Code of Conduct

In accordance with the Company’s commitment to the highest standards of ethics and the Al Ghazzawi Group of Companies Code of Conduct, the Company’s Board of Directors and Executive Board have approved and instituted the following anti-corruption compliance principles:

Ethics and the Law.

Al Ghazzawi Group of Companies employees shall conduct themselves in accordance with the Company’s commitment to the highest standards of ethical conduct and to ensure full compliance with the Al Ghazzawi Group of Companies Code of Conduct, the Anti-Corruption Compliance Employee Handbook, and all applicable national and international anti-corruption laws.

Integrity in Work Place.

Ghazzawi Group is committed to the highest standards of ethical business conduct, thus have a high expectation for its employee to have the same standards of honesty, integrity, and respect for co-workers, customers, partners and any party that an employee conducts business with on behalf of the Group. Ghazzawi Group seeks to provide an inclusive, positive environment and a welcoming workplace for its employees which would value their talents and contributions to the business. Ghazzawi Group expects its employees and all the stakeholders to be honest, faithful, treat your colleagues with mutual respect, contribute to the group’s mission and vision and treat the customers, suppliers and consumers with utmost integrity.

Health and Safety.

Ghazzawi Group conducts all its business with care for the environment, health and safety. Maintaining that commitment demands that the group’s companies and their employees understand and comply with all applicable relevant environmental, safety and health laws and regulations.

Accuracy of Business and Financial Records.

Ghazzawi group employees are required to use absolute care and attention accurately record and report information in business records and reports. Ghazzawi Group does not permit or otherwise allow falsification of documents. Employees should report to the ethics helpline any attempts to falsify records.

Conflicts of Interest.

Al Ghazzawi Group of Companies employees shall avoid any activity that leads to a conflict of interest or an appearance of impropriety, including but not limited to the acceptance or giving of personal gifts or hospitality to or from Al Ghazzawi Group of Companies stakeholders other than gifts of nominal value (i.e., less than SR 500) or reasonable hospitality given in the ordinary course of business.

Bribes.

Al Ghazzawi Group of Companies employees shall not, in order to obtain or retain business, offer, authorize, or pay bribes or provide anything of value, other than gifts of nominal value under any circumstances, including directly or indirectly to customers, suppliers, government officials or candidates, or other parties. Travel compensation is prohibited.

No facilitation payments.

Al Ghazzawi Group of Companies employees shall not, in order to expedite business or government procedures and/or processes, make any facilitation payments, in cash or kind, to government officials, whether directly or indirectly via third parties. They must ensure that all third parties acting for the Company are aware of this policy and do not make any improper payments whatsoever on its behalf.

Appropriate Internal Controls and Accurate Books and Records.

Al Ghazzawi Group of Companies employees shall ensure that the Company make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Company. Employees shall be responsible for executing the internal controls as defined in the Internal Controls Framework and related financial cycles and for reporting any significant deviations in these controls.

Anti-Corruption Compliance Employee Handbook.

Al Ghazzawi Group of Companies employees shall read and comply with the Al Ghazzawi Group of Companies Anti- Corruption Compliance Employee Handbook.

Anti-Corruption Compliance Training.

All Ghazzawi Group of Companies employees who deal with customers, third parties and/or government officials shall complete the Anti-corruption Compliance Training (ACT) online or similar classroom-based training.

Reporting Violations.

Al Ghazzawi Group of Companies employees are obliged to report to the Al Ghazzawi Group of Companies Chief Compliance Officer directly any suspected or actual violation of the Al Ghazzawi Group of Companies Anti-Corruption Compliance Principles, or of any anti-corruption laws. These include, but are not limited to, acts leading to conflicts of interest, or prohibited or suspicious payments or offers of payment to customers, suppliers, government officials, or political parties. Al Ghazzawi Group of Companies will ensure that there will be no adverse work-related consequences for any employee who in good faith alerts management to possible violations of these Principles.

Compliance Office Assistance.

Al Ghazzawi Group of Companies stakeholders shall seek clarification from the Al Ghazzawi Group of Companies Chief Compliance Officer at ethics@ghazzawigroup.com regarding any questions or concerns relating to the application or meaning of any provisions of the Al Ghazzawi Group of Companies Anti- Corruption Compliance Principles, Employee Handbook, or any other anti-corruption related matters.

Applicability.

This code of conduct must be followed by everyone work at Ghazzawi Group.

• Directors, Managers, Employee and Third parties representing Ghazzawi Group.
• Subsidiaries, which Ghazzawi Group owns more than 50 percent of voting rights, or which.
• Ghazzawi Group has the right to control.
• Agents, consultants, contracted labor and others when they are representing or acting for, or on behalf of, Ghazzawi Group.