STANDARD OPERATING PROCEDURE SOP HR-PR-EN-003 Number SOP Title — CODE OF CONDUCT SOP HR Department SOP No: HR-PR-EN-003 SOP Title: CODE OF CONDUCT SOP ‘SIGNATURE ‘Author Head of Department | Reviewer | Mohammad Shaban | Compliance & Risk Management Authoriser | Fatema Nayea Executive Director \O.NONP In( loll -% Final Jerome Carle General Manager (GM) Authoriser Distribution strictly reserved to Julphar GroupSTANDARD OPERATING PROCEDURE. HR Department SOP No: HR-PR-EN-003 ‘SOP Title: CODE OF CONDUCT SOP 4. PURPOSE ‘Acode of conduct is 2 set of rules to ensure that the best standards in professional conduct are achieved in business and also to create a positive atmosphere in the work environment To ensure that each employee has taken part of the content of this document, it is required for all employees to sign it and hand it over to Human Resources for filing in the personnel archives. ‘The organization requires its employees to strictly adhere to these guidelines in order to protect and maintain the reputation of Julphar. 2. INTRODUCTION We are committed to conducting our business with honesty and integrity, in accordance with high ethical and legal standards, and with respect for each other and those with whom we do business. This Code of Business Conduct (the Code) sets out the basic rules, standards and behaviors necessary to achieve those objectives, All of us are expected to display responsible and ethical behavior, to follow consistently both the meaning and intent of this Code and to act with integrity in all of our business dealings. Management and supervisors are expected to take such action as is necessary and appropriate to ensure that our business processes and practices are in full compliance with the Code. 3. SCOPE ‘Compliance with the Law Declaration of Secrecy (Confidentiality) Conflict of interest Professionalism Dealings with the Public / External Parties Safeguarding Company Assets 4. DEFINITION Defining and developing an effective code of conduct for organizations is the principle, values, standards, or rules of behaviour that guide the decisions, procedures and systems of an organization in a way that (a) contributes to the welfare of its key stakeholders, and (b) respects the rights of all constituents affected by its operations. 5. RESPONSIBILITIES All Directors and Managers should set the example for other employees by actively promoting disclosure ‘and compliance with this code of conduct in performance of their duties. Superiors should ensure all their employees receive guidance, training, and communication on ethical behaviour and legal compliance relevant to their role and responsibilities within the organization and all ‘employees are responsible for making sure to abide this code of conduct. The requirement to abide by this code both impliedly and ethically forms part of each employee's contractual obligations. Therefore, a responsibility exists upon every employee without exception to Understand and follow this code of conduct. Distribution strictly reserved to Julphar Group __ Page 2 of 6HR Department SOP No: HR-PR-EN-003 SOP Title: CODE OF CONDUCT SOP ‘Any violation of the code of conduct will be deemed as misconduct and shall be subject to disciplinary ‘action where severity shall be dependent on the circumstances and findings - misconduct being any conduct that is perceived against this approved code. All employees of Julphar are expected to meet @ standard of conduct which is appropriate to the good ame and reputation of the organization; uphold the law, moral and cultural standards of the United ‘Arab Emirates both on and off duty. Individual departments or sections may need to set down rules that are more specific to their duties which should be consistent with this code's framework. Managers should review their specific work rules in advance with the HR manager to obtain appropriate approval before implementation. Personal photography at any of Julphar's sites and facilities is strictly prohibited and employees should be fully aware of the consequences of any unauthorised disclosure, relaying or use of any such Confidential information, and agrees to assume any liability or responsibilty that may arise as a result of any breach of such This obligation shall remain in force for an unlimited period of time upon termination of employment and is enforceable by law. The employee shall handover immediately all documents, papers, files, materials, tapes, storage media, programs or other property (whether containing confidential information or not) which belong to their department. 6. CONFLICT OF INTEREST Conflict of interest arises when an Employee's personal, social and financial or other activities have the Potential of or are interfering with his or her loyalty and objectivity to Julphar. Employees have an obligation to act as fiduciaries of Julphar. All business decisions made for the Julphar are to be made solely on the basis of a desire to promote the best interests of the Julphar in serving its customers and internal/external stakeholders. A conflict of interest may take many forms but arises when an Employee might be able to use the authority oftheir position to: a) Influence Julphar’s business decisions in ways to give improper advantage or financial benefit to ‘oneself, a family member, or an associate or, 'b) Obtain for oneself, a family member or an associate financial benefit beyond the compensation he or she is authorized to receive for performing his responsibilities. Financial confict of interest exists if an Employee of the Julphar has actual or potential ownership or investment in, of receives compensation such as the receipt of cash, favour, substantal gifts or other property from any entity with which Julphar has a transaction, contact, or an arrangement with, or an entity whose business or operation has been or will be directly affected by a decision of Julphar. Employees have an obligation to disclose any financial conflict of interest where fallure to do so will result in disciplinary action as well as termination of Employee andior financial recovery, if it is established that the organization has incurred financial loss, or paid up more than required for any business transaction due to financial conflict of interest of such nature Itis illegal under UAE law to accept, elicit, negotiate or receive, either directly or indirectly, or be paid any gifts or be made a promise in exchange for a financial or non-financial benefit. Julphar Employees are expected to avoid all types or forms of corruption or gifts/bribery and Julphar shall investigate all suspected or reported cases of such bribery. If an official investigation confirms that an Employee has aid, received or asked for a gift, he/she shall be referred to the competent authorities for criminal prosecution as well as being subjected to the appropriate internal disciplinary action. Employees must not make or influence business decisions, including executing purchasing agreements ‘or other types of contracts, from which they, an immediate or extended family member, or an associate may personally benefit Distribution strictly reserved to JulpharGroup__ Page 3 of 6STANDARD OPERATING PROCEDURE HR Department SOP No: HR-PR-EN-003 SOP Title: CODE OF CONDUCT SOP Employees must not involve themselves in any official process or decision that would directly or indirectly influence the success of a contractor, supplier, vendor or any other business venture owned by Employee or their relatives (to the 4" degree of family relationship). Employees who stand to gain from a particular contract must identify the situation to their Supervisors. 7. PROFESSIONALISM Employee behaviour is at all times expected to be aligned with the code along with a positive attitude ‘and morale towards other employees and the organisation. We are a large organisation with many different departments, and very diverse organization with employees from almost every continent, hence we often must co-operate together to carry out a business function. Such co-operation requires both respect and teamwork hand in hand which shall enable us to be professional whilst dealing inter- departmental. Co-operation, respect and good manners shall and will prevail at all times, Ensuring this shall prevent any hostility within the work place, thus aiding teamwork and the Julphar cause. There must be mutual respect between employees with regards to the difference in cultures, customs, ‘and historical background, political and religious views. Julphar retains a ZERO TOLERANCE policy for any form of discrimination between employees on any basis whether racial, sexual, religious, social status, nationality physical, mental and any other words or actions that infringe on an individual's basic Human Rights, & DEALINGS WITH THE PUBLIC / EXTERNAL PARTIES To ensure a high standard of service is maintained and to improve the quality of service provided, it is essential to adopt a courteous, helpful and professional attitude when dealing with external parties. In particular Employees must: Consider own safety and the safety of others when undertaking duties; Refuse and report to line Manager, Department Head, Management Department on any attempt by members of the business community (including customers, suppliers) to offer inducements or other benefits in exchange for favours or special treatment either to self or any other colleague: Be fair and professional in all dealings with the public; ‘Adopt a courteous, friendly, helpful and professional attitude to the public as well as internally with other Employees; Exercise impartiality and ensure that they are not involved in promotional activities related to the customer without approval from their Immediate Supervisor. 9. SAFEGUARDING COMPANY ASSETS The intent ofthis policy is to ensure that all property maintained by Julphar is kept in the best possible working condition and to ensure proper utilization. Property shall be defined as any piece of equipment, furnishing, vehicle, building or supply leased, owned, donated or otherwise in the custodial care of Julphar or any person acting as its agent, or any other assets. Itis therefore the responsibilty of each Employee to maintain his work environment in an orderly fashion and follow all of Juiphar’s guidelines to ensure its proper use and maintenance. Should any Employee have knowledge of any misuse, he must notify his supervisor immediately. ‘Any Employee found to neglect or misuse Juiphar's property will be sanctioned under the disciplinary policies. If the neglect is determined to be gross, this may include termination and Julphar will expect recovery for part or all of the replacement cost; Distribution strictly reserved to Julphar Group Page 4 of 6STANDARD OPERATING PROCEDURE. HR Department SOP No: HR-PR-EN-003 SOP Title: CODE OF CONDUCT SOP Unless specifically authorized, the use of the Julphar’s assets and/or resources paid for by Julphar for Personal purposes or gain is prohibited. ‘Assets include but are not limited to: Julphar owned or leased property. Facilities (including electronic and telecommunications equipment's, telephones, Photocopier, office equipment’ supplies); Vehicles, vessels, machinery and equipment; ‘Computers and computer software; ‘Security passes, security badges, keys, passwords and the like, which are to be maintained safely; Employment card, identity badges are issued to assist and identify Employees in the performance of their duties and in exercising powers entrusted to them, which are not to be used for any other purpose; and Business card, official stationery, stamps and postal services; Any other assets belonging to Julphar, but not included here, 10. PROTECTING AND USING JULPHAR INFORMATION Julphar has a strong interest in protecting its own information. Employees must not disclose Julphar's confidential information except when disclosures are authorized or legally required. Confidential Information includes all non-public information that might be of use to compatitors or harmful to Julphar if disclosed, for example, confidential information about Julphar's product developments, business operations, or financial performance; competitive information including pricing, payment terms, discounts, and promotional strategies; the terms and conditions of distributor rights; customer lists; and any information marked confidential. Employees should be mindful of how they store and share Julphar confidential information 11. PROTECTING AND USING THIRD PARTY INFORMATION Julphar is committed to safeguarding third party information in accordance with applicable laws and contractual obligations, and in a manner that preserves trust with our partners. We will not improperly obtain or use proprietary information of our competitors or other third parties such as vendors, suppliers, customers, distributors and former employers. Employees will only discuss third party information on a need to know basis internally and discuss with no one externally. 12, CONFUSION WITH THE LABOUR LAW Whenever there is a confusion between our code of conduct policies and the labor laws then the labor law rules and regulations will supersede. 13. SPECIFIC PROCEDURE ‘The code of conduct should be read and signed by each employee and the signed copy should be filed on the HR file Distribution strictly reserved to Julphar Group __ Page 5 of 6STANDARD OPERATING PROCEDURE HR Department SOP No: HR-PR-EN-003 SOP Title: CODE OF CONDUCT SOP 14, STORAGE AND ARCHIVING Controlled SOPs are kept in PDF format under responsibility of Head of Compliance. 15. FORMS! TEMPLATES TO BE USED Code of conduct form. 16. _ INTERNAL AND EXTERNAL REFERENCES HR-PR-EN-003 17. CHANGE HISTORY Effective SOP no. Dee Significant Changes A0t HR-PR-EN-003 | 1 Nov 2017 Distribution strictly reserved to Julphar Group __ Page 6 of 6