Cactus (“the Company”) is committed to upholding and promoting the fundamental principles of human rights in all its operations, business relationships, and activities. As a responsible corporate entity operating in the United Arab Emirates, we recognize our duty to respect, protect, and advance the rights of all individuals associated with our business—employees, subcontractors, suppliers, and communities alike.
Commitment to Human Rights
The Company’s human rights policy is rooted in international standards, including the Universal Declaration of Human Rights, the International Labour Organization (ILO) Core Conventions, and relevant national labor laws and regulations. We strive to ensure that our practices are aligned with ethical, transparent, and fair labor and employment standards
Equal Opportunity and Non-Discrimination
We are dedicated to providing a workplace free from discrimination, harassment, and bias. Employment decisions are based solely on qualifications, skills, experience, and business needs. Discrimination based on nationality, race, color, gender, religion, age, disability, marital status, or any other protected characteristic is strictly prohibited.
Prohibition of Forced and Child Labor
We strictly prohibit all forms of forced, bonded, or involuntary labor, and do not tolerate child labor under any circumstances. All employees must be engaged willingly, and employment shall be based on documented contracts in accordance with applicable labor laws and regulations.
Working Conditions and Welfare
The Company is committed to providing safe, healthy, and respectful working conditions. This includes access to clean and secure accommodation (if provided), safe transportation, clean drinking water, sanitary facilities, appropriate rest periods, and a work environment free from physical or
psychological abuse or coercion.
Freedom of Association and Collective Bargaining
We respect the right of employees to freely associate, join or not join labor unions, and engage in collective bargaining, as permitted by local laws and regulations.
Fair Wages and Working Hours
The Company ensures that all workers are paid fair wages that comply with or exceed the minimum wage requirements set by UAE labor law. Working hours, including overtime, are in accordance with statutory limits, and all employees are entitled to rest days and leave entitlements as prescribed by law.
Grievance Mechanism
We maintain a transparent and accessible grievance redressal mechanism that allows employees and other stakeholders to raise concerns related to human rights, labor practices, and ethical conduct without fear of retaliation. All complaints are treated with confidentiality and addressed promptly and effectively.
Subcontractor and Supplier Responsibility
We expect all subcontractors, suppliers, and service providers to uphold the same high standards of human rights. The Company actively communicates its expectations and may conduct assessments to ensure compliance with this policy.
Training and Awareness
The Company provides regular training and awareness programs to ensure that all employees and relevant stakeholders understand their rights and responsibilities with respect to human rights and ethical practices.
Monitoring and Continuous Improvement
CACTUS MEGA BUILDING & CONSTRUCTIONS PROJECTS SOLE PROPRIETORSHIP L.L.C is committed to the continuous evaluation and improvement of its human rights practices. We regularly review our policies, procedures, and operations to ensure alignment with evolving laws, standards, and stakeholder expectations.
Policy Governance
This policy is approved by the Company’s management and applies to all employees, subcontractors, and partners engaged in our operations. It shall be made available to all stakeholders and reviewed annually or as necessary to ensure its continued relevance and effectiveness.
Policy Statement
We are committed to maintaining a work environment in which all individuals are treated with respect and dignity. We strictly prohibit any form of discrimination or unequal treatment based on race, color, sex, gender identity, age, religion, political opinion, national origin, social background, marital status, physical or mental disability, sexual orientation, or any other status protected by applicable laws or international conventions.
Scope
This policy applies to all employees, contractors, suppliers, consultants, and other stakeholders associated with the Company, across all locations and business operations.
Management Approach and Measures
The Company has implemented a structured and proactive management approach to ensure non-discrimination, consisting of the following key measures:
a. Inclusive Hiring Practices
Recruitment, promotion, and employment decisions are based solely on merit, qualifications, and business needs. Job postings and selection criteria are designed to encourage diversity and discourage any form of exclusion or bias.
b. Training and Awareness
Regular awareness and sensitivity training sessions are conducted for employees, supervisors, and management to reinforce the importance of diversity, equity, and inclusion and to prevent unconscious bias in the workplace.
c. Anti-Discrimination Procedures
The Company enforces a zero-tolerance policy against discrimination and harassment. All reported incidents are treated confidentially and investigated promptly in accordance with the internal grievance procedure.
d. Equal Pay and Opportunity
We ensure equal remuneration for work of equal value, and equitable access to professional development, training, and leadership opportunities, regardless of personal characteristics or background.
e. Workplace Accessibility and Inclusion
Special consideration is given to creating a workplace that is accessible and inclusive for people with disabilities. Reasonable accommodations are provided where necessary to support full participation.
f. Grievance and Reporting Mechanism
A clearly defined and confidential grievance mechanism is in place, allowing employees and stakeholders to report concerns or violations without fear of retaliation. All complaints are addressed in a fair, timely, and impartial manner.
g. Monitoring and Accountability
HR and Compliance departments regularly monitor workforce demographics, promotion patterns, complaint data, and other relevant indicators to identify and correct any potential imbalances or discriminatory trends. Results are reported to senior management and used to guide continuous improvement.
Policy Statement
We are fully committed to respecting all applicable international labor standards and national laws relating to working hours, rest periods, and employee well-being. We recognize that ensuring fair and humane working conditions is essential not only to compliance but also to the long-term health, productivity, and dignity of our workforce.
Compliance with International and National Standards
The Company aligns its practices with the International Labour Organization (ILO) Conventions, as well as the UAE Federal Law No. 33 of 2021 concerning the Regulation of Labor Relations. This includes:
Maximum Working Hours: Standard working hours shall not exceed 8 hours per day or 48 hours per week, unless otherwise authorized and compensated in accordance with applicable labor laws.
Overtime: Any overtime work shall be voluntary, pre-approved, recorded, and compensated as per statutory requirements. Minimum Breaks: Employees are entitled to appropriate rest breaks during their workday, including at least one hour of rest after every continuous five hours of
work.
Weekly Rest Period: A minimum of one paid rest day per week is provided to all employees.
Responsible Work Allocation
The Company actively assesses the capacity of its workers to comply with these time-related commitments when assigning tasks or setting performance targets. Work allocation is managed with the following controls: Feasibility Assessment: All project schedules and targets are developed in consultation with site supervisors and workers to ensure that workloads are achievable within regular working hours.
Monitoring of Hours Worked: A timekeeping system is in place to accurately monitor working hours, breaks, and overtime across all operations.
No Forced Overtime: Employees shall not be compelled to work overtime. All additional work is voluntary and undertaken in accordance with legal and safety guidelines.
Health and Fatigue Consideration: Supervisors are trained to identify signs of fatigue and overwork, and to take corrective measures including adjusting workloads and allowing recovery periods when needed.
Transparency and Accessibility
The Company communicates this policy publicly to all employees, partners, and stakeholders through onboarding programs, policy manuals, and notice board postings at work sites and accommodations. The policy is also accessible to inspectors, auditors, and third parties involved in monitoring labor compliance.
Grievance and Reporting Mechanism
Workers are encouraged to report any violations or concerns regarding excessive working hours or denied rest periods through our established grievance channels. All complaints are handled confidentially and without retaliation.
Continuous Improvement and Oversight
The HR and Compliance Departments conduct periodic audits to ensure working hour regulations are being followed in practice, and to identify opportunities for improvement. Feedback is integrated into policy updates and operational adjustments.
Policy Statement
Cactus (“the Company”) is committed to ensuring that all its direct employees receive a fair and decent standard of compensation. We recognize the importance of a living wage—one that covers basic needs such as food, housing, transportation, education, and healthcare—along with a discretionary income for a dignified standard of living. Our commitment to paying a living wage reflects our core values of fairness, dignity, and social responsibility. This policy extends across all our operational locations and to all categories of directly employed workers.
Definition of Living Wage
A living wage is defined as the minimum income necessary for a worker to meet their basic needs and those of their family, considering the local cost of living and without reliance on state subsidies. We distinguish a living wage from minimum wage requirements, which may not always reflect the true cost of living in the region.
Measurable Commitment
To fulfill this commitment, we have adopted the following measurable practices:
Benchmarking and Review: We regularly benchmark wages against credible living wage indicators and adjust salary structures to ensure alignment with the evolving cost of living in the UAE and other operational regions.
Wage Structure Transparency: Compensation structures for all levels of employment are standardized, documented, and reviewed annually by HR and Finance departments to ensure compliance with our living wage goals.
No Discrimination: Our wage practices are equitable and free from discrimination based on nationality, job category, or employment type.
Third-Party Verification: Where applicable, we engage third-party auditors to validate wage practices in line with international standards and stakeholder expectations.
Communication and Public Access: This Living Wage Commitment is made publicly available to employees, clients, business partners, and relevant stakeholders. It is included in internal HR handbooks and is accessible upon request as part of our transparency and accountability principles.
All directly employed full-time, part-time, and temporary workers across all CACTUS Group operations. It also informs our expectations for future supplier and subcontractor relationships, encouraging alignment with fair wage practices.
Monitoring and Compliance
The Company maintains internal tracking mechanisms through payroll audits and employee feedback systems to ensure full compliance with this policy. Discrepancies or gaps identified are addressed through immediate corrective actions and structural improvements.
Review and Update
This policy will be reviewed annually or when significant changes occur in national economic indicators, cost-of-living data, or employment regulations
DATA PRIVACY POLICY
The Purpose
The purpose of this Data Privacy Policy is to define how CACTUS MEGA BUILDING & CONSTRUCTIONS PROJECTS SOLE PROPRIETORSHIP L.L.C (hereafter “the Company”) collects, uses, stores, protects, and shares personal data, in compliance with applicable data protection laws, especially the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).
Scope
This policy applies to:
• All personal data processed by the Company in relation to employees, clients, subcontractors, vendors, partners, and any other individuals.
• All employees, contractors, and third-party service providers who handle personal data on behalf of the Company.
Definitions
• Personal Data: Any information that relates to an identified or identifiable individual.
• Processing: Any operation performed on personal data, whether automated or not, such as collection, storage, use, disclosure, or destruction.
• Data Subject: The individual to whom the personal data relates.
• Controller: The person or entity that determines the purpose and means of processing personal data.
• Processor: A person or entity that processes personal data on behalf of the controller.
Principles of Data Privacy
The Company adheres to the following principles:
• Lawfulness, Fairness, and Transparency: Personal data shall be processed lawfully, fairly, and in a transparent manner.
• Purpose Limitation: Data shall be collected for specific, legitimate purposes and not processed beyond that scope.
• Data Minimization: Only data necessary for the specified purposes shall be collected and processed.
• Accuracy: Personal data shall be kept accurate and up to date.
• Storage Limitation: Data shall not be retained longer than necessary for the purpose of processing.
• Integrity and Confidentiality: Data shall be protected against unauthorized or unlawful processing, accidental loss, destruction, or damage.
Types of Personal Data Collected
Depending on the relationship, the Company may collect the following personal data:
• Full name, date of birth, nationality, contact details
• Emirates ID, passport number, visa/residency information
• Employment details (position, salary, contract)
• Bank account details (for payroll or payments)
• CCTV or biometric data (where applicable)
• Any other data legally required for business, HR, or compliance purposes
Legal Basis for Processing
Personal data will only be processed when one or more of the following conditions are met:
• With the explicit consent of the data subject
• For the performance of a contract
• For compliance with a legal obligation
• To protect the vital interests of a data subject
For legitimate interests pursued by the Company, provided it does not override the fundamental rights of the data subject
Data Subject Rights
All individuals whose personal data is held by the Company have the right to:
• Access their personal data
• Request correction or deletion
• Object to processing or request restriction
• Withdraw consent at any time (where applicable)
• File a complaint with the UAE Data Office or relevant authority
Data Security Measures
The Company implements appropriate technical and organizational measures including:
• Secure storage systems and encryption
• Access control and authentication protocols
• Employee training on data handling
• Regular audits and monitoring
• Secure disposal of paper and digital records
Data Sharing and Transfers
• Personal data may be shared with third-party service providers only when necessary and under data processing agreements.
• The Company will not sell personal data to third parties.
• Data transfers outside the UAE will only occur in accordance with PDPL requirements and with adequate safeguards in place.
Retention and Disposal
Personal data will be retained only as long as necessary for its intended purpose or to comply with legal/regulatory obligations. Upon expiry of retention periods, data will be securely deleted or anonymized.
Policy Review
This policy shall be reviewed annually or upon significant changes to applicable laws or Company practices.
Violations and Enforcement
Any employee or third party found to be in violation of this policy may face disciplinary action, legal proceedings, or termination of contract.
INFORMATION SECURITY POLICY
Purpose
This Information Security Policy establishes the framework and principles to protect the confidentiality, integrity, and availability of all information assets managed by CACTUS MEGA BUILDING & CONSTRUCTIONS PROJECTS SOLE PROPRIETORSHIP L.L.C (hereinafter referred to as “the Company”). The policy ensures that information is protected against unauthorized access, disclosure, modification, or destruction, in accordance with legal, regulatory, and contractual obligations.
Scope
This policy applies to:
• All employees, contractors, consultants, temporary staff, and third-party service providers.
• All organizational information assets, including physical and digital data, networks, applications, hardware, software, and cloud-based services.
• All locations and premises operated or controlled by the Company.
Information Classification
Information shall be classified as follows to ensure appropriate protection:
Access Control
Asset Management
Physical and Environmental Security
Network and System Security
Data Protection and Privacy
Information Security Awareness
Incident Management
Business Continuity and Disaster Recovery
Compliance and Monitoring
Roles and Responsibilities
Founder and Owner: Approve policy, allocate resources, and ensure enforcement.
Information Security Lead: Oversee policy implementation, conduct risk assessments, and manage incidents.
All Employees: Comply with policy, report incidents, and safeguard company information and assets.
Review and Revision
This policy shall be reviewed annually or upon significant changes to operations, technology, or regulatory environment.
Enforcement
All employees and associated personnel are required to adhere to this policy. Breaches of this policy may result in disciplinary action up to and including termination and legal liability.
At Cactus Mega Building & Constructions Projects Sole Proprietorship L.L.C, we are fully committed to delivering construction, infrastructure, and interior fit-out projects that meet and exceed customer expectations, while complying with statutory, regulatory, and contractual requirements in the United Arab Emirates.
We aim to achieve excellence in quality, safety, and sustainability by implementing and continually improving a robust Quality Management System (QMS) aligned with ISO 9001:2015 standards.
Our core quality principles are:
1. Client Satisfaction
Understand and fulfill client requirements through professional execution, timely delivery, and consistent performance.
2. Compliance & Standards
Adhere to all relevant local authority regulations, government procurement standards, and international codes of practice in all aspects of our work.
3.Process Efficiency
Streamline operations by integrating best practices and lean construction principles to improve efficiency, reduce rework, and minimize waste.
4. Employee Competence
Enhance staff knowledge and skills through continuous training, awareness, and empowerment, fostering a culture of accountability and excellence.
5. Supplier & Subcontractor Alignment
Work only with approved vendors and subcontractors who share our commitment to quality and reliability.
6. Continuous Improvement
Regularly review performance indicators, client feedback, and audit findings to identify opportunities for ongoing improvement in quality management.
7. Health, Safety & Environment (HSE) Integration
Uphold stringent HSE standards and ensure that quality does not compromise the safety and well-being of our employees, clients, and the public.
This Quality Policy is communicated to all employees and stakeholders, and is reviewed periodically by top management to ensure its continued relevance and effectiveness.
We are dedicated to building a trusted name in the UAE construction industry—defined by integrity, professionalism, and quality.
