Since the foundation of the CCC Group over 65 years ago, Honesty, Integrity and Family Values have always been the backbone of our Code of Practice and the basis of our successful operations that led us to where we are today.
Living in this troubled world where human values and simple good principles are no longer the beliefs of many people around us, one must remember that neither short-term benefits nor following others can justify us from deviating from our main principles and beliefs. I want every single one of you to hold on to these three pillars while carrying out the responsibilities that you are entrusted to perform: Honesty, Integrity and Family Values.
Since we issued the first version of the Ethics and Anti-Corruption Program a few years ago, the world around us has changed and, in the spirit of continuous improvement, we have revised our procedures.
The Company’s Revised Ethics and Anti-Corruption Program is your guide for holding on to these Three Pillars in our operations. Your full commitment and compliance to this Ethics and Anti-Corruption Program are required to maintain our sustainability and development in this challenging world.
CCC Core Value: Commitment Towards Anti-Corruption
In late December 1999 and as CCC was heading towards its 50th anniversary, the late Said Khoury, one of the founders of CCC, ushered in the new millennium with the announcement that CCC’s unique corporate culture with distinct values and practices will be summarized in the form of a written booklet to be called “Core Values, Guiding Principles & Code of Practice” with the hope that this Code of Practice will fill all employees with pride in our company’s accomplishments founded on a commitment to these enduring values.
More importantly, this Code is intended to provide all employees with a sense of certainty about the rules by which CCC operates and about the ethical standards by which the performance of each member of the organization is judged. Above all, the Code contains recognizable time-tested human values that provide guidance in carrying out corporate activities.
Employees’ uncompromising compliance with this Code of Practice will be honored by Management with due recognition and respect.
CCC undertakes to fully distribute this code of practice among our employees and provide regular training on our ethics and anti-corruption and anti-bribery program and procedures, and inform about the ethical values and behavior everyone is expected to diligently follow throughout their employment.
CCC’s “Core Values, Guiding Principles & Code of Practice” booklet was revised in 2018 to include Whistleblowing Channels and is available in English and Arabic.
CCC Core Values, Guiding Principles & Code of Practice. (Download here)
Given that we are in the construction business on a global scale and operate in many countries around the world, it is essential for us to have a program in place to define anti-corruption and anti-bribery components of our compliance program. Our approved quality management procedure “Ethics and Anti-Corruption Program QMP-MOA-029” describes the main elements of the corporate anti-bribery and anti-corruption compliance program.
Consolidated Contractors Company CCC is committed to comply with the “FCPA: The US Foreign Corrupt Practices Act 1977”, “The Bribery Act: The UK’s Bribery Act 2010, which came into effect on 1 July 2011” and “The OECD Convention: The Organization for Economic Cooperation and Development’s Convention on Combating Bribery of Foreign Public Officials in International Business Transactions Convention, which came into effect in February 1999” in all business relationships.
CCC employees are forbidden from engaging in any corrupt activity in the performance of their duties and must maintain a complete and clear accounting of books and records.
CCC is a member of all of the important Ethics and Anti-Corruption International Organizations such as:
PACI has become the leading business voice on anti-corruption and transparency. It is one of the World Economic Forum’s strongest cross-industry collaborative efforts and is creating a highly visible, agenda-setting platform by working with business leaders, international organizations and governments to address corruption, transparency and emerging-market risks.
CCC is a Founding Member of this Pear Initiative, an independent, non-profit institution working to influence and improve corporate accountability and transparency in the Arab world. It was established in cooperation with the United Nations Office for Partnership and launched in December 2011. CCC became a founding partner of the Initiative in April 2011 and supports its goals and activities especially those that focus on implementing higher standards in areas such as corporate governance, anti-corruption, best practice and lessons learned in corporate social responsibility.
The UN Global Compact is a leadership platform for the development, implementation, and disclosure of responsible and sustainable corporate policies and practices. Launched in July 2000, the platform seeks to align business operations and strategies everywhere with ten universally accepted principles in the areas of human rights, labor, environment and anti-corruption. CCC became a signatory of the UN Global Compact (UNGC) on March 1, 2001 to streamline and align its business practices with the ten principles and report on them, as well as to build partnerships with various civil society organizations, and communities in developing corporate social responsible initiatives and projects that will improve the wellbeing of communities in which it operates.
CCC is a member of the Business Integrity Forum of Transparency International Greece.
Transperancy International’s mission is stop corruption and promote transparency, accountability and integrity at all levels and across all sectors of society. Our Core Values are: transparency, accountability, integrity, solidarity, courage, justice and democracy.
Based in London, C5 is recognized as the market leader by major corporates, leading private practice law firms and regulatory bodies across Europe, the Middle East and Asia. C5 Anti-Corruption Portfolio offers 10+ cutting edge events as well as innovative executive roundtables all across Europe.The events bring together key enforcement officials to talk about global trends and priorities, Chief Compliance Officers, General Counsel, Head of Internal Audit and Outside Counsel, Compliance Professionals, Representatives of International Organisations, Investigators, Financial Experts, and others to participate in a dialogue on cross-border issues and best practices in controlling anti-corruption risks and responding effectively when problems are identified.
Over and above regular internal audits and self-assessments, we also carry out regular audits by an International Independent Agent who regularly conduct detailed assessments of CCC’s areas of operations, ongoing projects and facilities, personnel and records, and investigate noncompliance with management procedures and report on our Ethics and Anti-Corruption Program.
CCC requires that all business transactions must be fully and accurately accounted for in our books and records, this is a mandatory legal requirement. Records and books of accounts of Operations must be maintained to accurately reflect each transaction recorded therein.
This is one of the most important ways in which corruption is prevented.
All Third Parties working with CCC must declare their commitment to CCC’s Ethics and Anti-Corruption Program prior to carrying out any work on any of our projects.
Third parties must declare that they have read and fully comprehend and commit their compliance and adherence to CCC’s Ethics and Anti-Corruption Program and undertake to ensure that they will take all necessary measures to support, implement and enforce the Ethics and Anti-Corruption Program and comply with the applicable anti-corruption laws of the country in which the project or operation is being carried out
A conflict of interest exists whenever an employee’s personal interests are inconsistent with and conflict with the interests of CCC. Employees must avoid any conflict between their CCC role and responsibilities and personal priorities.
Whilst employed at CCC, an employee’s principal allegiance must lie with CCC, and therefore an employee must not participate in activities outside of work that create a possible conflict of interest between an employee’s and CCC’s best interest.
A Compliance Team is established in all areas of operations including the UAE, Saudi Arabia, Qatar, Palestine, Oman, Lebanon, Kuwait, Jordan, Italy, Iraq, the CIS, and Africa.
The Compliance Team ensures adherence of all Areas of Operations and Projects to the corporate anti-bribery and anti-corruption compliance program.
“Ethics & Anti-Corruption” training courses are part of CCC Technical & Project Management Training program. CCC project management programs are approved by the Project Management Institute (PMI) and, upon completion, attendees earn Professional Development Units (PDUs) as CCC is a registered Global Registered Education Provider (REP) by PMI and an authentic certificate is issued.
CCC’s policy is to maximize online EACP training to reach the maximum number of employees in a relatively short period of time and this is due to; (1) the large number of employees (thousands) and (2) to having the employees spread around the world in many different countries and many different sites in any one country.
In 2015 “CCC’s Ethics Compliance Online Training Program” was launched to raise our staff’s EACP awareness in which more than 90% of CCC staff participated and successfully completed the course. CCC developed this program in coordination with an International specialist company in this field. The online course is a 60 minute online training session that provides an overview of the most important aspects of CCC’s Ethics & Anti-Corruption Program (EACP). Staff receive an individual e-mail providing a personalized link that takes the individual to an interactive Online Training Program. Participation is mandatory to all recipients and, upon successfully completing the program, a personalized authentic Certificate of Completion is issued. In early 2018, the online course was given again.
Whistleblowing is encouraged and reporting channels are advertised and displayed across CCC and is translated to all the main languages of the multinational workforce and the countries in which we operate. To ensure objective consideration of Whistleblowing reports, all reporting channels (online, email, mail or fax) fully protect anonymity of reporters.
Mail: Addressed to The President (Engineering & Construction), POB 61092, Amaroussion 15110, Athens, Greece.
CCC employees can and are encouraged to report any violation of our corporate policies, code of conduct or any observed bribery or corrupt activity. Fully confidential and anonymous whistleblowing channels are provided for reporting any suspected breach of our policies, and retaliation for reports of misconduct made in good faith is prohibited.