Compliance

Compliance with all applicable laws, regulations and policies is the foundation of MDX Technology Solutions ME (hereinafter “MDX”) operations and business conduct. MDX creation is a consequence of a management buyout of Fujitsu’s business in Middle East. As such MDX is very proud of the Fujitsu’ DNA, the high set ethical business standards and professionalism in the industry, and to ensure that we maintain this long tradition of excellence. We at MDX are committed to having our policies and procedures effectively communicated throughout our business units and understood by our Employees and Business Partners providing services for and on behalf of MDX.

MDX has inherited Code of Conducts, Ethics and Compliance policies from Fujitsu and our employees are part of Fujitsu’s compliance program which mandate various forms of training to the employees on continues basis. MDX will comply with all applicable laws and regulations applicable to its business as well as with Fujitsu’s Global Business Standards (see: http://www.fujitsu.com/global/about/philosophy/codeofconduct/gbs/ )

The Directors of MDX are fully aware of their responsibilities under the Fujitsu’s Global Business Standards, and especially the requirement to demonstrate that adequate procedures have been put in place to prevent acts of bribery or corruption.

MDX shows zero tolerance toward corruption, violations of fair competition laws and other breaches of law. But compliance means much more that just adhering to laws and to our policies and Code of Conduct. Compliance forms the basis for all our decisions and activities and it is the key to integrity when conducting our business.

MDX is committed to an ethical and responsible conduct in its business operations, which respects the rights of the individuals and the environment.

In addition, MDX Technology Solutions ME is committed to the principles of anti-bribery sustainability through identifying and addressing any aspects of bribery that may occur as a result of conducting its business.

We comply with community business practices when entering into deals and carefully check that our business terms and conditions are in line with local requirements. Therefore, in addition to complying with the laws and regulations of our local territory, we also follow and respect the laws, regulations and ethnic characteristics of other territories in which we do business.

This is achieved through:

• Leadership. Demonstrating commitment through personal example, controlling the introduction of ideas and supporting employees.
• Evaluation and Improvement. Monitoring, reviewing and improving the effectiveness of policies, standards and plans through trainings, drills and corrective actions.
• Preparedness. Tacking actions to anticipate the impacts of potential security and compliance risks through timely and effective assessments, and the development of prevention and response protocols.
• Awareness. Training and educating our employees on security and compliance risks and our associated protocols for situations that may be encountered while in a workplace, including interacting with the public.
• Controls. Planning and deploying controls to manage compliance risks, ranging from developing special processes and procedures.
• Incident report. Managing incidents following established, validated and well-through-out action plans.

MDX Technology Solutions ME and each of our employees conduct business in compliance with all laws and regulations, and we expect future business partners to honor and uphold the principle of loyalty in the performance of their duties.

Our aim is that compliance it’s not only a matter of the compliance function alone but of the whole organization. We have implemented three lines of defense to support an effective compliance methodology: the first line of defense (the sales and service delivery units) has the primary responsibility of managing compliance risks. The second line of defense (the compliance and supporting functions such as Finance, HR) has the responsibility of providing tools to manage risks and monitor compliance. The third line of defense (the audit function) has the responsibility of conducting independent testing to assess financial bookings. The analysis, oversight and direction is done by the GMB which meets quarterly so consolidate results and coordinate activities of the three lines of defense.

For any further clarifications or more information regarding MDX Technology Solutions ME Compliance process, please reach out to the Compliance Officer compliance@mdx-me.com and raise any concerns.

Policies and Code of Conduct

• Anti-Money Laundering /Combating Financing of Terrorism Policy. The intention of this policy is to outline the standards and regulations to be adhered by MDX Technology Solutions ME in relation to the prevention and control of money laundering, terrorist financing and proliferation financing (AML/CFT).
• Anti-Fraud, Bribery and Corruption Policy. MDX Technology Solutions ME has zero tolerance for any level of fraud-corruption-bribery. This document outlines company's policies and procedures for combating fraud and other forms of dishonesty.
• Compliance Manual. The primary purpose of this Manual is to assist staff to understand and comply with the policy, expectation, responsibilities, and requirement of MDX Technology Solutions Middle East company.
• Export Control and Trade sanction Policy. The policy sets forth the obligations of the company and its employees who engage in international business activities or have other responsibilities related to the distribution of the company's products or services to ensure compliance with all applicable trade laws and regulations.
• Whistleblowing Policy. The policy is designed to ensure that employees and stakeholders can report violations without fear of retaliation and to provide a transparent and confidential process for addressing violations.
• Code of Conduct. This Code of Conduct provides an overview of the principles and values based on which the company does business and how we expect each and every one of our employees and business partners to abide by and uphold its principle of dedication in carrying out their responsibilities.