Our reputation, and the trust and confidence of those with whom we deal, are among our most vital corporate resources. We are committed to conducting our affairs in a uniformly ethical manner and pursuant to a standard of fundamental honesty and fair dealing. This standard requires adherence to all laws, regulations and normal ethical practices that apply to our business activities, including adherence to official working hours and appropriate business attire. We expect all employees to act in the highest integrity and to report violation of law or policies to the Compliance Officer. You should obey all lawful instructions given by KPC or by any person duly authorized to do so.

• Knowingly holding, or having a relative such as a spouse, sibling, parent, child, uncle, aunt, nephew, niece, grandparent, grandchild or parent- or sibling-in-law who holds, a substantial financial interest in any enterprise with which KPC has business dealings (e.g., suppliers, contractors, vendors, customers and licensees);

• Knowingly holding, or having such a relative who holds, a substantial financial interest in any enterprise in which KPC has an investment;

• Accepting, directly or indirectly, from any vendor or supplier of services any vacations, cash payment, service, loan (except from financial institutions) or discount (except those offered generally to KPC employees) or other items reasonably seen to be inducements by you or any of your relatives of the first or second degree;

• Acting as a director, officer or employee of any non-affiliated business or other institution with which KPC has a business relationship;

• Directing a business opportunity from KPC for your personal interest;

• Using KPC assets (e.g., stationery, letterhead, funds, facilities, equipment, tools, personnel or job-related know-how) for the benefit of other business or personal interests; and • Engaging in outside activities that may adversely affect your impartiality or judgment or that may interfere with or adversely affect your ability to perform your official duties.

Corruption is any abuse of an official position for personal gain. Bribery is a form of corruption. You must not offer, solicit or accept a bribe in any form and not permit any third parties acting on behalf of KPC to do so. You may not accept any gift, payment or bribe, or anything else of value, whether directly or indirectly, from any person for the purpose of influencing an official act or decision, or to obtain, retain or direct business to any company or person.

In principle, there is nothing wrong with receiving or giving gifts of appreciation of nominal value and of a promotional nature endorsed with a corporate logo such as calendars, diaries, pen sets and calculators. However, if you receive any gift valued at over KD100 or the local currency equivalent or any lesser amount stipulated in your local policy, you must declare the same to your supervisor.

You are also prohibited from offering any gift to anyone employed by an outside organization, government department, or anyone else with whom KPC has or may be in the process of developing a business relationship where the giving of such a gift violates the regulations issued by your company or the laws governing the recipient.

Generally, KPC’s employment contracts prohibit any employment outside KPC, except pro bono work at registered charitable organizations. Accordingly, we will strictly enforce this provision and any employee who violates this prohibition will be subject to disciplinary action, including termination of employment.

We recognize, however, that some KPC companies’ employment contracts may permit outside employment by employees so long as it does not interfere with an employee’s official duties. In those cases, you are advised that outside employment could give rise to a conflict of interest with respect to your continued employment. Therefore, if your company permits outside employment, you must obtain written approval from your Managing Director (or the manager to whom he has delegated that responsibility) before accepting any supplemental job. You must also notify your supervisor if your duties in outside employment change significantly.

In either case, you must devote all official working time to work duties and not engage in any other duties without permission from the Personnel Department.

Fraud and theft are violations of the law and of this Code of Conduct. Types of fraud and theft include but are not limited to:

• Falsifying contractual issues such as receipts, charges, quantities, quality, etc.;

• Falsifying qualifications and experience;

• Misappropriation of funds;

• Deliberate misinterpretation of information;

• Unauthorized use of contractor manpower, vehicles and equipment; and

• Misuse of budget funding, including petty cash, vouchers etc.

You should seek advice from your supervisor or the Compliance Officer before entering into an activity that could be construed as fraud or theft.