corresponding investigations, are meticulously stored, enabling statistical analysis of complaint trends over time. Management has continuous access to this comprehensive repository, offering a valuable resource for reference at any time.
The effectiveness of this system is evident in its streamlined follow-up process, the ability to measure performance, and the promising prospect of reducing complaint numbers. By addressing issues at their root, the system contributes to problem resolution and the prevention of recurring incidents. It also serves as a checkpoint to ensure the completion of processes.
Noteworthy advantages and benefits of the system include the capability to upload pictures and videos, traceable complaint numbers, automatic reminders, performance management, robust reporting functionalities, streamlined follow-up procedures, reduced paperwork, mobile accessibility, all-time statistics accessible to managers, performance and ticket tracking, seamless integration of multiple departments with a single click, easy communication between teams, assurance that no complaint is overlooked or left unresolved, continuous monitoring of sales and quality team performance, user-friendly interface, audit management, process streamlining with a standardized version of information for all teams, identification of opportunities for process and product/service improvements, and the convenience of email alerts. The implementation of this system represents a significant step forward in enhancing efficiency, transparency, and overall operational effectiveness within Siniora Food Industries Company.
MANAGEMENT CONTROL PRACTICES
Through the meticulous execution of internal audits, compliance departments, external audits, and performance appraisals, we position our company as a trailblazer in sustainable and accountable governance within the business sector. This commitment reflects our pledge to not only meet but exceed the expectations of our stakeholders, contributing to a corporate landscape defined by integrity and responsible leadership.
Compliance Departments – Compliance with Laws and Regulations
Integral to our governance structure is the presence of dedicated compliance departments, strategically positioned to uphold the company’s commitment to adhering to all relevant laws and regulations. These specialized departments actively cultivate a culture of legal and ethical compliance, implementing rigorous measures to stay abreast of evolving regulatory landscapes and fostering an environment where ethical conduct is not only encouraged but ingrained in our corporate DNA.
Internal Auditing
Our commitment to maintaining the highest standards of governance is reinforced by the regular conduct of internal audits, a vital practice designed to meticulously assess and enhance the effectiveness of our governance mechanisms. The Company’s internal audit follows the international standards of the Institute of Internal Auditors (IIA) and utilises leading global accounting firms. These internal audits serve as a proactive measure to identify areas of improvement, fortifying our organizational resilience and ensuring that our governance practices consistently align with industry best practices.
External Auditing
As a testament to our unwavering dedication to transparency, independent external audits constitute a pivotal element of our governance practices. These audits, conducted by leading global accounting firms, serve as a robust validation process, thoroughly scrutinizing our financial reporting and governance practices. This external validation not only instils confidence among stakeholders but also underscores our commitment to accountability and the highest standards of financial governance.
Performance Appraisals
In tandem with our governance practices, our management control measures encompass comprehensive performance appraisals. These evaluations serve as a dynamic tool, aligning individual and team objectives with the company’s ethical and governance standards. By intertwining performance assessments with our overarching commitment to ethical conduct, we ensure that our workforce is not only skilled and proficient but also aligned with the ethical principles that define our corporate identity.
