CEO’s STATEMENT
November 02, 2021

To our Stakeholders:
I am pleased to confirm that Gulf Catering Company for General Trade and Contracting, WLL reaffirms its support of the United Nations Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption.

During the past year, we, like nearly all global companies, have faced many challenges due to the COVID-19 epidemic. Rather than stepping back, we re-thought and retained our commitment to our people, customers, contractors and business model.

In this annual Communication on Progress, we describe our continued adherence to the principles of the Global Compact, our commitment to corporate citizenship and our achievements in furthering the 10 Principles in our business strategy, work culture and daily operations.

Despite global lockdowns, contract drawdowns, suspensions and challenges related to health and safety, we provided services, took care of our employees and the communities in which we work.

Our company operates in remote and challenging locations throughout the Middle East, Africa, Australia and Asia, serving a commercial and IGO client base.

We mitigate conflicting social and customary business practices through ISO training and audits, as well as on-line ethics training. Our 2021 cumulative position reflects the below certifications, awards and achievements:
 ISO 9001:2015 certification for UAE, Australia, Iraq and Uganda
 ISO 14001:2015 certification for UAE, Australia, Iraq and Uganda
 ISO 45001:2018 certification for UAE, Australia, Iraq and Uganda
 Successfully retained and upgraded all our ISO certifications – 26 ISO certifications globally.
 ISO 9001 :2015 Quality Management System
 ISO 14001:2015 Environment Management System
 ISO 22000:2018 Food Safety Management System
 ISO 45001:2018 Occupational Health and Safety Management System
 Successfully completed transition of ISO 9001 Quality Management System and ISO 14001 Environment Management System to 2015 version, and ISO 22000 Food Safety Management System and ISO 45001 Occupational Health and Safety Management System to 2018 version.
 ISO 22000:2018 certification for Cyprus, Iraq, Lebanon, Sudan/Darfur, and the UAE
 HACCP certification by Highfield, UK of 506 Sudanese staff members in Sudan/Darfur and Abyei
 Continued “Go Green” Environmental Recycling and Tree Planting Program in Africa and Iraq
 Handover of our “Go Green’’ Composting and Kitchen Garden in Abyei Sudan to UNISFA incoming contractor whereby we replaced imported fruits and vegetables carbon footprint with items grown on location and increased staff quality of life
 Award of the American Society for Safety Professionals HSE Excellence Award 2020– our 5th GOLD Award for Corporate Social Responsibility.
 Award of the American Society for Safety Professionals HSE Excellence Award 2020- our 8th GOLD Award for Facility and Maintenance
 Arab Organization for Corporate Social Responsibility – 4th Award in 2019. The 2020 program was cancelled due to COVId-19.
 TATWEEJ Awarding Body (UAE) Corporate Social Responsibility Award 2018 – our 3rd award
 UAE (TATWEEJ) 2019 ‘Golden Eagle’ Award for Leadership in CSR
 Establishment of corporate Construction Skills Training Program for Ghana and Cote D’Ivoire employees
 OTHERWAYS Green Award for Sustainability, July 2019
 British Safety Council International Safety Award April 2020
 British Safety Council International Safety Award April 2021, for the fourth consecutive year.

Annually, we select a CSR project that is proposed by our employees who take responsibility for the projects we support. To date, we have refurbished four schools in the Darfur region of Sudan. In 2020, we continued our CSR activity in Sudan/Darfur: renovating a girl’s school in El Fasher, Darfur and supporting families in Beirut impacted by the Port explosion.

And in 2020, we quickly responded to the explosion in the Port of Lebanon by contracting a local restaurant to prepare meals that we delivered to residents whose homes were damaged. We then contracted and donated new glass for windows and doors, kitchen appliances and furniture to help people recover.

We proudly present our latest achievement to our stakeholders. They represent the UNGC as action taken by our company, and our enduring commitment.

Rashad Sinokrot, CEO

UN GLOBAL COMPACT
Human Rights

Gulf Catering Company adheres to the United Nations Proclaimed International Human Rights. Our Ethics training, business practices and Corporate Social Responsibility Programs support and promote these rights.

Gulf Catering Company personnel are required to participate in Ethics and Compliance e-learning courses through Integrity International. Human Rights are a key component of the first module, Code of Business Ethics. The program is administered by Integrity International and allows us to reach our employees regardless of their physical location. Participation is conducted on an individual basis – and employees must pass an on-line examination to achieve certification. Statistical data is sent to our Human Resources Department on a monthly basis.

In 2020, a total of 486 Ethics Training Modules were successfully completed through Integrity International inclusive of: EEO and Workplace Conduct for Managers, Preventing Sexual Harassment, Code of Business Ethics, Human Rights, Global Mutual Respect, Combatting Bribery, Antitrust and Insider Trading. Represented were employees from Australia, Dubai, Abu Dhabi, Indonesia, Iraq, Lebanon, Sudan, Uganda and Cyprus. Courses are mandatory and completion is tracked electronically.

Training modules relating to Human Rights included:
 Protecting Human Rights in the Supply Chain
 Whistleblowing: Raising Concerns
 Fair Labor Practices Management Awareness
 Fair Labor Practices Awareness
 Combating Trafficking in Persons (CTiP) Train the Trainer
 Combating Trafficking in Persons (CTiP) Awareness
 Essentials of Leadership
 Fair Labor Train the Trainer
 GCCS Management Development Program (MDP)
 Litigation and Dispute Management in the Middle East: The Insider's View
 Compensation and Benefits Forum
 Code of Business Ethics

We also incorporate UN Global Compact awareness into our new employee orientation programs and annual training plan: using the 10 principles and our communication on progress as the program foundation. Our goal here is to ensure that UNGC is understood and practiced by all employees.

Gulf Catering Company has worked in challenging and remote locations throughout the Middle East, Africa, Australia and Asia since 2003. We currently employ 3,219 employees in 13 countries, representing 52 nationalities.

Many of our employees are from developing countries: representing a challenge in ensuring proper recruitment, hiring, work conditions and accommodation of staff members is adhered to at all levels of our organization. Our HR Manager personally conducts surveillance interviews with employees to ensure that they have been properly represented by legitimate agencies.

Our Australia operations are focused are signed agreements with indigenous tribes that ensure fixed entry-level positions for non-skilled community members. We guarantee job skills training as part of our community citizenship.

Our Ghana and Cote d’Ivoire construction projects included construction skills training and certificate issuance to local employees as a part of their employment with us. This allows the local construction team an advantage working on new projects in their country by proving their skills training completion.

In our Iraq operations we have 73% local hire employees. This number dropped somewhat since 2015 (75%) as oil companies scaled back projects as a result of the decrease in oil prices. Our Sudan Darfur operations represent 75% local hires and Abyei represents 74% local hires. In Lebanon, our UN Food rations contract represents 77% local employee content.

Article 26 of the United Nations Internationally Proclaimed Human Rights forms a key pillar of our Corporate Social Responsibility Program.

CSR Strategy
Our strategy is to move from ‘informing’ and ‘responding’ to ‘involving’ stakeholders in CSR communication itself. We are focusing on expanding the role of stakeholders in corporate CSR communication processes to build legitimacy, a positive reputation and lasting stakeholder relationships.

Our projects also create a type of Multiplier Effect, whereby one project or activity has multiple impacts.

Careful stakeholder mapping has been conducted by each of our business units. Stakeholders were identified and their level of impact assessed. From here, we engage stakeholders at all levels and develop CSR projects or participate in their projects. In doing do – a clear picture of what resources we have to offer and how we can make the best CSR impact emerges.

For example:
 We are involved in remote site construction – so we can help build, and protect the environment. We can also train local employees at an international level in both OSHAS and individual skills such as welding, carpentry, equipment operation, first aid etc.
 We are a catering and food procurement company – so we can provide food and influence human rights and labor practices of our suppliers
 We operate our employee camp kitchens in Abyei by composting kitchen waste from produce and use it to fertilize our camp kitchen gardens which have now become an oasis in the camp
 Our business requires an internationally trained team – so we can hire and train local employees
 Logistics is a key element of each of our projects – so we can extend these resources to support CSR initiatives by including items such as school supplies for local children on our transport vehicles
 We combine hands on participation of our staff members, education of children and protection of the environment in one project
 We support Emirates Environmental Group (WWF) beach cleanup in Dubai. The beach is a protected nesting ground of the Hawkbill Turtle. Our employees collect trash that has washed ashore from the Gulf, including fishing nets, plastics, wood, and debris that prevent the turtles from coming ashore and nesting.

Areas of CSR Engagement that leverage our core competencies include:
 People (human rights, labor)
 Environment (recycling, cleanup and tree planting)
 Society (education, aid and disaster relief, training)

People
Partnership’ captures the true spirit of our organization. In our relationships with clients, with each other, with suppliers and business partners, integrity is our foremost standard of conduct; we strive to treat all stakeholders with respect and dignity. We strive to find solutions by looking at the issues together.

Employees have the same rights regardless of where they are employed, and 100% compliance is mandated. Our UN and Oil & Gas clients assess KPIs that are incorporated into our own performance indicators. If there is a conflict, the more stringent regulation or guideline is applied.

Our direction:
 We will respect our people and encourage their development and training
 We aim to be a firm that is fully supportive of a diverse workforce including both gender and ethnicity. We will continue to promote equality and diversity and always consider the health and wellbeing and the work-life balance of our people
 We aim to empower our people; we will consult and provide two-way communication for all matters right across the firm
 We will recognize individual contributions and reward our people fairly
 We ensure that our labor force – and that of our suppliers does not exploit child labor
 We support Human Rights

Environment
Environmental, Social and Governance targets are mandated by our parent company, however operational implementation provides for the establishment of KPIs based on the countries in which we operate. KPIs must be in line with corporate/global guidelines, regardless of location.

Example: environmental protection applies even in Iraq and Darfur where no legislation is in effect. We still guard against soil contamination, recycle and reduce our footprint.
At the remote site-level we provide continuous tree planting in the UAE, Sudan and Iraq. We developed a remote site beautification program of planting to improve the appearance of our camps.

In the UAE we have a two-fold environmental approach: supporting the indigenous Ghaf tree that does not require extensive watering (depletion of water resources) and the targeted planting of trees, grass and plants at the schools attended by the children of our employees.

Recycling is promoted for paper, plastic water bottles and E-Waste. As our projects are all in remote areas with little attention paid to environmental issues, we set the standard and promote environmental protection to our local communities.

We are continuously review the feasibility of solar power to replace some aspects of generator power at our sites. Total replacement may not be possible, but we can light and power many parts of our camps and heat water using solar power.

Society
Social & Community Objectives (‘Giving Back to the Community’)

We are committed to the communities in which we live and work. We understand the impacts we create on the local community in the everyday running of our business.

Our direction:
 Continue Highfield Awarding body for Compliance of the UK HACCP Certified Training to all Local Nationals with an aim to provide important job skills and opportunities to employees in remote areas
 We will continue to encourage those employees who like to involve themselves in public and charitable service.
 We will continue to give our time and expertise for free to local community groups and voluntary organizations.
 We will aim to build long-term relationships with our suppliers and support small and local businesses.
 In our charitable giving we aim to work together with charities and create a partnership that is in tune with our business values.

We ensure one major project per year that we self-fund and self-perform.
Our 2020/21 projects include:
 Humanitarian aid to Beirut Port residents whose homes were damaged during the port explosion.
 Refurbishment of the Um Ayman Elementary School for 750 girls in EL Fasher, Dafur Sudan

BEIRUT PORT EXPLOSION AID TO FAMILIES
A key event during the pandemic led to accelerated CSR activity when, on 4 August, a massive explosion destroyed much of the Port area in Beirut. A large amount of ammonium nitrate stored at the port of the city of Beirut, the capital of Lebanon, exploded, causing at least 203 deaths, 6,500 injuries, and US$15 billion in property damages; leaving an estimated 300,000 people homeless in Lebanon –in the midst of an economic crises.

Beirut Port Explosion, August 4, 2020
Child’s Drawing of Life in Beirut, 2020
Objective:
Assist families in the Port Area that had lost their homes or suffered serve damage to their homes.
Description
GCC SERVICES contracted a local restaurant to prepare 250 daily meals per day for our volunteer team to deliver. We contracted a glass company to replace shattered windows to homes. Refrigerator and Cooking ranges were purchased and donated to families that had lost their kitchens and ability to prepare meals. A carpentry shop was engaged to utilize our shipping pallets to construct tables and cabinets for the damaged homes.

Food support packages were prepared and distributed to emergency responders.
 Port Family Support
 Daily meals prepared by a local restaurant and delivered to families in the port area
 100 food support boxes containing: 50 Kg salt, 25 Kg sugar, 25Kg lentils green, 25 Kg lentils red, 25 Kg Burghul brown fine, 25 Kg red beans, 750 L oil, 100 Kg rice and 12 boxes of kidney beans
 Glass and window repair of 42 houses
 Purchase and Distribution of Household Appliances – ovens, refrigerators, washing machine, televisions
 Purchase, fabrication of furniture: beds, tables, chairs
 100 Food Support boxes for Security Forces on site
 100 Food Support boxes for Lebanese military responders
 By contracting local businesses, we provided an economic multiplier effect to the community businesses by providing them with contracts and revenue generation.

Meals prepared for Port Residents and delivered by Volunteers

Homes Received new Glass Doors, windows, Furniture and Appliances
Beneficiaries
Residents of Beirut living near the port, Security and Military First Responders
Inception
August 4, 2020
Timeline
 Port explosion – August 4 2020
 Response Organization and Start Date: August 5, 2020
 Duration: 2 months
Key Milestones
 Emergency Meal Program Established
 Window and Door Glass replacement to damaged homes
 Purchase and Delivery of appliances, and furniture for households
 Food Package support to First Responders
Evaluation of the Program
Incredibly worthwhile hands-on program whereby direct impact was realized daily. All work was done by volunteers, without overhead costs. By using local businesses to prepare meals, purchase appliances and furniture, we further impacted the community by contributing to economic activity.

This model of local involvement closely follows the United Nations Business for Peace initiative, to which GCC SERVICES is committed.

DARFUR SUDAN GIRL’S ELEMENTARY SCHOOL REFURBISHMENT
Despite the impact of the COVID-19 Pandemic, areas such as Sudan’s Darfur region remain isolated in their needs and tend to be forgotten as travel bans, precautions and delays concern the rest of the world. GCC SERVICES moved ahead, albeit more cautiously and perhaps slowly as we searched for and agreed on a school to renovate.

Rather than ‘celebrating’ International Women’s Day, we decided to do something and give 750 girls a chance at an education and perhaps a better future.
Objective:
In honor of International Women’s Day, GCC SERVICES initiated a program to refurbish a 750-student girl’s elementary school in El Fasher, Darfur/Sudan.
Description:
Refurbishment of the Um Ayman Elementary School for girls in EL Fasher, Dafur Sudan. There are 750 students and 18 teachers at this school. The school will be the 4th school refurbished by GCC SERVICES in Sudan. Refurbishment is, essentially a rebuild as the school has no floors, desks, chairs, a poor ‘roof’, no drinking water, and no WCs.
Works completed in June 2021 for the school include:
 Add classrooms to the building
 Put in floors
 Plaster walls
 Add window shutters
 Manufacture steel desks and chairs (wood is eaten by termites)
 Install blackboards
 Install drinking water
 Install toilets
 Paint the facility
 Engage local employees
 Build partnership between local employees, communities and our company
 Ensure a sustainable contribution to the education of children
 Ensure that funds are well-spent
Beneficiaries:
 750 elementary school girls
 18 teachers
 El Fasher community members
 Sudan as it moves towards development of this conflict region
Inception:
The project was started in March 2021 and was completed in June 2021.
Timeline:
 November 2020 – February 2021 Identification of a school to refurbish/reconstruct by our Sudan Project Manager and Corporate leadership
 March 2021 Establish works to be done and contract local workers and suppliers
 Initiate desk and chair manufacturing locally
 March – April 2021 Start floors and roof works, drill well for water
 April-May 2021 Painting, and project completion

Key Milestones:
 Review schools in need
 Select a School
 Prepare a Budget and Work Plan
 Obtain Corporate Approval and Funding
 Contract local workers, builders and fabricators to ensure that funds stay in the community and are well spent. One worker is estimated to support 10 family members, so having paying work is critical to post conflict development
 Start Work
 School Completion
 School reopening (post Eid 2021) Community Event whereby the tribal chief presides over the event (Business for Peace model)

Evaluation of the Program:
As our 4th school in the Darfur region of Sudan, we have contributed significantly to our core CSR goals of education. Our hands-on model has proven to be very successful in that:
 Our entire team participates
 Communities see foreign companies as responsive and interested in their well-being
 Budgets are kept low
 Funds are managed by our in-region Project Managers, without administrative overheads
 Work is done completely by community members who are paid (bring income into their households
 The tribal structure in supported as its chief is viewed positively for bringing and supporting development
 Most importantly, students are provided an opportunity to learn, and teachers are provided with the facility and tools with which to do their work

Construction Trades Training
Our construction department is heavily focused on the building of warehousing facilities in the Ivory Coast and Ghana. In doing so, there is a need for local workers that, if positive, provides much-needed community income. International-level construction skills and knowledge of work-site safety are often not available. Rather than bring in ex-pat workers, we engage the local community. Employee candidate skills are assessed, and a development plan is created to teach and train them. Course participants gain knowledge, skills and enhance their work lives. Participants receive certificates for courses including:
• American Standard Medic First Aid Training (2-year validity)
• Steel Fixing
• Carpentry
• Plumbing
• Electrical Works
• Masonry
• Welding & Plumbing
• Driver Safety

Gulf Catering Company has adapted the Universal Declaration of Human Rights and US Government guidelines on Trafficking in Human Beings (TIPs).

We adhere to and exceed international regulations on Trafficking in Human Beings.
Our contract performance is constantly monitored and inspected by our auditors, clients and audit agencies. Likewise, our supplier audits extend the same surveillance: ensuring that we are not buying from suppliers who abuse human rights.

As a part of our recruitment and employee orientation training, new staff members are informed of their rights in their native language. Contracts defining salary and benefits are issued to each employee. Gulf Catering Company pays all recruitment fees, visa, airfare, travel, lodging and meals for our employees. We also pay all social taxes, provide paid holidays, bereavement leave, sick leave and pay indemnity to departing employees.

Employee orientation includes individual human rights and direct reporting access that is independent of direct line management. Daily training modules cover all aspects of job performance and a Trafficking in Persons (TIPS) module that reinforces employee human rights.

Labor Camps and Lodgings are routinely inspected to ensure that each employee receives a minimum of 55 square feet of personal space, adequate caloric intake, no cost medical care, a free monthly hygiene kit, and free laundry service. Employees are issued 6 complete sets of company uniforms, 2 pairs of safety shoes, winter weather clothing and job-related personal protective equipment (PPE). As required, body armor is provided for employees working in conflict zones such as Iraq.

All employees retain their own passports.

At our employee camps in Darfur and Abyei, employee rooms have beds, desks, refrigerator, TV and in-room bathrooms. All linens and hygiene items are provided by the company. Our laundry is operated onsite. Employee clothing and uniforms are cleaned and pressed at no cost to the employee. Meals are prepared on site in the facility kitchens and provided to employees at no cost.

Working hours are governed by the labor law of the country in which we are operating or our own corporate policy, with the more stringent policy being applied if compliance is unclear. Religious holidays and Ramadan hours are respected. Our camps also feature small mosques or prayers rooms. Midday meals are provided for local employees at no cost.

Employees in Iraq and Sudan are paid in compliance with local labor laws: ensuring that social taxes and allowances are a part of their salary package.

Gulf Catering Company has adapted a no-tolerance policy regarding violations of human rights. From direct line supervisors, to project managers, QHSE and corporate HR: all management personnel are held directly responsible for the welfare of employees. In 2018, there were no complaints alleging discrimination.

At our Dubai Headquarters, our CEO chairs a junior employee council meeting. All council members are non-management level and represent every department in the company. A target of 3 key improvement areas (whereby results are 70% positive or less) is taken from the company’s independently administered annual survey and serves as the council’s objective.

A daily newsletter was sent to all employees during the height of the pandemic: providing global WHO information and advice. Free vaccinations were offered to employees, their families and household employees.

A locked, CEO Mail Box is prominently placed so that every employee can voice issues, either directly or anonymously.

Additionally, all employees are provided with our parent company HOTLINE access.

Quarterly town hall meetings are conducted as an open forum with the CEO and HQ staff. These meetings were done by ZOOM conference calls in 2020 – 2021.

Gulf Catering Company is ISO 9001:2015, ISO 22000:2005, ISO 18001:2007 and ISO 14001:2015 certified. Our ISO audit systems ensure proper living and working conditions for our staff and subcontractors.

As transition to the new series of ISO 9001 and 14001 audits, we extended audit criteria to start first with leadership: querying them to ensure that they are aware of and practicing compliance.

The company successfully transitioned from ISO 18001 to ISO 45001 standards.

Our 2020 Employee Satisfaction Survey was completed by 79% of our Dubai staff members, despite many working from home due to COVID-19 outbreaks. Areas for improvement become the tasking of the employee council who focus on work life and Job satisfaction, and most importantly communications where many employees felt isolated.

We ensure one major project per year that we self-fund and self-perform.
Our 2020/21 projects include:
 Humanitarian aid to Beirut Port residents whose homes were damaged during the port explosion.
 Refurbishment of the Um Ayman Elementary School for 750 girls in EL Fasher, Dafur Sudan

BEIRUT PORT EXPLOSION AID TO FAMILIES
A key event during the pandemic led to accelerated CSR activity when, on 4 August, a massive explosion destroyed much of the Port area in Beirut. A large amount of ammonium nitrate stored at the port of the city of Beirut, the capital of Lebanon, exploded, causing at least 203 deaths, 6,500 injuries, and US$15 billion in property damages; leaving an estimated 300,000 people homeless in Lebanon –in the midst of an economic crises.

Beirut Port Explosion, August 4, 2020
Child’s Drawing of Life in Beirut, 2020

Objective:
Assist families in the Port Area that had lost their homes or suffered serve damage to their homes.

Description
GCC SERVICES contracted a local restaurant to prepare 250 daily meals per day for our volunteer team to deliver. We contracted a glass company to replace shattered windows to homes. Refrigerator and Cooking ranges were purchased and donated to families that had lost their kitchens and ability to prepare meals. A carpentry shop was engaged to utilize our shipping pallets to construct tables and cabinets for the damaged homes.

Food support packages were prepared and distributed to emergency responders.
 Port Family Support
 Daily meals prepared by a local restaurant and delivered to families in the port area
 100 food support boxes containing: 50 Kg salt, 25 Kg sugar, 25Kg lentils green, 25 Kg lentils red, 25 Kg Burghul brown fine, 25 Kg red beans, 750 L oil, 100 Kg rice and 12 boxes of kidney beans
 Glass and window repair of 42 houses
 Purchase and Distribution of Household Appliances – ovens, refrigerators, washing machine, televisions
 Purchase, fabrication of furniture: beds, tables, chairs
 100 Food Support boxes for Security Forces on site
 100 Food Support boxes for Lebanese military responders
 By contracting local businesses, we provided an economic multiplier effect to the community businesses by providing them with contracts and revenue generation.
 Meals prepared for Port Residents and delivered by Volunteers
 Homes Received new Glass Doors, windows, Furniture and Appliances

Beneficiaries
 Residents of Beirut living near the port, Security and Military First Responders

Inception

 August 4, 2020

Timeline
 Port explosion – August 4 2020
 Response Organization and Start Date: August 5, 2020
 Duration: 2 months

Key Milestones
 Emergency Meal Program Established
 Window and Door Glass replacement to damaged homes
 Purchase and Delivery of appliances, and furniture for households
 Food Package support to First Responders

Evaluation of the Program
Incredibly worthwhile hands-on program whereby direct impact was realized daily. All work was done by volunteers, without overhead costs. By using local businesses to prepare meals, purchase appliances and furniture, we further impacted the community by contributing to economic activity.

This model of local involvement closely follows the United Nations Business for Peace initiative, to which GCC SERVICES is committed.

DARFUR SUDAN GIRL’S ELEMENTARY SCHOOL REFURBISHMENT
Despite the impact of the COVID-19 Pandemic, areas such as Sudan’s Darfur region remain isolated in their needs and tend to be forgotten as travel bans, precautions and delays concern the rest of the world. GCC SERVICES moved ahead, albeit more cautiously and perhaps slowly as we searched for and agreed on a school to renovate.

Rather than ‘celebrating’ International Women’s Day, we decided to do something and give 750 girls a chance at an education and perhaps a better future.
Objective:
In honor of International Women’s Day, GCC SERVICES initiated a program to refurbish a 750-student girl’s elementary school in El Fasher, Darfur/Sudan.
Description:
Refurbishment of the Um Ayman Elementary School for girls in EL Fasher, Dafur Sudan. There are 750 students and 18 teachers at this school. The school will be the 4th school refurbished by GCC SERVICES in Sudan. Refurbishment is, essentially a rebuild as the school has no floors, desks, chairs, a poor ‘roof’, no drinking water, and no WCs.
Works completed in June 2021 for the school include:
 Add classrooms to the building
 Put in floors
 Plaster walls
 Add window shutters
 Manufacture steel desks and chairs (wood is eaten by termites)
 Install blackboards
 Install drinking water
 Install toilets
 Paint the facility
 Engage local employees
 Build partnership between local employees, communities and our company
 Ensure a sustainable contribution to the education of children
 Ensure that funds are well-spent
Beneficiaries:
 750 elementary school girls
 18 teachers
 El Fasher community members
 Sudan as it moves towards development of this conflict region
Inception:
The project was started in March 2021 and was completed in June 2021.
Timeline:
 November 2020 – February 2021 Identification of a school to refurbish/reconstruct by our Sudan Project Manager and Corporate leadership
 March 2021 Establish works to be done and contract local workers and suppliers
 Initiate desk and chair manufacturing locally
 March – April 2021 Start floors and roof works, drill well for water
 April-May 2021 Painting, and project completion

Key Milestones:
 Review schools in need
 Select a School
 Prepare a Budget and Work Plan
 Obtain Corporate Approval and Funding
 Contract local workers, builders and fabricators to ensure that funds stay in the community and are well spent. One worker is estimated to support 10 family members, so having paying work is critical to post conflict development
 Start Work
 School Completion
 School reopening (post Eid 2021) Community Event whereby the tribal chief presides over the event (Business for Peace model)

Evaluation of the Program:
As our 4th school in the Darfur region of Sudan, we have contributed significantly to our core CSR goals of education. Our hands-on model has proven to be very successful in that:
 Our entire team participates
 Communities see foreign companies as responsive and interested in their well-being
 Budgets are kept low
 Funds are managed by our in-region Project Managers, without administrative overheads
 Work is done completely by community members who are paid (bring income into their households
 The tribal structure in supported as its chief is viewed positively for bringing and supporting development
 Most importantly, students are provided an opportunity to learn, and teachers are provided with the facility and tools with which to do their work

Gulf Catering Company headquarters and management personnel are required to participate in mandatory Ethics and Compliance Courses through Integrity International. Employees participate electronically and are required to pass the course examination – the process of which ensures compliance and provides the foundation of our zero-tolerance policy regarding breach of conduct.

Courses from August 2020 – August 2021
Course Name No. of Completion
Privacy and Data Protection 23
Code of Business Ethics 9
UK & EU Competition Law 2
Global Data Protection 3
Code of Conduct: Best Practices 170
Antitrust: Careful Communication with Competitors 1
Whistleblowing: Raising Concerns 277
Global Competition Principles and Practices 15
International Anti-Bribery Principles 321
International Sanctions Made Simple 12
OFAC and Other Trade Restrictions 7
Integrity Leadership 249
TOTAL 1,089

Gulf Catering Company respects and protects the right of employees to freely associate and form collective bargaining groups as allowed by local labor laws in the countries in which we operate. We do not discriminate against employees involved in activities of association or collective bargaining.

While the majority of our work is performed in the Middle East, where labor organizations are not common, we do impose International Labor Organization guidelines within our organization. Such guideline compliance is mandatory through our contracts with governments, international agencies, NGOs and global corporations. Our Sudan employees have collective bargaining rights under local labor law.

Our Sudanese employees have labor councils and benefit from a very comprehensive government allowance system for local employees.

Our Global Employment Policy commits us to not tolerate any inhumane treatment of people working for us, including any form of forced labor, physical punishment or other abuse.

Work contracts clearly define employee entitlements, including salary and its payment date, vacation, indemnity and medical entitlements.

Gulf Catering Company promotes workplace equality and seeks to eliminate all forms of unfair discrimination. Equitable processes for recruitment, promotion and remuneration are in place, which ensure employment and promotion on the basis of job requirements and merit, and which support the establishment of a diverse workforce and ensure that all employees and employment applicants are treated equally irrespective of race, color, sex, sexual orientation, religion or belief, family circumstances, political opinion, age, nationality or disability.

Employee training is ongoing: allowing us to identify abilities and to promote from within the organization. It is not uncommon to find that employees who began with the company have risen to supervisory or management roles.

Gulf Catering Company became certified by Highfield Awarding Body for Compliance in the UK to conduct, test and certify HACCP training. A total of 8 QHSE Managers are certified Tutors through Highfield Awarding Body for Compliance. This allows a greater reach in training employees in Iraq and Africa – areas where training personnel are scarce. By adding Food Safety HACCP training and certification, we provide important job skills and opportunities to employees in remote areas.

To date we have trained and certified:
 Sudan Darfur – Level 1 Food Safety – 388 employees
 Sudan Abyei – Level 1 Food Safety – 118 employees
 Tyre, Lebanon – Level 1 Food Safety – 71 Employees
 Abu Dhabi - Basic Food Hygiene Training – 126 employees
 Abu Dhabi – Essential Food Safety Training – 164 employees
 Abu Dhabi - Level 2 Food Safety – 27 employees
 Abu Dhabi – Level 3 Food Safety – 14 employees
 Abu Dhabi – Level 4 Food Safety – 1 employee
 UAE Dubai corporate office – HSE Level 1 – 22 employees

Gulf Catering Company’s focus is on a safe and productive working environment for our employees. QHSE awareness and training are a daily part of our work environment.

Gulf Catering Company includes information on employee rights to associate and bargain in our employee orientation program and on-going training program. Employees elect their own representative to management on location and they receive direct QA/ QC corporate access.

We strongly believe that children belong in school. Gulf Catering Company carefully screens all employees prior to employment. We do not employ personnel under the age of 18, nor do we accept suppliers who employ children. Children are not allowed on site, both for their safety and to remove any doubt about their working.

In countries where the minimum employment age is higher than 18 years of age, we adhere to local laws.

Vendor Selection Process
By implementing ISO 9001 standards, all vendors are vetted prior to engaging in supply contracts. Vetting by our QHSE Team involves plant / facility inspection, verification of company registrations and licenses, ISO certifications, product traceability, and product manufacturing ingredient lists.

A comprehensive food product supplier inspection format has been designed specifically for our United Nations food rations contracts. Our Quality Control team visits all premises of food products of animal origin or key product lines before our procurement team issues purchase orders to a supplier company. Child labor presence is audited by examining employee records and visual observation of supplier factories and warehouses.

We also engage TUV Nord and SGS to conduct audits of manufacturing facilities. Identifying signs of labor abuse is key to our audit process. Employee records are reviewed, and visual inspections of working conditions are conducted to ensure compliance on the part of our suppliers.

In our UAE operations, compliance with government-approved accommodation units is required. Here, the government has stepped in to ensure that each employee has life support at a level in agreement with international standards on human rights. Facilities are continuously inspected by our Quality Assurance auditors and by government auditors. Inspections are frequently unannounced to ensure that a true picture is made.

As a company, 15% of our management team are females. This includes 1 Director, 3 Heads of Functions, and 15 Managers.

Our Sudan, Abyei, and Iraq teams are key example of workplace equality. While our primary work is comprised of warehousing – an area of work where only local males apply, many female community members are proudly earning wages in administrative and camp support services. Culturally, the women often segregate themselves from the males – but we have trained them together, and the women achieve HACCP certification along with the men. They continue to develop their skills and progress.

Gulf Catering Company includes information on employee rights to associate and bargain in our employee orientation program and on-going training program. Employees elect their own representative to management on location and they receive direct QA/ QC corporate access.

We have a a hotline at both our corporate and partner company level that are emphasized in all ethics, human rights and compliance training modules. This is prominently posted in our offices and communicated through each training module.

As we slowly move forward from COVID-19 lockdowns, we are working towards external audits of our operations and procedures, which are currently a part of our ISO 9001 certification audit in the HR Department.

As an ISO 14001 certified company, and with nearly all of our clients requiring environmental compliance, we align our business practices to ensure environmental sustainability. Many of our contracts are performed in countries where the environment is being contaminated, so ensuring that we do not contribute to this is a key factor in our operations. Our Environmental Management Plan went into effect in 2013.
The CEO has defined an Environmental Policy (QHSE Policy) that suits the purposes of GCC, including EMS Objectives, the commitment to meet contractual, legal and normative requirements, in order to ensure a continual improvement.
GCC is committed to providing the o highest quality of remote site, life support services to our customers, o provide safe food to our customers, acting to develop a sustainable food safety culture, o protect the natural environment where we operate and live, o caring for and protecting the health and safety of our employees, our customers, and the other communities in which we operate.

Gulf Catering Company received ISO 14001:2004 certification through Lloyd’s Register Quality Assurance on November 12, 2011. In December 2021, we became re-certified in the UAE under ISO 14001:2015. We undergo surveillance audits annually.

Gulf Catering Company implemented a ‘Go-Green’ program in 2011. Although small, we push the reduction of printing and use of paper, reduced use of plastics in our offices and in our commercial shops, and we recycle printer cartridges. We currently track all primary and secondary packaging to ensure maximum recycling potential.

Plastic water bottles have been eliminated and replaced by 25-liter water coolers. Plastics cups have been eliminated for the water coolers, with employees using their personal water thermos. We started this initiative by providing each employee with a personal thermos. Disposable coffee cups have also been eliminated.

In our Abyei cafeteria and PX UN service operations, we eliminated plastic bags and plastic disposable items: opting for recyclable alternatives.

Our corporate newsletter is now issued quarterly, but its’ focus remains on Health, Safety and Environmental topics. Environmental issues have covered Recycling, Reducing Paper Use, Tree-planting and Safety issues. Monthly safety bulletins are issued by our QA Department and QHSE reporting is including in each country’s monthly financial operations review.

Our country operations in Iraq, Uganda, Sudan and Abyei have each developed their own environmental programs, from recycling, to tree-planting and water conservation. In Sudan Darfur and Abyei, staff members have focused on planting of trees and kitchen gardens. Compost areas have been created for kitchen waste and the compost is then used to fertilize trees and the gardens.

Example: Abyei Kitchen Garden
Abyei Sustainable Kitchen Garden
GCC SERVICES’ United Nations food rations contract in Abyei, Sudan received recognition in 2015. Abyei is a demilitarized zone between Sudan and South Sudan. At the start of contract, conditions were harsh for our team: poor accommodation, lack of rest and relaxation amenities and a food supply that was trucked in from the Port of Sudan. Our camp chef lacked fresh herbs, vegetables and fruit. And our staff, who worked long days on duty rotations of 10 weeks in and 3 weeks out of Abyei, were challenged to keep morale up. With only mealtime to look forward to, our corporate team and the project manager came up with a unique solution: if the fresh herbs, vegetables and fruits were not available as desired – they would grow what they needed.

While this sounds as if it is a small ‘issue’, it reflects the development of a complete environmental eco-system.

Soil was not ideal, and required fertilization. Here the team created a composting area where kitchen waste from fruits and vegetables was placed in a pit and allowed to decompose. This recycling effort eliminated the need to place refuse in a dumpster for disposal, reducing the carbon footprint of waste removal trucks and incinerators, and enriched the soil for future use.

Seeds were needed, so the project manager Hassan Bittar, brought seeds back from Khartoum and Lebanon. Team members now do the same when they go home on R&R.

No pesticides are used, and the project is 100% ‘green.’
The Compost Bin – made from recycled materials - provides all needed fertilizer.

Growing started slowly with fresh herbs, some tomatoes and peppers. As items to be grown are identified by the chef and our employees, they are planted and grown. The GCC SERVICES kitchen garden is now a self-sustaining oasis. In 2021 it was turned over to the incoming contractor.

Our Construction and Life Support contracts involve both preventative actions and the incorporation of environmentally friendly / recycling initiatives. Examples include the safe processing of waste, fuel overspill basins, recycling of aluminum cans, metals and plastic water bottles, and the use of biodegradable catering materials.

Gulf Catering Company gives priority to ISO 14001 qualified suppliers.

When sourcing materials and supplies we require a Material Data Safety Sheet (MSDS) that we provide to our clients.

Environmental spills or contamination have an immediate reporting requirement. Refueling stations are equipped with spill kits, and fuel storage tanks are enclosed in concrete spill containers capable of holding 110% of the tank contents. Catering Operations feature special cooking oil collection areas and grease traps to prevent soil contamination.

Gulf Catering Company has developed waste management charts that include specific handling for each type of domestic and industrial waste including: batteries, tires, concrete, light bulbs, plastic, aluminum, spent brass, iron, glass, oil-soaked clothing and rags, paper, wood, kitchen waste, and chemicals. These charts are distributed to all of our work sites and to our clients.

Employees are furnished with appropriate Personal Protective Equipment such as overalls, gloves, eyeglasses, hearing protection, reflective vests and safety shoes to ensure that anyone coming into contact with Hazardous Materials (HAZMAT) is protected. Training is continuous for both recognizing and responding to environmental incidents.

Beginning in 2017 our CEO challenged each senior manager traveling from our Dubai HQ to mission sites to conduct a Safety Inspection as one of their Key Performance Indicators. Senior Managers and Directors were provided with an audit worksheet that included key environmental aspects including oil spills, garbage processing and greening of the sites. Findings are presented at management meetings and follow-up action is monitored. The result of this action was very positive, and has become a key performance indicator for all senior managers visiting sites.

GCC has had no legal cases, fines or rulings related to environmental violations.

Specific progress related to environmental protection include:
- Removal of all individual-size plastic water bottles in our remote site locations and HQ office
- Elimination of single-use plastic cutlery in our catering operations
- Elimination of plastic shopping bags in our PX operations
- Removal of polystyrene food boxes and their replacement with recyclable options
- Procurement of all office electronics with energy efficient star ratings
- Utilization of sea freight shippers who track, monitor and reduce their carbon footprint
- Identification and requirement of all food-relating packaging, and cartons to be of recyclable/bio-degradable materials
- Sorting and segregation of all camp waste
- Utilization of waste removal companies for camp sewage in compliance with national and global waste processing requirements

GCC Services undergoes ISO 14001:2015 surveillance and recertification by an external audit agency (Lloyd's Register Quality Assurance Ltd - LRQA). We have remained certified since 12 November 2011. The next audit will take place in 2023.

Recognizing the difficulties of employees and clients in the Middle East, Asia and Africa to understand international standards and practices, Gulf Catering Company’s parent company Agility published a comprehensive Code of Business Ethics and Conduct that apply to all group companies and our external relationships.

During the COVID-19 pandemic, employees were required to work from home. ZOOM conference calls replaced in-office training. The Internet-based training modules continued without interruption.

All headquarters and management personnel are required to complete Integrity International on-line, interactive training modules in:
 Antitrust
 Antitrust: Careful Communication with Competitors
 Code of Business Ethics
 Code of Conduct: Best Practices (mandatory)
 Combating Bribery in Business
 Conflicts of Interest
 EEO and Workplace Conduct for Managers
 FCPA Anti-Bribery
 Global Competition Principles and Practices
 Global Data Protection
 Global Mutual Respect
 Government Procurement
 Human Rights
 Insider Trading
 Integrity Leadership (mandatory)
 International Anti-Bribery Principles (mandatory)
 International Sanctions Made Simple
 OFAC and Other Trade Restrictions
 Preventing Sexual Harassment
 Privacy and Data Protection
 Protecting Human Rights in the Supply Chain
 Recognizing and Avoiding Bribery
 UK & EU Competition Law
 Whistleblowing: Raising Concerns (mandatory)

The training is conducted on-line using examples and situational analysis designed to develop understanding and model behavior. Participants must complete an imbedded examination designed to ensure understanding of good business practices. Course participation is mandatory. An electronic transcript of completion and certificate are generated for employee and corporate records.

The Anti-trust module focuses on advanced relationships in the business environment. In many cases, we had never thought of situations where our suppliers became our competitors, but in our current environment, with very large contracts at hand, but fewer contracts due to the oil crisis, this is becoming a very real business situation. We now explore the business activities of the companies who have previously been only our supplier.

A key example of this changed business environment manifested itself when an approved, and prominent industry supplier in the UAE was found to be adulterating spices with rice and maize powder to increase profits. Our company reacted by undertaking DNA sampling and then providing the results to the Ministry of Health to ensure that the company would provide no future products in the market.

To ensure that we equip our team members with more advanced business skills in the detection of food adulteration, we have organized a training module by EUROFINS Laboratory in Germany to impart observational skills in detecting food adulteration and a more concise understanding of the use of DNA testing.

Our corporate Code of Business Ethics and Conduct mirrors the UN Global Compact and specifically addresses Employee conflicts of interest, gifts, meals and entertainment in the course of interacting with clients, suppliers, subcontractors and competitors. Our work in emerging or conflict nations requires an understanding of how employees are to conduct themselves – knowing full well that such situations will arise.

The document further addresses business with third parties and anti-trust compliance including:
 Conducting Business with Suppliers, Vendors, Jobbers, Agents, Consultants, and Customers
 Conducting Business with Governments
 Antitrust Compliance
 Agreements among Competitors
 Monopolization

A new revision was issued in 2015, followed by an update in 2020 – both of which require extensive employee training. The updates include:
 Updated Corporate Alert Line numbers and contact information to report suspected violations
 Adjustments to the Gifts, Meals and Entertainment section highlighting the difference between acceptable hospitality and acts that can be considered bribes in different countries where we operate
 A revised anti-corruption section that reflects more stringent standards that were set by a number of anti-corruption laws, including some with broad-ranging extraterritorial reach. The revised anti-corruption section reflects what is “as a minimum” acceptable to our global customers as well as an increasing number of local customers.
 Our Corporate obligations towards unilateral and multilateral trade sanctions and our commitment to respect them while conducting our business

Employee orientation and training covers real life situations encountered by employees and provides explanatory responses that demonstrate compliance with corporate policy. A series of ‘What would you do if……’ scenarios provide guidance.

Gulf Catering Company has a zero tolerance anti-corruption policy. The first page of our corporate Code of Business Ethics and Conduct clearly specifies a hotline number for clarifications, employee concerns and reporting. All communications are considered privileged to ensure employee trust.

Gulf Catering Company and our parent company Agility Logistics are dedicated to our Code of Business Ethics and Conduct. We staunchly defend our record of performance and strive to ensure international compliance at corporate levels.

Our audit processes include internal and external audits. External audits include ISO 9001 compliance and Ernst & Young third-party financial audits