Our Policies & Standards

Our businesses are expected to comply with the laws and regulatory requirements applicable to their location, sector, legal status, and activities in the Kurdistan Region of Iraq and, where relevant, federal Iraq and other jurisdictions in which they operate.

• Identify the competent authorities and requirements relevant to each project.
• Obtain and maintain required registrations, licenses, permits, approvals, and professional authorizations.
• Meet applicable tax, customs, employment, commercial, environmental, and reporting obligations.
• Keep accurate business records and respond appropriately to lawful inspections and official requests.
• Escalate suspected non-compliance and address identified issues promptly.

Requirements differ by activity. A company-wide policy does not replace a permit, a regulator's direction, or the legal review required for a specific project.

We aim to conduct business honestly and professionally, with transparent decisions and fair treatment of stakeholders.

• Prohibit bribery, improper payments, fraud, and dishonest business practices.
• Disclose actual or potential conflicts of interest.
• Use fair, documented processes for purchasing, contracting, and supplier selection.
• Protect confidential information and company property.
• Provide appropriate channels for raising concerns without retaliation for good-faith reporting.

Residential projects should be planned and delivered with attention to lawful land use, safe construction, service access, building quality, and the needs of residents.

• Verify land rights, project authorization, permitted use, and relevant planning approvals.
• Use qualified professionals for design, engineering, inspection, and construction where required.
• Follow approved plans and applicable building, fire, structural, electrical, water, and sanitation requirements.
• Maintain appropriate records of specifications, inspections, changes, and handover.
• Communicate clearly with buyers, residents, contractors, and relevant authorities.
• Address reported defects and safety concerns through documented review and resolution procedures.

Specific obligations depend on the location, project type, applicable permits, and the terms of relevant contracts.

Property-related activities should protect legitimate ownership and use rights, preserve asset condition, and support fair and transparent dealings.

• Review relevant title documents, leases, boundaries, and permissions before transactions or development.
• Use written agreements that clearly describe responsibilities, costs, services, and applicable terms.
• Maintain properties, shared spaces, utilities, and safety systems according to their use and applicable requirements.
• Keep records of maintenance, complaints, repairs, and material property-related decisions.
• Respect privacy and handle tenant, buyer, and customer information responsibly.
• Refer disputes and uncertain property rights for appropriate professional or legal review.

Healthcare-related supply activities should prioritize product integrity, traceability, safe handling, and compliance with the rules governing the products and services involved.

• Verify supplier qualifications and the required registration, authorization, or approval for relevant products.
• Source products through legitimate supply chains and retain appropriate invoices and documentation.
• Check packaging integrity, product identity, lot or batch details, and expiry information where applicable.
• Maintain required storage, transport, temperature, and handling conditions for sensitive supplies.
• Separate damaged, expired, suspect, or recalled products from usable inventory and follow appropriate reporting and return procedures.
• Protect customer and patient-related information encountered during authorized work.

Medical devices, medicines, and other healthcare products may be subject to different licensing and regulatory controls. The relevant requirements must be confirmed for each product category.

GIA and other group companies should operate within their own registered business activities, delegated authority, contractual commitments, and applicable regulatory obligations.

• Maintain current company registration, ownership, licensing, and corporate records as required.
• Define decision-making authority, approval limits, and responsibility for financial and operational commitments.
• Use documented contracts and appropriate due diligence for suppliers, partners, and customers.
• Keep accurate financial, purchasing, inventory, and operational records.
• Identify sector-specific permits, technical qualifications, and reporting duties before beginning new activities.
• Report material operational, financial, compliance, and safety risks through the appropriate management channels.

This section is a general governance framework. GIA-specific obligations should be confirmed against its registered activities, licenses, and approved internal procedures.

Construction work should be planned, supervised, and delivered according to approved project documents, applicable technical requirements, and relevant safety and environmental controls.

• Confirm planning, building, land-use, and other required approvals before work begins.
• Use appropriate drawings, engineering assessments, specifications, and qualified technical personnel.
• Inspect construction materials and workmanship against project specifications and applicable standards.
• Maintain site safety arrangements, equipment checks, worker protection, and incident reporting.
• Manage dust, noise, waste, drainage, and other environmental impacts in accordance with applicable requirements.
• Document inspections, design changes, defects, corrective actions, and project handover.

Technical requirements and approval processes vary by project type, scale, location, and the authority responsible for the work.

Industrial operations should prioritize consistent product quality, worker safety, responsible resource use, and lawful production and distribution.

• Obtain relevant industrial, operational, environmental, and other required approvals.
• Set product specifications and conduct suitable checks on incoming materials and finished goods.
• Maintain machinery, equipment, ventilation, and other safety-critical systems.
• Manage raw materials, stock, production records, and product traceability as appropriate.
• Handle waste, emissions, wastewater, and potentially hazardous substances according to applicable controls.
• Investigate product-quality concerns and document corrective action.

Any proposed geological, quarrying, mineral, land-development, or resource-related investment must be assessed according to the actual activity and the permissions required for that activity.

• Confirm land access, land rights, boundaries, and any restrictions before fieldwork.
• Determine whether exploration, sampling, drilling, extraction, or related activities require separate licenses or authorizations.
• Engage suitably qualified geologists, engineers, surveyors, and other specialists as required.
• Prepare suitable site assessments, technical reports, risk assessments, and environmental studies where applicable.
• Assess worker safety, water use, waste, land disturbance, restoration, and impacts on nearby communities.
• Secure the necessary written approvals before starting any regulated field activity.
• Maintain reliable field data and submit reports required by the competent authorities.

Land ownership or an investment approval does not necessarily authorize every form of geological exploration or resource extraction. The relevant authorities and licensing pathway must be confirmed before proceeding.

Investment decisions should be supported by credible information, sound commercial reasoning, risk assessment, and appropriate approvals.

• Assess feasibility, capital needs, expected returns, operational risks, and environmental or community impacts.
• Review partner identity, authority, relevant experience, and legal capacity to enter into agreements.
• Confirm the appropriate investment registration, licensing, land allocation, or sector approval route.
• Use clear written agreements defining ownership, contributions, responsibilities, and dispute procedures.
• Document approval decisions and monitor performance against agreed objectives.
• Obtain qualified legal, financial, engineering, and technical advice where needed.

We aim to provide a professional workplace that respects employees, supports fair treatment, and encourages responsibility and cooperation.

• Use clear employment terms and comply with applicable employment, wage, working-time, leave, and social-security requirements.
• Promote fair treatment and prohibit harassment, bullying, discrimination, and retaliation for good-faith reporting.
• Maintain appropriate recruitment, onboarding, attendance, performance, and training records.
• Provide role-appropriate training, supervision, and information about workplace responsibilities.
• Protect personal and employment information and limit access to authorized purposes.
• Provide a suitable process for raising grievances and investigating workplace concerns fairly.
• Apply disciplinary procedures consistently and in accordance with applicable law and approved company rules.

These principles do not replace applicable labor legislation, employment contracts, or any binding collective or regulatory requirements.

Employees, contractors, visitors, and project partners should follow the safety procedures relevant to the location and activity. Work should not proceed where a serious uncontrolled hazard makes it unsafe.

• Identify hazards and assess risks before starting work and when conditions change.
• Provide appropriate personal protective equipment, instruction, and supervision.
• Inspect tools, machinery, vehicles, work areas, and safety equipment at suitable intervals.
• Establish appropriate emergency procedures, evacuation arrangements, and incident reporting.
• Manage high-risk tasks through suitable permits, competent supervision, and risk controls where required.
• Record incidents and near misses and implement corrective actions.

Renewable-energy projects should be designed and installed with attention to electrical safety, equipment suitability, reliable performance, and relevant approval requirements.

• Assess the site, system capacity, structural suitability, electrical demand, and installation risks.
• Use appropriately qualified installers and suitable equipment for the project.
• Follow applicable electrical, fire, structural, grid-connection, and inspection requirements.
• Provide safe installation, commissioning, maintenance, and shutdown procedures.
• Explain system operation, limitations, and maintenance needs to the customer or property owner.
• Handle damaged panels, batteries, electrical components, and end-of-life equipment responsibly.

Technology and digital communications should be used responsibly, securely, and in accordance with the rights of customers, business partners, employees, and content owners.

• Use authorized access to company systems, devices, accounts, and business data.
• Apply suitable access controls, backups, software updates, and incident-response measures.
• Collect and use personal information only for appropriate, authorized purposes and handle it securely.
• Ensure marketing claims are accurate, appropriately supported, and not misleading.
• Respect intellectual property, permissions, and applicable advertising and communications rules.
• Escalate suspected data breaches, unauthorized access, and other security incidents promptly.

We aim to consider environmental impacts in project planning and operations, especially where construction, manufacturing, energy, or resource-related activities may affect land, water, air, or nearby communities.

• Identify applicable environmental approvals and assessment requirements before work begins.
• Manage waste, dust, noise, wastewater, fuel, chemicals, and other environmental risks appropriately.
• Use water, energy, and raw materials responsibly where practical.
• Prevent avoidable spills, pollution, and unauthorized disposal.
• Maintain environmental records and implement corrective measures when issues are identified.
• Follow any required site rehabilitation, monitoring, and reporting conditions.

Procurement should support quality, value, reliability, and transparent business relationships.

• Define the scope, specifications, quantities, and acceptance criteria before purchasing.
• Evaluate suppliers against relevant capability, quality, price, delivery, and compliance criteria.
• Use authorized approvals and written purchase orders or contracts where appropriate.
• Check deliveries against orders and document defects, shortages, or discrepancies.
• Monitor contractor qualifications, site rules, and safety obligations relevant to their work.
• Maintain records that support traceability, accountability, and financial review.