Code of Ethics & Professional Conduct

This Document is considered as an integral part of the

Human Resources Policy of Starlink

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 Starlink’s code of ethics and professional conduct policies

This code is divided into the following parts:

Part 1: Usage of the Code

Part 2: Consequence of violating the Codes

Part 3: Expected Conducts

Part 4: Exploiting Confidential Information

Part 5: Work Environment and Other Matters

Part 6: Adherence to the Code and Whistle Blowing

Part 7: The Responsibility of Human Resources Management

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1. Usage of this code

Since ethical issues stand out daily and there is no clear definition for what is right or
wrong.

It is important that all employees read and understand this code of ethics and professional
conduct policies, and request additional information if they need it:

2. Consequence of violating these codes:

2.1 Starlink takes the adherence to these codes seriously, therefore all the employees
must understand that any violation of these codes could lead to disciplinary
measures, including termination from work (vide part 2 of the policies of HR at
Starlink on disciplinary measures) besides the personal responsibility that shall be
shouldered by the person in charge if the same resulted in violation to the law.

2.2 Disciplinary measures can also be taken against members of the management,
who fail directly or indirectly to monitor violations of these codes or are not
aware of the provisions of these codes, and who do not responds properly to any
of the reports that are related to any potential offence or who do not cooperate
with any investigation related to any potential offence.

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3. Expected conducts:
4.
4.1 Adherence to the regulations and laws:
All Starlink employees are required to adhere to all the laws and regulations
applied at Starlink, since any violation by any employee could hurt Starlink’s
reputation and can negatively impact upon its performance. Therefore, all the
employees must commit to understanding the basic legal requirements relating to
their tasks and responsibilities. Ignorance of Starlink’s regulations and policies is
not an excuse for not adhering to the regulations and the above codes. Employees
are required to consult the legal department in case they have any inquiries or
doubts.

4.2 Conflict of Interest:

Starlink requires its employees to terminate any activities that could lead to
conflicts of interests between their activities and the activities of Starlink. These
conflicts of interests include personal interests of close relatives and partners with
important investments.

Conflicts of interests appear at times when these personal activities or interests

impact upon the individual’s ability to act properly in the interest of Starlink.
Conflicts of interest also appear when the individual’s loyalty and actions are
divided between Starlink’s interest and his/her interest and other person’s or
institution’s interests, such as competitors, suppliers, clients, service providers,
partners and close relatives.

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Although all kinds of conflicts cannot be restricted to potential interests, we list
the following causes of conflicts of interests:

a) Practicing any business or trade that conflicts with the tasks of one’s tasks
at Starlink or with Starlink’s interests.

b) Managing any business or activity that could lead directly or indirectly to

personal benefits for the individual from any contracts or business relating
to the activities of Starlink or which Starlink is part to.

c) Accepting any personal gifts or grants from competitors, clients, suppliers,

service providers, current or potential partners, except those relating to the
normal work.

d) Flow of the business in terms of development or activities relating to the

relationships with clients.

e) Utilizing information of or owned by Starlink for personal gains or hurting

Starlink’s work directly or indirectly.

f) Utilizing Starlink’s assets, including Starlink’s name, reputation, good

willor employees for personal use or gain.

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 g) Gaining or holding financial interests or other interests, directly or
indirectly, through investments or contracts of different forms, in deals,
operations, or activities relating to Starlink, or gaining any personal
advantage from these interests except through owning shares in Starlink.

h) Gaining benefits such as ownership or assets of any type for the purpose of
selling or leasing the same to Starlink.

In case an employee faces any of the above situations, and could not verify
whether specific activities or relationships could cause conflicts of interests, it is
his duty to inform the management of Starlink to look into the matter and decide
whether it leads to a conflict or not, and the procedure to handle the situation.

4.3 Relationships with Stakeholders outside Starlink:

Starlink seeks to gain competitive advantage through its exceptional
performance; therefore, the employees should avoid appearing in an
inappropriate manner that could reflect unprofessional conduct. In order to
achieve success in the different fields it operates in, Starlink must develop and
sustain relationships with the different parties that constitute capability and
credibility.

Clients: Starlink employees are responsible for meeting the requirements of the
clients and providing the services they expect and deal with them with integrity,
courtesy and respect. The employees must fully seek to build trust with clients,
by providing them with high quality products and services, as
agreed upon.

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 Society: Starlink supports initiatives for societal developments and encourages
all employees to participate in such initiatives.

Suppliers: Starlink deals in a transparent way with suppliers. Product and

service decisions are conducted in Starlink’s interests, while taking into
consideration; quality, price, performance suitability and effectiveness factors. In

case the employees participate in taking such decisions, they must take caution
in avoiding any conflicts of interests.

4.4 Gifts, bribes, loans and any other rewards:

Starlink’s monies or properties shall not be used for illegal or unethical purposes.

4.4.1 Gifts, prizes and hosting:

Workers should not accept invitations for food or accept grants or gifts or
facilities related to work irrespective of the value of the same except with
the consent of the management in order to avoid creating obligations or
potential obligations towards others.

4.4.2 Bribes and Commissions:

All types of bribes and commissions are strictly prohibited. Starlink

employees are specifically prohibited from the following:

a) Granting or providing or making others to provide any

financial payments or valuable things in order to impact

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 upon the recipient’s decision
that is related to work or processing work. Exempted is Facilitation of
payments.

b) Soliciting or accepting any kind of bribe or commission and for

whatever reason.

c) Providing gifts to government employees in order to gain business or

maintaining a business, except for gifts that aim to develop
relationships, in accordance with general customs, as in the case when
meeting a high-level government official, part of an official delegation,
conditional that it is allowed and in accordance with the law. In this
context, gifts include invitations to lunch/dinner and promotional
materials.

4.4.3 Fair Competition:

Employees are prohibited from engaging in conducts that violate the law and
principles relating to fair competition. In general, fair competition laws were
found in order to prevent agreements or conducts that impair competition and
hurt the clients. Employees are also prohibited from entering into any
agreement or discussions with competitors, which could impact pricing, in
terms of setting or limiting the price, dividing the market pie, or cutting off
relationships with specific suppliers or clients without prior approval from the
management.

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 4.4.4 Utilizing the company assets:

The assets of the company should be utilized to achieve the goals of the
company. All the employees are responsible for protecting and maintaining
the company’s property and utilizing in an appropriate manner. The
company’s assets include moneys and information sources such as the
company’s computers, programs, data, operation and financial records,
internet, emails, phones, and databases.

5. Exploiting Confidential information:

5.1 Starlink’s Records and critical reports:

Critical information is important for Starlink, in order to meet its legal and
operational commitments and to enable it to compete efficiently. Therefore, it is
important for Starlink and its employees to effectively manage its records and
saved information. Tools and comprehensive policies were developed to
manage the records in order to help the employees to appropriately manage the
records. As a general rule, they are required to:

a) Preparing financial records in an appropriate manner, in accordance

with the general standards for this matter.
b) Guaranteeing that the financial record and other critical business
records are accurate, complete, correct, credible, and are available on
time.
c) Preventing any wrong or misleading or unfounded entries in the
financial register or in work records.

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 d) Auditing
and signing only the complete and accurate financial and work records.
e) Not to hide any information relating to the financial record or other
business record from the concerned department at all times and on
request.
f) Not to reveal any authorized financial or business records to non
authorized people, in accordance with Starlink’s policies.

g) Following all the laws and external accounting requirements and

Starlink’spolicies and procedures in presenting reports relating to
financial and other business records; saving, protecting, destroying, and
unveiling the same.

5.2 Intellectual Property:

Intellectual property means the intangible legal rights that grant the owner of
the IP certain exclusive rights related to that IP. IP includes secret information,
original copies of written works and technological processes. All workers are
expected to take suitable steps to protect the IP of Starlink. Besides, any IP that
may have been produced during the service of the worker at Starlink is
considered Starlink’s IP. The salary that a worker has got during his work at
Starlink is considered a suitable compensation for any such produced IP.

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5.3 Protecting Secret Information:

All workers should protect the secrecy of information that Starlink or its clients
have provided except for the information that are permitted to be revealed or if
the information is legally required to be revealed conditional on obtaining the
consent of the company. Secret information includes all information that is not
publicly known including the information that are used by competitors or the
information that if revealed may harm Starlink or its clients. Workers should
not reveal any secret information related to the activities of Starlink or its
workers or shareholders or clients even after the end of service without
obtaining prior written permit from the top executive management.

5.4 Privacy:

Workers should not utilize their work at Starlink to intrude unlawfully and
without permission on the communications of any workers or client.

5.5 Trading in secret information:

Trading in secret information is prohibited according to law and as per Starlink

policy.

Why should workers avoid this? Violating the laws of secret information may
result in lodging criminal accusations against the offender. If workers deal and
utilize secret information or consciously help others in dealing with such
information they will face legal liabilities irrespective of obtaining personal
financial benefits. Those who come to know secret information should take
suitable steps to prevent disseminating such information.

Who is the privy to secret information? Any person who has

important information on Starlink which is not known to the

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 public is considered privy. Some
by the very nature of their job become privy to secret information.

These include members of the Board and the top executive management and
workers who work with the executive managers and workers at the financial
affairs. Besides that the close members of the family are considered privy to
the secret information.

5.6 Social Media:

You are legally responsible for content you post on the internet, in any of the
social media format. Please note, you can be personally liable for defaming
others, reveling trade secrets or proprietary information, copy right
infringement, among other things. All of our company policies apply to

anything you write on social media sites , upload to the internet or post to the
internet.

6. Work Environment and other issues:

6.1 Fair Equation:

Policies and procedures of Starlink have been designed to guarantee dealing

with all respectfully and justly. Fairness includes specifying assigned tasks,
granting bonuses and promotions or any other procedure.

6.2 Health and Safety:

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 Starlink observes the principles
of health and safety and expects all workers to take proper procedures and
inform of any potential dangerous issue. The company provides its workers
with the tools of personal protection and the instructions of security and safety
at worksite for workers who undertake risky activities.

6.3 Harassment free environment:

Starlink policy prevents all kinds of harassment at the work environment. It

does not hesitate in responding to or punishing any worker who is accused of
committing harassment of any kind after verifying and establishing the truth in
such accusation.

6.4 Diligence in Work:

Workers carry out the tasks assigned to them diligently, accurately and
honestly. Workers should strive to be distinguished in accomplishing the aims
of Starlink and should project high level of ethical behavior, adherence to law,
rules, regulations, policies and procedures prevailing at Starlink.

6.5 Political Activities:

Workers shall not be involved in political activities at Starlink or publicize any

political thoughts among workers at Starlink or among its clients.

6.6 Smoking:

Starlink’s policy is not to smoke in its facilities including the toilettes and stairs
as that may cause fire. However smoking is allowed outside those places.

6.7 Alcohol and prohibited substance:

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 It is strictly prohibited to possess or
use or distribute or sell alcoholic drinks or other prohibited stuff at Starlink
properties or during carrying out work. In case of suspicion Starlink has the
right to subject the worker to investigate for alcohol and drugs. Starlink has also
the right to inspect the personal effects of the worker at its facilities and in its
vehicles.

6.8 Clothes during work:

The clothes of all workers at Starlink should be congruent with the work
manners putting into consideration the religion and traditions of the worker.
Clothes should mirror the professional nature of Starlink and its workers.
Workers may be asked to put on Starlink official attire while carrying out
certain tasks.

In all cases workers should put on decent clothes that are suitable to work while
undertaking tasks for Starlink. Decent clothes include traditional dress, suits,
lady’s gowns, lady’s skirt, trousers, socks, blouses, shirts, golf shirts, long
collar shirts and pullovers. Necktie is not compulsory for men.

If workers put on costumes that are not suitable they should consider
appointments with Starlink customers, suppliers and vendors. Sports clothes,

shorts, undershirt and similar clothes that are not suitable or congruent with the
prevailing mores are not allowed.

For safety purposes shirts with tight sleeves, traditional clothes such as Gulf
clothes, open shoes or sandals are not allowed.

7. Adherence to the code and whistle blowing:

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7.1 Informing of violations and Secrecy:

All workers should be vigilant and sensitive to any violation of this code. If a
worker feels that his or other’s behavior is incongruent with this code we urge
him/her to inform his/her manager of such case and if such behavior is directly
related to the manager she/he should inform the Starlink management of the
same.

All reports and notifications shall be treated with utmost confidentiality.

Reports maybe sent without mentioning the name. Reports shall be kept under
utmost secrecy depending on the content of the report and the Starlink law
binding duties.

7.2 Investigations:

Starlink management shall conduct initial review to see to itself the extent of
seriousness of a complaint and whether or not an investigation is required. If an
extra investigation is deemed necessary the management of the company may
take the necessary steps for that and submit a report to the Board’s verification
committee. If offences are dangerous the same shall be referred to the
verification committee for investigation and to take corrective measures which
are deemed suitable.

7.3 Supervisors’ Obligations:

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 Any officer in charge or manager
who receives reports on violating the provisions of this code or any financial or
legal related violations shall draw the attention of the legal or financial
department immediately upon receiving such report so that the said departments
in coordination with the management of Starlink and other competent
departments start investigating such alleged violations. Reports on all violations
and matters related to financial or legal violations shall be sent to the Board’s
verification committee immediately on discovering the same with a view to
verify the reality in three days time of discovering such violation depending on
the level and danger of the violation.

7.4 Penalizing whistle blowers:

Starlink shall not punish or threaten any worker who reports with good
intention any offence that contravenes this code or cooperate with any
investigation related to any related report whether or not such offence is proved
true. If a worker who submits the report is a party to such offence a suitable
disciplinary measure shall be taken for committing such offence. However on
taking such disciplinary procedures Starlink puts into consideration the
worker’s role in revealing the offence.

8. The Responsibility of Human Resources Management:

8.1 Novice Workers:

Every novice worker shall on joining work be provided with a copy of this code
of Starlink and shall sign in acknowledgment of reading and understanding the
same.

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 On appearance of or
reporting such conflict of interest the HRM shall inform the competent units
and departments with the aim to protect the code of any violation.

8.2 Obligation to inform on any potential conflict of interest:

The Human Resources management requires all employees to inform Starlink

management immediately upon becoming aware of any potential conflict of
interest.

Employee Signature :

Full Name : Edwin Gustavo Beltran Cardozo

Date : May the 26th 2022

CEO Signature :

Full Name : Noor E. Al-Sulaiti

Date : 27-Oct-2020

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