Code of conduct & business ethics

From Chief Executive Officer.

Suhail Al Mazroui Group (SMG) demands and maintains the highest ethical standards in carrying out its business activities. This is necessary because SMG’s image is reflected by the people who work for the group. SMG can only build and grow on solid foundations of integrity and strong ethics.

This Code describes the principles of SMG’s business ethics and is intended to assist all employees in meeting high standards of personal and professional integrity required of them. The Code applies to everyone who works for or with SMG, whether as employee, director, consultant, officer, contractor (and their subcontractors) or any other business partner.

Our ethics policy is straightforward: everyone working for or with SMG must uphold the highest standards of business integrity and ethics in the conduct of all Company activity, complying with both the spirit and letter of all applicable laws and regulations. SMG’s employees are expected to avoid any action or behavior which could create even the perception that such behavior is unethical, illegal or otherwise improper.

Irrespective of an employee’s position within SMG, he or she is involved in the business process including decision-making that affects SMG and other employees. It can sometimes be difficult to discern if a certain course of action will result in contravention of the provision of the Code. Also, certain situations may arise which may not be covered in our Code of Conduct. If there is any doubt as to whether a certain action is in compliance with the Code or any other SMG policy, it is expected that an employee will err on the side of caution and discuss the issue with his or her manager. If you have any questions concerning the legality of an action or the meaning of the Code, you should contact SMG’s HR and Legal Department.

I am certain that as a team we will uphold the highest ethical standards.

Thank you,

Rashed Suhail Helal Al Mazroui

Group Chief Executive Officer

Suhail Al Mazroui Group.