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We are committed to never compromising on this legacy and articulating it with all stakeholders, to continually improve our prominent Agro Feed business model by implementing robust Quality & Food Safety Management Systems.
DAL Food Leadership shall provide the required resources to continually improve the adopted Quality and Food Safety standards, and strives to achieve the following goals:
• Integrate Quality & Food Safety Standards into the backbone of business strategies, processes, and performance measures.
• Set and review measurable Quality & Food Safety objectives for all operations, in alignment with risks and opportunities within the context of DAL Food.
• Ensure compliance with, and wherever feasible, exceed mandatory statutory, regulatory, and international requirements.
• Foster an inclusive culture of ownership where employees feel valued and respected.
• Ensure that all employees are competent and appropriately trained to understand and carry out their roles towards Quality & Food Safety.
• Select business partners who embrace our commitments and demonstrate compliance with DAL Food, Quality & Food Safety Standards.

Ihab Daoud Abdellatif
Managing Director – DAL Food
November 2022

Data Protection Policy

INTRODUCTION

The Data and confidentiality Protection is handled and maintained in all aspects in accordance with the Constitution of the Republic Sudan which guarantees that all citizens are allowed freedom of communication and correspondence. Confidentiality is guaranteed and no communication or correspondence may be observed or recorded except as provided by law. In its Article 37 the Sudan Constitution provides for: “The privacy of all persons shall be inviolable; no person shall be subjected to interference with his/her private life, family, home or correspondence, save in accordance with the law”.

Data Protection Policy — Purpose Statement about the use of Personal Information

This policy outlines the guidelines for handling and the purposes for which we hold personal data about our employees, consultants, agents and others who work for us. As part of our Compliance Management System this Policy has been introduced to be part of our internal policies. The Personal Data is being dealt with subject to the constitution and the other relative enactments and legislation and should be kept and handled always subject to law, accordingly:

1. We will collect, hold and process information consisting of personal data including sensitive personal data about all our employees, applicants for employment, self-employed contractors, consultants, agency workers, and others who work for us, who are referred to in this policy as ‘Data Subjects’.
2. The purpose for which we hold any information about Data Subjects is solely for administrative and personnel management purposes.
3. The policy defines ‘Sensitive Personal Data’ as personal data consisting of but not limited to information as to nationality; religion; sex; age; date of birth; health condition; marital status; dependent details; qualifications; residential address; the commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed, including the disposal of such proceedings or the sentence of any court in such proceedings.
4. The purpose for which we hold Sensitive Personal Date about ‘Data Subjects’ is solely for monitoring equal opportunities, or the provision of specific services to individuals, including but not limited to: suitability and fitness for work, sick pay and sick leave, safe environment and obligations in respect of the employment equal opportunities.
5. We will establish and adhere to standard retention times for the various categories of information to be held on the records of workers and former workers and the retention times on business needs taking into account relevant professional guidelines. [Normally information about applicants for work and employees, including references and recruitments documents, will not be kept for longer than any period during which claims might be brought against us in connection with which the information may be needed.
6. The purpose for which we hold any information about ‘Data Subjects’ after the end of our contractual relationship is solely for meeting any residual contractual related matters including, but not limited to the provision of references, processing applications for re-engagement, matters relating to retirement benefits and allowing us to fulfill contractual or statutory obligations.
7. In addition to the above purposes, we may collect, hold and process data including Sensitive Personal Data if it is necessary to do so for the sake of compliance with any
8. If necessary for the above purposes we may transfer personal data to our subsidiary and associate companies, insurers, bankers, legal, medical and other professional advisers, administrators of Social Insurance and Pension scheme or pension provider and other companies to which we have contracted work relating to any of the above purposes for which the personal data are to be used. The transfer of personal data is always subject to confidentiality undertaking by recipients. Data may also be disclosed to others at employee’s or data owner request.
9. Subject to the extent Permitted by Law, we monitor electronic communications by our consultants and employees, within our Information Technology System including access to websites, to ensure that these systems are being used in accordance with our internet policies.
10. The Data Protection Policy and the relevant enactments set out eight enforceable principles of good practice, to which we will make all reasonable efforts to adhere. These principles are that the data must be: – Fairly and lawfully processed; – Processed for limited purposes and not in any manner incompatible with those purposes; – Adequate, relevant and not excessive; – Accurate; – Not kept for longer than is necessary; – Processed in accordance with individuals’ rights; – Secured; – Not transferred without adequate protection.
11. Each of our staff and to whom the data subject belongs shall have a right to request access to, and to request correction of, his personal data in relation to our employment agreement. Those who wish to exercise

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11. Each of our staff and to whom the data subject belongs shall have a right to request access to, and to request correction of, his personal data in relation to our employment agreement. Those who wish to exercise these rights can contact the Human Resources Manager who is the person accountable for Data Protection and Privacy.

Sanctioned and Approved by the Board of Directors this Day of 150 March 2017.

Osama Daoud Abdellatif.

Chairman of Board of Directors DAL Group.

INTRODUCTION

DAL GROUP, based on its mission and philosophy, has set a number of fundamental principles and values which it believes are the foundation of sound and fair business practise and as such are important to uphold. One such principle is a zero tolerance position in relation to corruption, wherever and in whatever form that may be encountered. This document is intended to build on our Ethics Policy and to clearly state the standards and principles required to ensure conformance to legal requirements within Sudan and the countries in which DAL GROUP operates.

LEGAL OBLIGATION

It is DAL GROUP policy to comply with all laws, rules and regulations governing anti bribery and corruption law, in Sudan and all the countries in which DAL GROUP or any of its subsidiary companies operate. We believe it is a fundamental principle of good business practice to respect local laws and customs when operating internationally. However, as Sudanese company, DAL GROUP is also bound by the laws of the Sudan, which governs our conduct both at home and abroad.

Under Sudan law, bribery and corruption is punishable for individuals, and if the company is found to have taken part in corruption it should face punishment. It can easily be seen why DAL GROUP takes its legal obligations in this area very seriously. Under Sudan law the payment, or offer to pay bribes, or provision of or offer to provide gifts or anything of value for improper purposes to obtain or retain business or any other benefit, is prohibited and punishable with imprisonment for a term not exceeding (2) years, in addition to fine and all cases the forfeiture of the property obtained by reason of the offence. Such payments or gifts are also forbidden under the terms of this policy and may result in immediate dismissal for those involved in their payment or receipt.

DAL GROUP is required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

POLICY

This policy applies to all DAL GROUP employees. Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for DAL GROUP or another party. Further guidance as to what is regarded by DAL GROUP as unethical (which includes corrupt) payments can be found in the Code Of Conduct and Gift Acceptance Policies in the HR Manager’s Policies& Procedures Manual.

No bribes of any sort may be paid to or accepted from customers, suppliers, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions.

This policy does not prohibit the following practices provided that they are customary in a particular market, or are proportionate and are properly recorded:

• Normal and appropriate hospitality (given or received)
• The giving of a ceremonial gift on a festival or at another special time

DAL GROUP recognises that market practice varies across the international arena in which it does business and what is normal and acceptable in one place may not be in another. DAL GROUP also appreciates that to refuse a gift in certain circumstances and/or countries would offend our trading partners. The test to be applied in all circumstances is whether the gift or entertainment is reasonable and justifiable. What is the intention of the gift? Special care must be taken in accepting or giving gifts/entertainment and these are not

DAL GROUP has an excellent reputation of conducting all of our business according to the highest principles of business ethics. We are proud of this reputation. We are committed to conducting our business activities with honesty, and in full compliance with the laws and regulations of Sudan and countries in which we do business. We also believe in treating our employees with the same principles.

The following Business Ethics Policy sets down the guidelines for business conduct at DAL GROUP. It is our firm intention that these standards and rules guide the actions of all Employees. We ask everyone to pledge his or her support to this important policy.

The Group’s full Business Ethics Policy can be found here

DAL Food is committed to the pursuit of excellence in Occupational Health, Safety and Environment in carrying out its business activities to create value to its stakeholders.  Thus, DAL Food OHSE policy is abide to:

• Comply with all applicable legal requirements of the Republic of Sudan, as well as to the requirements to which DAL Food industry subscribes, such as the International standards ISO 14001:2015 and ISO 45001:2018, as well as to the performance standards and OHSE guidelines for environmental and social sustainability of the International Finance Corporation (IFC), World Bank Group (WBG) and AfDB.
• Maintain an OHSE Management System that defines relevant responsibilities and accountabilities at management, employees and contractors’ levels.
• Identify and assess all work-related risks and environmental aspects and implement proactive measures to control such risks by using appropriate control measures.
• Mitigate potential risks from project design phase, through construction and operation phases of DAL Food facilities order to protects its employees, contractors and local communities, and minimize the impact to the environment through Environmental and Social Impact Assessment (ESIA) and the appropriate implementation.
• Consider the principles of sustainable development and sound environmental practices in planning and conducting its business, with emphasis to water and energy conservation programs and waste management.
• Developing OHSE competency for DAL Food employees through the promotion of OHSE trainings, awareness and encourage worker participation and consultation.
• Provide resources, adequate information, instructions and supervision for employees and contractors to proactively manage OHSE.
• Develop and implement a management plan to meet the minimum requirements of workers’ welfare facilities
• Review the systems, controls and processes at regular intervals to ensure OHSE compliance is maintained at all times.
• Ensure emergency preparedness at DAL Food facilities to deal with any emergency situation or crisis.
• Implement this policy through a comprehensive plan with measurable goals and objectives and with monitoring and analyzing performance against the plans.
• Remain committed to the continual improvement and updating of the above mentioned OHSE Management Systems and guidelines.

DAL Food expects that everyone within the Company recognizes their personal responsibility for upholding our OHSE values. DAL Food management will ensure that our employees, contractors and subcontractors fully understand this policy and are active in promoting OHSE culture.

The Group’s E&S Policy Statement can be found here.

Ihab Daoud,

Managing Director

December 2023