GPIC Code of Conduct and Professional Ethics

Chairman’s Foreword

Gulf Petrochemical Industries Company is an industrial entity, distinguished by its institutional work, which follows the best practices applied around the world within our field.

Of course, the success of the company is not only based on the quality of its products, but also on the efforts of a professional team who work according to a system dominated by cooperation and respect. Whereby each individual is aware of the limits of their responsibilities and tasks, in addition to the values and principles that they must adhere to whilst conducting their company duties.

Just as in all large and successful entities, including that of our company, the interest and dedication to these principles and values is paramount. It gives me great pleasure to note that this guide sheds light on professional work ethics and behavior outside and inside the workplace, which should be adhered to at all times whilst performing duties, as well as when representing the company and dealing with others.

We are extremely proud of this pioneering industrial entity, and our partners; Bapco Energies in the Kingdom of Bahrain, SABIC AgriNutrients Investment Company in the Kingdom of Saudi Arabia and the Petrochemical Industries Company in the State of Kuwait. We have immense confidence in the ability of the company’s employees to continue achieving outstanding results through their professionalism and ethical behavior, as well as their integrity.

As we are all confident and well aware, they will continue to work on what they have always committed to in terms of work standards and behavior, in order to preserve the confidence of others within our developed company and to enhance and maintain its impeccable reputation amongst this strategic industry.

May God grant you success and direct your steps on the path of goodness.

Professionalism Integrity Caring

Teamwork

CEO’s Foreword

Gulf Petrochemical Industries Company - GPIC - has played a positive role in advancing development, progress and prosperity within the Kingdom of Bahrain, through its success in making optimal use of natural resources to manufacture its high-quality products, which are marketed within the largest global markets.

Behind the company’s success is a professional team that shows great care and commitment, not only to occupational health and safety standards, and to preserving the environment, but who is also keen on applying behavioral and ethical principles based on the values of integrity, teamwork and care for the health and safety of others.

Accordingly, we as the company’s management, have been keen to collect all these principles in this publication to be a reference for all members of the work team and an available guide for professional behavior that should be taken into account in all circumstances and times.

The Gulf Petrochemical Industries Company’s Professional Conduct Guide provides an overview of the standards of honesty, integrity and ethical behavior expected from all employees working within the company, as well as anyone associated with the company in any other shape or form.

Therefore, I cordially invite and encourage everyone to read this guide, kindly absorb its contents until you understand it well, adhere to it and work in accordance with all the principles and values contained within it, especially since integrity and business ethics are the foundation of how we build and conduct all our business.

I am fully confident that you will abide by the rules of professional and ethical conduct contained in this guide, at all times and occasions, in a way that guarantees the protection and preservation of our company’s leading reputation in the field of values and ethical commitment.

Engineer Yasser Abdul Rahim Al Abbasi CEO

Code of Ethics

Conduct and Professional

professional conduct?

The Code of Conduct defines the minimum behavior expected of any person who represents or works for Gulf Petrochemical Industries Company (GPIC) and the group of supplier companies involved in the manufacturing of goods or performance of services with regard to their responsibility towards society, the environment and individuals.

In the Gulf Petrochemical Industries Company, we are committed to the ten principles of the United Nations Global Compact, which guide us in performing our work within the framework of ethical standards, while adhering to the highest values of citizenship. The name “GPIC” should always be associated with respect for human rights and the provision of a healthy work environment and appropriate social and environmental conditions. Through this guide to the rules of professional conduct and professional ethics, we seek to shed light on the manner in which we expect our employees, contractors and other third parties to abide by whilst conducting business on behalf of the company.

How do these rules work?

These rules demonstrate GPIC’s commitment to integrity in everything it does, and it applies to everyone who works for or represents the company, including employees seconded from third parties.

These rules are an integral part of the documents that link the company with the people working in it, whether these documents are appointment decisions or employment contracts. The commitment of those who work for GPIC to the rules of professional conduct begins from the date of joining the company, whether through contracting, or by undertaking work, assignment or appointment, and until the date of the termination of that relationship.

All types of leave, work assignments inside and outside the Kingdom, or training and study missions do not preclude compliance with these rules during that period, bearing in mind that any violation of these rules may lead to the imposition of disciplinary penalties that may range from warning to termination of service. As for third parties, such as; suppliers and business partners, any violation of the Code of Conduct will lead to severance of the relationship with GPIC and/or legal action.

As a condition of doing business with GPIC, we expect our suppliers to comply with these requirements, as well as being subject to national and international environmental standards and regulations.

GPIC intends to give this Code of Conduct a spirit of constructive dialogue and partnership with suppliers. If GPIC becomes aware of or suspects incidents of non-compliance with this manual, and informs the supplier of this, it expects the supplier to investigate and correct incidents of non-compliance as soon as possible, within an agreed timeframe. In the event that the supplier is not ready to rectify these incidents, the company reserves the right to take appropriate legal action.

How do we abide by the responsibility?

Each of us are individually responsible for understanding and complying with these rules, and this is achieved by:

 Read these rules thoroughly until fully understood.

 Always seek advice for any uncertainty or further clarification that may be required.

 Follow good judgment and common sense.

When you are faced with a difficult situation, ask the following questions:

 Does it sound right?

 Do you think it aligns with our other codes, values and policies?

 Does it serve the interest of your co-workers, the company and society?

 Would you be pleased to announce your behavior in front of everyone?

 Are you ready to face accountability for your actions?

If your answer to any of these questions is NO - STOP that action immediately and if you are not sure, speak to your Line Manager or Compliance Officer.

1- Compliance with Laws and Internal Company Policies

Compliance with all applicable laws, regulations and policies, whether locally or internationally, is fundamental to how we conduct our business. Gulf Petrochemical Industries Company will not accept any violation of applicable laws. In the event of a discrepancy between the legal requirements and the provisions of this guide, we seek to apply the highest ethical standards whilst always complying with the provisions of the law. It is the responsibility of each individual to familiarize themselves with all GPIC policies and procedures that apply to all, and to ensure they comply with them.

Whoever works for GPIC must exhibit the highest levels of behavior and wisdom in accordance with the rules of law and professional conduct. They must also abide by all applicable laws, regulations and regulatory controls in this regard, and be aware of the applicable regulations before starting any work with third parties, especially those related to confidentiality, disclosure, purchase and sale of products and services, and antibribery systems.

Tips and Advice

You should:

Show fairness and respect in your dealings in accordance with the law, rules of conduct and internal policies of the company.

Consider the general principles of law and human rights in dealing with employees, contractors and partners.

Report cases of child employment, forced labor, or inhumane treatment of workers in our sites or those who carry out work related to our company to the supervisor, manager or human resources department.

If you are conducting work that may be governed by international legal systems, or has points of contact across international borders, you need to ensure that you and your team are aware of and fully compliant with the laws, regulations and restrictions in this regard.

Avoid:

Tolerance of discrimination or racism of all kinds.

Ignoring internal laws and policies that apply to your employees and your business. Using suppliers without ensuring that they comply with the requirements of the law and the goals of human rights protection.

Complacency in reporting cases of violation of the law and company policies.

2- Occupational Safety and Health and the Environment

Gulf Petrochemical Industries Company is committed to carrying out its work in a sound environment without the occurrence of accidents, which could whereby result in any loss of life and property, or hinder operation and production.

Gulf Petrochemical Industries Company is fully committed and dedicated to carrying out its work in a safe, healthy and environmentally friendly manner, whereby the welfare of all employees is paramount and at the forefront of all that we do, as we continue to strive towards ensuring there is no loss of life or property, or hindrance to operations and production.

The company is constantly working on applying the highest standards of environmental protection, occupational health and safety in all stages of its business from design, construction, operation and maintenance, and also during the shutdown and production stages. Accordingly, the company is keen on the following:

 Establishing an environmental, health and safety management system to set and review targets.

 Periodically evaluating environmental, health and safety risks in all the company’s facilities, and then treating and reviewing them periodically.

 Introducing contractors, suppliers, workers, and everyone who has an interest in the company with this policy.

Training employees, and providing them with the resources, tools and expertise necessary to maintain their job efficiency.

Compliance with legal and regulatory requirements, internal standards and any other controls approved by the company.

 Ensuring the safe operation of the company’s facilities.

Tips and Advice

You should:

Ensure proper understanding of environmental protection, occupational health and safety requirements before starting work.

Identify, assess and take steps to control health and safety risks associated with your business. Immediately stop any work that appears to be unsafe or risky.

Use the necessary Personal Protective Equipment (PPE) for the task at hand, and also encourage others to do so.

Handle and dispose of all materials properly, safely and legally.

Report any accident, injury, illness, unsafe or unhealthy condition, or material release to your supervisor or manager so that appropriate action can be taken Pay attention to all health and safety complaints or warnings .

Avoid:

Carrying out work unless you are fully trained in this field, or specialized and medically fit to do so.

Practicing work under the influence of alcohol or psychotropic substances.

Tolerance of threats, intimidation or violence at work. Bringing any of the prohibited materials into the company’s factories.

Assuming that someone else will report a potentially dangerous situation and dependence on others.

Carrying out work that may affect the environment, unless you are trained to do so and in accordance with the applicable controls to reduce environmental impacts.

Involving suppliers or contractors in joint ventures without an assessment that takes into account environmental and societal impacts, risks, controls and their performance.

3- Harassment and Bullying

Every individual working for the company deserves the necessary level of respectful and treatment of decency, regardless of their grade or position. The company calls on its employees to act with caution, as behaviors that may be acceptable in some cultures are not necessarily acceptable in others. Therefore, any action involving the belittling, insulting or diminution of one’s reputation, dignity or character of any of the company’s employees is strictly prohibited.

This includes, but is not limited to: spreading lies and malicious rumors, insulting and slandering, bullying, verbal and sexual harassment, violating freedom and personal information.

Tips and Advice

You should:

Treat everyone with respect and dignity in line with our values.

Be wise in dealing with others and taking into account the cultural considerations of others.

Encourage behavior aimed at creating a work environment free from harassment and inconvenience.

Avoid:

Behaving in an aggressive, insulting, intimidating or humiliating manner.

Mocking or making comments about someone’s race, gender, affiliation, religion, age, physical appearance or disability.

Assuming that your acceptable behaviors are acceptable to all cultures and people.

4- Narcotics and Psychotropic Substances

The worker must perform their duties with full awareness and away from all forms of psychotropic substances, and it is prohibited to have in their possession, trade or use narcotic drugs, alcohol or any kind of psychotropic substances whilst on company premises. It is also prohibited to have consumed any of these substances whilst representing and performing work duties outside of the company premises.

GPIC reserves the right to conduct drug, alcohol and psychotropic drug tests on its employees and contractors as required by law and company policy.

The company also prohibits smoking outside of the designated areas in order to preserve the safety of facilities and workers.

Tips and Advice

You should:

Perform the work entrusted to you with mental presence and full readiness.

Inform the Supervisor or Manager of any work related violation.

Follow professional advice if you are taking prescribed medications or receiving medical treatment that could affect your ability to do your job safely.

Consult your Supervisor, your direct Manager, or the company’s Medical Clinic if you have doubts about your fitness or ability to do the work.

Maintain the safety of others and be prepared to report any suspicious persons or activities.

Avoid:

Performing company business whilst under the influence of alcohol or any kind of psychotropic substances.

Using or serving alcohol to others on the company premises.

Smoking on company premises, with the exception of the permitted designated smoking areas.

Avoid the use of drugs and psychotropic substances throughout the period of your work in the company, whether inside or outside the company premises.

5- Protection of Commercial Information and Personal Data

The company is committed to all laws that provide for the protection of information, whether it is information, trade secrets or personal data, and it respects the privacy of all individuals or commercial entities working for it.

It considers the actions of the company’s employees outside the framework of work not of its interest, unless these actions affect the company’s interests, impair its business performance, or threaten its reputation.

The company seeks to obtain the personal information of those working for it through legitimate means, and uses it to comply with all legal requirements, and does not allow third parties to view it except with the knowledge of the person concerned and within the limits of the law or as dictated by the nature of the work.

Employees are advised to keep their personal data and documents away from the company’s business environment, its electronic media or its circulation using the company’s wired and wireless lines.

Tips and Advice

You should:

Comply with all legal requirements in collecting, using, storing or disclosing employee personal data.

The use of personal data for the purposes necessary to perform the work only. Use personal data in a manner consistent with the purpose for which it was collected. Take the necessary care to protect personal data from risks such as loss, damage, unauthorized access or illegal disclosure of personal information.

Avoid:

Accessing employee personal data unless you have prior permission and a specific and clear business need.

Trading, falsifying or disclosing employee personal data to anyone inside or outside the company without obtaining prior approval.

Saving and sharing employee’s personal and private data on the company’s devices or using its wireless network.

6- Conflict of Interests

Conflict of interest arises when someone who works for the company is asked to express an opinion, take a decision or act in the interest of the company and at the same time, they have either an interest related directly or indirectly to the opinion they are required to express. It could also be towards the action they are required to take, or obligation towards a party other than the company relating to this opinion, decision or action.

Conflict of interest cases involve a violation of confidentiality, abuse of trust, personal gain and disloyalty to the company. Therefore, whoever works for GPIC must perform the company’s business and obligations towards it independently and free of any potential conflict between the company’s interests and their personal interests, and present the company’s interest in business and its services over any other interest.

Whereby they must also avoid their personal interest conflicting with any of the interests of the company and must disclose to the company, in writing, any actual or potential “interest” whether directly or indirectly and not engage in a case that involves an interest without obtaining the required prior written consent.

The company’s employment contracts, in general, prohibits any association of its employees with other work with external parties or volunteer work with NGOs or any other parties. Consequently, the company strictly applies this clause, as every employee who violates this clause is subject to disciplinary measures being applied, including termination of their service with the company.

The following represents the most common Conflicts of Interest:

 Being associated with another business that would cause an actual or potential conflict with the interests of the company.

 Investing with a current or potential competitor or with any of the company’s suppliers, contractors, consultants, or clients, in which they have a substantial interest.

 Dealing with parties related to the company in a way that creates a direct interest or benefit between those who work for the company or one of the contracting parties with the company.

 Loyalty to relatives in that whoever works for the company has a role in making the decision to contract the company with a commercial establishment belonging to a relative of theirs, or that they have administrative authority over a relative working in the company.

 Participating in a business, providing a service or becoming a member of a Board of Directors or a Committee in a competing establishment or competing with the company’s business.

 Representing others before the company in transactions in which the company is a party, or using the company’s assets and properties for personal interest.

Tips and Advice

You should:

Conduct all business relationships in a professional and transparent manner.

Avoid commercial dealings and personal relationships that cause or may cause a conflict of interest (actual or potential) or appear to be a conflict of interest.

Consult your Supervisor or Manager in writing regarding any outside activities, financial interests or relationships that could lead to your involvement in an actual or potential conflict of interest.

Obtain the appropriate approval before accepting board membership in any other company or institution.

Exercise discretion when deciding to give or accept gifts, hospitality or entertainment and obtain necessary approval when required.

Apologize for making any company decisions that is in your interest or seen as affecting your ability to make an objective decision and fulfill your responsibilities towards GPIC.

Avoid:

Hiring, promoting or directly supervising a relative, whether in the company or with its contractors, unless you obtain prior approval.

Providing gifts, hospitality or entertainment or accepting any of that from legal personalities or from an individual involved in a bid or tender with GPIC.

Requesting a personal gift, hospitality, or anything of value from a supplier, customer, or partner, including all direct requests, giving the impression that the provision of a gift, hospitality, or something of value would be appropriate or desirable.

Misuse of company resources or exploiting the position to achieve personal interest or encouraging or assisting any third party.

7- Gifts, Hospitality and Entertainment

Gifts offered by a customer of the company to someone who works for the company, their family or others, at their request, may cause an actual or potential conflict of interest.

The company prohibits those who work for it from accepting a valuable or insignificant material or intangible gift. The company considers this an actual conflict and a breach of trust, whenever presented in a way, which prevents the individual from performing their assigned duties, claiming their competence to do so, or exceeds the permissible value.

The company prohibits those who work for it from accepting any privileges (such as; granting free hotel accommodation or discounts on products or services for the individual, their family, or whoever they may have requested).

Hospitality and entertainment provided by a client of the company to an employee working for the company, his family or others, at their request, may cause an actual or potential conflict of interest.

Hospitality is considered as an actual conflict if it is regularly repeated or done so in an unusual or extravagant manner.

Entertainment is also considered as an actual conflict if it is unusual, or if it is presented independent of the official relationship with the company and the invitee does not participate in the public event themselves.

Compliments:

GPIC maintains good working relations with business partners and seeks to develop and prosper them. Accepting or offering courtesies is an expression of good intentions,

taking into account that such courtesies do not impose certain obligations on the company or embarrass its employees. Those who work for GPIC must be wise in rejecting courtesies that may not be accepted. Submitted in good faith or those that involve suspicion of any legal risks and in the event that the employee is not sure of their authenticity, they must seek advice from the Compliance Department.

Tips and Advice

You should:

Disclose any gifts, hospitality or entertainment that has been accepted, refused or returned.

Only accept gifts, hospitality and entertainment that comply with GPIC standards and applicable laws and regulations.

Evaluate the potential for a conflict of interest when accepting gifts, hospitality or entertainment.

Politely and willingly decline any offer that is not in line with company standards.

Avoid:

Accepting gifts, hospitality, entertainment or other courtesies from anyone participating in a tender with GPIC.

Requesting a gift, hospitality or entertainment of any kind from a supplier, customer, partner or other party doing business for GPIC is in violation of the conflict of interest policy.

Keeping any gift or accepting hospitality or entertainment above the approved value permitted by the Conflict of Interest Policy and the rules of professional conduct.

Accepting personal discounts or other benefits from suppliers, service providers, customers or other third parties, as a result of your association with GPIC that are not available to the general public.

8- Anti Corruption

GPIC is committed to what was stated in the National Strategy; to protect integrity, combat corruption and battle against all types of corruption, which arise from the practice of improper behavior that is contrary to laws, legislation or policies of company procedures and objectivity. This results in a clear and intentional conflict with the interests of the company, and that this results in an interest, whether material or moral.

Among the most prominent features of corruption are the following:

Violation of the Company’s Funds and Rights:

It includes every violation or misuse of the company’s funds that are in the employee’s possession and disposition, whether by fraud, embezzlement, breach of trust, squandering, wasting, or whether by neglecting funds through maintenance, unauthorized spending or spending them in other ways other than what the funds were actually allocated for, whether it be directly or indirectly.

Bribery and Abuse of Influence and Power:

Whoever works for GPIC is considered to have taken a bribe if they do the following:

 A request for themselves or for others, or accepts or takes a promise or gift to perform, abstain, or fail to do any of their job duties, or claim that it is one of their job duties, even if this work is lawful, or to reward them for what they did, even if it was an unlawful prior agreement.

 They breach their duties of their position by performing an action or refraining from performing an action of that position as a result of a request, recommendation or mediation.

 Asking for themselves or for another or accepting or taking a promise or gift to use real or purported influence to obtain or attempt to obtain from any authority an action, order, decision, obligation, license or supply agreement for a job, service or advantage of any type.

 A request for themselves or for others, or accepting or taking a promise or gift because of their job to follow up on a transaction related to the company.

Tips and Advice

You should:

Obtain the required prior approval before making an offer, promise or giving of anything of value, including sponsorships, community donations and social development projects. Obtain the required prior approval before entering into any partnership and after conducting due diligence and as directed. Ensure that all expenses are accurately recorded.

Immediately report any suspicions of corruption in order for the appropriate action to be taken.

Avoid:

Authorizing, undertaking or participating in schemes that grant illegal benefits, bribery or secret commission to any person.

Making an offer, promise, or giving of cash or cash equivalents of any kind to a government official.

Creation of a hidden or incorrectly registered fund for blocked payments.

Personally making a gift or hospitality purchase, or other items of value, in order to avoid complying with GPIC’s standards and procedures.

9- Media Statements

The media statements are limited to persons and departments authorized in writing to do so, and it is prohibited to make a media statement on behalf of the company, or to present an offer of the company’s policy or information without obtaining the company’s prior written approval and according to the approved policies and procedures.

Any written or oral communication made on behalf of GPIC is considered as public disclosure, therefore, it is forbidden for anyone working for the company to deal and directly communicate with the media. It is also forbidden to talk on behalf of the company without a license, or to communicate with investors of the company without a license and outside the framework of the concerned departments.

Dealing with GPIC social media accounts is governed by a document dealing with social media rules that regulate the controls for participation in various social networks, forums, groups, and digital encyclopedias such as Wikipedia.

Tips and Advice

You should:

Review the rules governing who has the authority to authorize the name of GPIC. Refer media inquiries and investment inquiries to Investor Relations immediately.

Report lost or stolen GPIC information (for example, your laptop computer or your briefcase) to your Manager immediately.

Avoid:

Disclosing information to the public, including the media, unless you are authorized to do so.

Hiding facts or deleting information that may be relevant to disclosure.

Using any of GPIC’s trademarks in external communications, including social networks (an hashtags).

Sharing comments about GPIC or photos of work sites, operations and activities on social media.

10- Political and Volunteer Activity

GPIC avoids entering or engaging in any political activity, domestically or internationally, and does not make any such contributions, whether directly or indirectly.

The company also respects the right of its employees to engage in voluntary and political activity in their own time, using their own resources, bearing in mind that any political affiliation must be expressed. However, it is not permissible for the individual to express it as an opinion or point of view of GPIC’s.

The controls of these participations take into account the policy of practicing foreign business, including but not limited to (membership of bodies and councils, voluntary and organizational work in all its forms, joining civil society institutions, or non-governmental organizations and institutions).

Tips and Advice

You should:

Take permission from the company’s management before engaging in any voluntary or political work.

Do not collect any donations or run advertising campaigns for any third party on the company’s websites or premises.

GPIC’s reputation and how the public views and perceives your actions are taken into account when dealing with engaging in any business with third parties.

Avoid:

Engaging in voluntary or political activities during or outside working hours without obtaining prior permission from the company’s management.

Using or allowing others to use any GPIC assets or resources for any political campaign or posting and distributing flyers and political slogans within the company’s websites.

Using your position at GPIC in an attempt to influence another person to make any contributions to provide support to any third party.

GPIC encourages everyone who works for the company to report any concerns related to unethical behavior, behavior in violation of laws, or any suspicious activities by adopting a policy of “reporting waste” through the available communication channels with the company’s compliance officials, through direct communication with the company’s compliance officials. Or through the commitment page on the company’s website, or by phone or fax designated to receive communications.

The reporting person must cooperate with the company by providing correct information that guides the company to conduct appropriate investigations regarding violations or concerns related to breaching the rules of professional conduct, and taking into account good faith in raising all doubts related to noncompliance and not charging accusations without proof.

Encouraging GPIC to report legal violations or erroneous behavior stems from its commitment to integrity entrusted to those who work for the company, so that the company does not accept any negligence in compliance or deliberate silence on violations. The company considers failure to report, as solidarity with the violator because the obligation to report is a responsibility of individuality of everyone.

GPIC makes every reasonable effort to protect the reported information, and to provide complete confidentiality and appropriate protection for any person who reports in good faith, the existence of a legal or ethical violation against any harm resulting from the reporting.

Therefore, employees must avoid malicious complaints and false reports and cooperate with the compliance team by stating what they have in the facts they are looking for testimonies and data to verify the complaint.

For any other inquiries or to submit complaints and suggestions, please contact the following channels:

Contact Data:

Manager/ Superintendent

Human Resources Department

Phone:+973 17733321

Legal Advisor

Phone:+973 17733844

Email: ethics@gpic.net

Acknowledgement

I acknowledge that I have read and received a copy of the Code of Conduct and Professional Ethics of the Company, and confirm my commitment to what is stated therein and to all future amendments.

Name : ............................................................................

Employee # : .................................................................

Job Title: .........................................................................

Date : ...............................................................................

Signature : .....................................................................