laa ' Sadara’Table of Contents Message from Sadara Compliance with Laws, Codes and Regulations Environmental, Health, and Safety Practices Ethical Business Practice Fair Trade Practice Ethical Sourcing Relationships and Communications Bribery, Kickbacks and Fraud Gifts, Gratuities and Hospitality Monitoring and Compliance Office of Ethics & Compliance Confidentiality Application Acknowledgment of Sadara’s Supplier Code of Conduct. "Available in other languages soon. OYINDHUHALARWWY Sadara Supplier Code of Conduct To make a report, goto: om, Ethics & Compliance page 2|PageMessage from Sadara Chemical Company The Value of Trust Sadara is affiliated with companies worldwide and is fully committed to the very highest standards of business integrity. We believe that it is critical to our joint success that Sadara and its Suppliers maintain the highest ethical standards and be aware of, and adhere to, all applicable laws and regulations. Return on Influence Our business relationships are founded on trust. Sadara has zero tolerance toward violations of this Code, conflicts of interest, or even the appearance of one, in any dealings. As such, all Sadara and Supplier employees are required to conduct themselves with the highest standards of honesty, fairness and personal integrity at all times. In addition to our Company Code of Ethics & Business Conduct, available at [website], Sadara has this Suppliers’ Code of Conduct which more specifically addresses our relationship with our suppliers. We understand it is essential that all parties to our business activities feel confident in the fairness and transparency of our business practices. This is why we have codified the ethical responsibilities of our Suppliers in the Supplier Code of Conduct (hereafter referred to as ‘the Supplier's Code’). The code establishes a policy for all current and potential Sadara Suppliers who are, or who wish to be, registered with Sadara. In a competitive global environment, we inevitably encounter situations that will test our awareness, judgment and integrity. When that test arises, the Supplier Code can guide us to address ethical questions before taking action. It reflects our commitment to conducting business in an ethical, legal, safe, and environmentally and socially responsible manner, and requires each of our Suppliers to share and demonstrate this commitment in order to be considered for, to do, or continue to do business with Sadara ‘Compliance with Laws, Codes and Regulations: Sadara Suppliers must comply with all applicable laws, codes, and regulations as set forth in applicable procurement documents and agreements (including but not limited to proposals, invitations to bid, solicitations, and resulting contractual and purchasing agreements). Willful or negligent violation of relevant laws and regulations may result in the dissolution of all business relationships between Sadara and the non-compliant Supplier. Environment, Health, and Safety Practices It is the responsibility of the Supplier to ensure that its facilities are designed and safely operated in compliance with the established government and industry environmental protection policies and to ensure they do not present unnecessary risks to the environment or public. Sadara Suppliers shall maintain safe, sanitary, and healthy work and living environments for all their employees. Such compliance shall include, among other things = Obtaining and maintaining any necessary environmental permits. - Proper storage, handling and disposal of hazardous materials and refuse. - Monitoring, controlling, and responsible treatment of discharges generated from operations. Sadara Supplier Code of Conduct ‘To make a report, goto: www sadara.com, Ethics & Compliance page 3|Page~ Conducting appropriate employee safety training and providing adequate safety equipment. ~ Maintaining records of safety training and monitoring safety performance. - Ensuring Suppliers’ employees comply with applicable health and safety rules and regulations and perform their duties and work in a manner which will not endanger themselves, others or the environment. - Providing training required to promote sound public health and hygiene practices. Ethical Business Practices Sadara and its Suppliers shall conduct their businesses in accordance with the highest standards of ethical and compliant behavior. Suppliers are expected to conform to these requirements in each of the following areas: Fair Trade Practices Suppliers shall not engage in collusive bidding, price discrimination, anti-competitive, antitrust, or other unfair trade pract Ethical Sourcing Suppliers shall source goods or services from third parties that meet, as a minimum, country of origin standards for health and safety, working hours, pay, employment conditions and environmental protection. Relationships & Communications Sadara Code of Ethics and Business Conduct Policy requires that all transactions are to be conducted fairly, honestly, and with integrity, according to the standards of Best Practices and compliant behavior. Abuse or violation of this Business Ethics Policy is considered as corrupt behavior, and will not be tolerated. Suppliers and their personnel shall avoid even the appearance of unethical or compromising practices in relationships, actions, or communications with regard to existing or proposed business relationships with Sadara. Sadara views it as a conflict of interest and improper business practice for current or former Sadara employees to utilize any confidential or proprietary business, technical, or other information obtained while in the service of Sadara to influence Sadara’s existing or proposed commercial transactions for the purpose of gaining a personal commercial advantage, or benefitting any third party, or to otherwise damage Sadara, whether during or after leaving the employment of Sadara. Suppliers shall not encourage, entice or utilize current or former Sadara employees in any manner which would cause them to disclose or provide any confidential, proprietary, or other restricted information obtained while employed by Sadara to influence Sadara’s existing or proposed commercial transactions for the purpose of gaining a commercial advantage. Suppliers shall not hire, employ, engage as a consultant, procure the services of, or allow acquisition of any ownership interest of the supplier, except through a permitted passive investment, any current Sadara employee. This restriction shall also require any former employee Sadara Supplier Code of Conduct To make @report, goto: ywwww.sadara.com, Ethies & Compllance page 4|Pagewho has held a position within Sadara at the level of “department head” or higher that such hire and relationship be immediately and fully disclosed to Sadara, and may subject the Supplier to additional reporting requirements and safeguards with respect to such. The restriction pertaining to former employees shall be valid for a period of two (2) years following the time that such individual is no longer an employee of Sadara, Suppliers may seek exceptions to these restrictions from Sadara. Requests for such exceptions should be submitted in writing to the Sadara Office of Ethics & Compliance. Sadara will take appropriate measures to detect any such improper business practices and will take appropriate action against current or former employees and Suppliers who violate these restrictions. Suppliers are expected to cooperate with Sadara investigations and to provide reasonable assistance as requested. Bribery, Kickbacks and Fraud Sadara is committed to maintaining the highest ethical and legal standards in our relationships around the world. This includes our relationships with governments and government officials as well as with other businesses. We do not participate in or tolerate bribery or corruption in any form. Giving or accepting a bribe of any kind is criminal offense. Sadara will pursue criminal charges which may include heavy fines and prison Sadara prohibits its employees, agents or Suppliers acting on its behalf from paying bribes to foreign government officials, representatives of companies that are partially or wholly owned by a government, and political figures. No funds, assets, services, privileges, or benefits shall be paid, rendered, loaned, or promised for payment or otherwise dispersed by Suppliers or their representatives as bribes, “kickbacks”, or other payments or inducements designed to influence or compromise the judgment or conduct of Sadara or its representatives. Gifts, Gratuities and Hospitality Suppliers and their personnel shall not offer or provide Sadara or its personnel with gifts, gratuities, or hospitality unless it involves nominal value and is in line with customary business practices. Nominal gifts are described as gifts of a general nature having a low value, including such items as logo inscribed pens, caps, shirts, and coffee mugs. Customary business practice in terms of hospitality would include the acceptance of reasonable business entertainment and business meals. Gifts, gratuities, and hospitality offered or extended by Suppliers to Sadara personnel, which exceed nominal value or reasonable hospitality are reportable under internal Sadara policies and regulations. Items which are made available to the general public do not fall under this Policy. Sadara Supplier Code of Conduct -Tomakea report, goto: wwww.sadara.com, Ethics & Compliance page 5|PageFor the avoidance of any doubt, Sadara pays for all of its employees’ business expenses. Suppliers are not required or requested to incur or reimburse business expenses for Sadara employees. Monitoring and Compliance Suppliers shall be responsible for complying with the standards and requirements of this Supplier Code of Conduct and to monitor their own business activities. Suppliers shall conduct periodic internal reviews, inspections, and audits to ensure their compliance with this Supplier Code of Conduct and its applicable requirements. Additionally, Suppliers are responsible for ensuring that the standards and requirements of this Code are communicated and understood by their personnel working on or in support of Sadara projects, jobs, contracts, agreements, and orders. Suppliers will be held responsible for the conduct and actions of their employees. The implementation of this Policy is a shared responsibility between Sadara and its Suppliers. Suppliers are required under the terms of their business relationship with Sadara to promptly disclose to Sadara, on a confidential basis, all current and potential incidents which have or may give rise to the appearance of conflicts of interest, and instances of unethical or fraudulent behavior by any party. This includes, but is not limited to Supplier employees or Sadara employees, involved with any Sadara business contracts or associations. Suppliers are to cooperate with Sadara in any inquiries or investigations pertaining to past, current, or potential instances of unethical or fraudulent behavior or conflicts of interest related to any Sadara business ity. Office of Ethics & Compliance Suppliers are to promptly notify Sadara when they become aware of any actual or potential violation of this Suppliers’ Code of Conduct and to communicate plans to correct and remedy such violation Additionally, Supplier employees that become aware of violations of this Code of Conduct are to notify Sadara. Potential or actual violations of this Code of Conduct and other ethical irregularities are to be reported directly, and anonymously if the reporter choses, to the Sadara Office of Ethics & Compliance. Contact us by mail: SADARA CHEMICAL COMPANY Office of Ethics and Compliance P. 0. Box No 39777 Dhahran 31942 Kingdom of Saudi To report a violation of the Code you may visit Sadara’s website at Compliance page. www.sadara.com, Ethics & Suppliers shall maintain appropriate records to substantiate compliance with the terms and conditions of this Code of Conduct and provide such evidence to Sadara upon request. Sadara or its designated representatives may engage in periodic monitoring activities to confirm Suppliers’ compliance with this Code of Conduct. These monitoring activities may include on-site inspections of facilities, use of questionnaires, review of publicly available information, or other measures necessary to assess Supplier compliance with this Code of Conduct. Such monitoring activities may be performed in addition to any audit rights which may be set forth in an agreement with Sadara. A Supplier performance assessment will Sadara Supplier Code of Conduct. To make a report, go to: www sadara.com, Ethics & Compliance page 6|Pagebe used by Sadara as a factor in the selection of bidders, the administration of contracts and procurements, or to possibly restrict Supplier access to new Sadara business opportunities. Based on the assessment of information made available to Sadara, Sadara reserves the right (in addition to all other legal and contractual rights) to disqualify any potential Supplier or to terminate any relationship with a current Supplier which Sadara has found to be in violation of this Supplier Code of Conduct, without liability. Confidentiality As part of the process of seeking to provide goods, services, or personnel (including consultants) to Sadara or in providing such goods, services, or personnel under the terms of an applicable Agreement, Suppliers may gain access to information or material which Sadara deems to be proprietary or confidential. Suppliers, in all instances, shall comply with the obligations of confidentiality which are set forth in the applicable request for proposal, invitation to bid, other solicitation document, or agreement by and between Sadara and the Supplier. Sadara views breaches of confidentiality and unauthorized disclosure or use of proprietary or confidential information very seriously and reserves the right (in addition to all other legal and contractual rights) to disqualify any potential Supplier or to terminate any relationship with a current Supplier Sadara has found to have violated its obligations of confidentiality. All advertising, press releases, or printed matter that reference Sadara or a Supplier's relationship with Sadara must be approved by the Sadara Public Relations Department prior to publication or other use. Application This Supplier Code of Conduct is a general statement of Sadara’s expectations and requirements with respect to its Suppliers. This Code of Conduct should be read in addition to any Supplier obligations set forth in a) Requests for proposals, invitations to bid, or other solicitation documents, or b) Agreements by and between Sadara and the Supplier. In the event of a conflict between this Code of Conduct and any Sadara solicitation documents or applicable agreements, the terms of Sadara’s applicable solicitation documents or agreements shall prevail The requirements of this Code of Conduct are not subject to waiver. Sadara personnel, Suppliers, their personnel, nor representatives are authorized to propose or approve conduct inconsistent with this Code of Conduct. Kindly review and sign the following ‘Acknowledgement of the Supplier's Code of Conduct submit both pages to the Sadara Procurement Department. Sadara Supplier Code of Conduct To make areport, go to: yw sadara.com, Ethics & Compliance page 7|PageACKNOWLEDGEMENT OF SUPPLIER’S CODE OF CONDUCT This Supplier's Code of Conduct sets forth the basic principles expected of all Vendors, Manufactures, Contractors, Sub- Contractors, and Suppliers when working with Sadara. Sadara is committed to excellence in Ethics & Compliance, and expects its business associates to be as well HUMAN RIGHTS & LABOR: Respect, equality, falmess, and integrity. Sadara adheres to these principles and expect our suppliers to respect the human rights of their employees and treat them fairly, in accordance with all applicable laws. Diversity and Equal Employment Opportunity: Suppliers will respect and promote diversity in the workplace, taking all necessary steps to promote and protect equal employment opportunities for qualified candidates, free from discrimination. No Forced or Compulsory Labor: Suppliers will not use forced or involuntary labor. This includes child labor, prison labor, indentured labor, bonded labor, or slave labor, No Harassment or Abuse of Labor: Suppliers will ensure that their employees are not subjected to any form of harassment, and will comply with all applicable laws and standards of ethics on harassment and abuse of employees. Full Compliance with Labor Regulations: Suppliers will adhere to all rules, regulations and best practices in respect to full compliance with relevant labor regulations. ENVIRONMENT, HEALTH & SAFETY: Sadara's commitment to sustainability includes efficient use of resources, respect for the environment and safe and healthy workplaces and efforts to effectively reduce the Company's carbon foot-print on the ‘environment from the impact of their operations. Respect the Environment: Suppliers will comply with all applicable environmental laws. Suppliers will have system in place to censure safe management of waste, air emissions and wastewater discharges. Sadara will favor suppliers who seek the best ways to minimize non-reusable resources, and use all resources more efficiently, Protect Health & Safety: Suppliers will provide a safe and healthy workplace for their employees including appropriate controls, training, work procedures and personal protective equipment. Suppliers will comply with all applicable workplace health and safety laws. ETHICS & LEGAL REQUIREMENTS: Sadara expects its suppliers to conduct their business ethically and in full compliance with the law and best practices standards of operations. Conflicts of interest: Suppliers will avoid an interaction with a Sadara employee that may conflict, or appear to conflict, with ‘that employee acting in the best interests of Sadara. This includes offering payments or other any other form of compensation, No Bribery: Suppliers agree to and adhere to a strict ‘No Tolerance’ policy for Bribes or kickbacks. As well as take reasonable actions and precautions designed to prevent and detect Bribe or kickback. The Suppliers must notify Sadara if they have reasonable grounds to believe any violation of Law or the Code may have occurred. Suppliers agree to fully cooperate with Sadara in any investigation of suspected illicit behavior. Fair competition: Suppliers will comply with all applicable laws regarding fair competition and antitrust. ‘Accurate Accounting and Business Records: Suppliers will keep accurate and thorough business records for all business interaction with Sadara chemical Company. Suppliers will provide Sadara these records upon request. Sadara Supplier Code of Conduct To make a report, goto: wwrw.sadara.com, Ethics & Compliance page B|PageConfidential Information: Suppliers may have some access to confidential Sadara information that they would not normally have access to. Suppliers will protect Sadara’s confidential information and take all reasonable steps to prevent any misuse of the information. ‘Compliance: In addition to the legal regulations referred to in this Code, suppliers will comply with all other applicable laws in the provision of products or services to Sadara. Sadara expects suppliers to implements systems and controls to promote full compliance with applicable laws and standards defined in this Code; including polices, training, and audit programs. Sadara reserves the right to assess supplier’s compliance with this Cade and any given time. Suppliers who are not in compliance wit this Code are expected to implement corrective actions. Failure to make the necessary corrective actions may result in the rescinding of any current contracts with Sadara and they may not be considered for future business. Reporting misconduct: Suppliers who believe that a Sadara employee or anyone acting on behalf of Sadara has engaged in illegal or otherwise unethical conduct with respect to their business with the supplier should report the matter to Sadara ‘Chemical Company's Office of Ethics & Compliance at www.SadaraEthics@sadara.com. Sadara has a No Retaliation policy. ‘Therefore a Supplier's relationship with Sadara will not be affected by an honest report of a potential misconduct. Acknowledgement of Sadara Chemical Company's Supplier Code of Conduct |, on behalf of ~ (name of vendor / manufacturer /contractor/Sub-convactor) _» hereby acknowledge and agree to abide by the policies and principle of the Sadara Chemical Company's Code of Business Conduct for Suppliers and to ensure that the employees, officers, directors, agents, representatives of {Name of Vendor / Manufacturer / contractor /Sub-Contacion) F@ aware of and shall abide by such policies and principles in the process of preparing and submitting bids, proposals, or other business related communications for Sadara Chemical Company, for provision of goods and services to Sadara, and during the performance and administration of all agreements entered into with Sadara Chemical Company for such purposes. ‘Authorized Signatory Name: Signature: Job Title: Date: Company, ‘Supplier No. Sadara Supplier Code of Conduct. To make a report, goto: www-sadara.com, Ethics & Compliance page 9|Page