ETHICAL GUIDELINES
FORMS

KHAMIS BUAMIM INVESTMENTS (KBI) ETHICAL GUIDELINES

KBI has a set of values and ethical standards that are espoused by all of its collaborators (including all Collaborators, consultants, associates, advisors, counsels irrespectively as to whether bound by employment or services’ provision agreements). It is corporate policy to ensure that all activities are carried out in accordance with the highest standards of honesty, integrity and professionalism. These values and ethics enable KBI to remain worthy of the trust placed in it by its customers, Collaborators, shareholders, suppliers and all of its partners.

KBI introduced Ethical Guidelines setting forth the principles and standards, to be used as a basis for collaborators’ and associates’ conduct under all circumstances. The guidelines, which are summarized below, are not intended to replace or revise the laws and regulations in force, but to provide points of reference and guidance for the conduct of professional activities.

COMMERCIAL BEHAVIOR

Upholding the Law

In all the countries in which KBI operates, its collaborators must uphold the law. Care should be taken, as it may be difficult to understand the law in a legal and cultural environment that is very different than that in which the employee has previously worked. When there is a question or there is any doubt, the employee should immediately consult with a superior or the Legal Department.

Collaborators of a subsidiary jointly owned by KBI and a foreign company must uphold the law of the country in which the subsidiary is based, and the country or countries in which it operates and where its shareholders are based.

Integrity, honesty and transparency should guide each of the KBI collaborators in their work. Collaborators are expected to deal with customers, suppliers and other business partners in KBI’s interest and in compliance with laws and regulations.

All Collaborators must take particular care to uphold laws on competition, export and re-export control, labor and employment, safety, health and environmental protection.

Engaging in proper business practices
Zero tolerance of corruption

KBI and its Collaborators do not tolerate any form of corrupt practices, be they active or passive, direct or indirect, for the benefit of those in the public or private sector.

KBI applies all international conventions on combating corruption and the anti-corruption laws in force in the countries where they do business.

KBI and its Collaborators never use a third party to perform any task that they are ethically or legally forbidden to perform themselves. Engaging a third party for the purpose of bribing a natural person or a legal entity violates anti-corruption laws. Prior to entering any contractual relationship with a business partner, KBI must follow a methodical and documented procedure.

Complying with export laws

As a global company, KBI purchases services from a diverse group of suppliers. KBI also provides services to customers all over the world. It is therefore critical that KBI strictly complies with all applicable regulations that govern its export activities.

Before engaging in any export activity, KBI’s Collaborators must verify the eligibility of both the delivery location and the recipient. They must also obtain, when applicable, all required licenses and permits, including government authorizations and approvals for government-controlled products or technologies. These authorizations can be obtained from the relevant management in cooperation with KBI’s export control organization.

Competing fairly

As part of its commitment to fair competition, KBI must strictly comply with applicable competition laws in the countries where it does business. In general, these laws prohibit agreements or practices likely to restrain or alter competition. Examples of prohibited agreements include: price fixing, bid rigging, allocating markets, territories or clients amongst competitors, or boycotting or discriminating among certain customers or suppliers unless legally justified.

The exchange or disclosure of commercially sensitive information relating to competitors, customers or suppliers may also violate applicable laws.

Gifts and hospitality

Business courtesies, such as gifts and hospitality, given to or received from customers, suppliers and other partners are commonly used to build goodwill and acknowledge appreciation in business relationships. However, these courtesies must not exceed a nominal value and may not influence, or give the appearance of influencing, any business decision. Good judgment, discretion and prudence should always guide KBI in these situations. Business courtesies are prohibited by law under certain circumstances and in certain countries. KBI’s Collaborators must comply with the policies and laws that apply in each country where KBI does business.

Behavior towards customers

Each Collaborator must uphold the principles of fairness and integrity in his or her dealings with customers.

The business of KBI, to a large extent, concerns financial and cyber- safety; no compromise can be tolerated for any reason; any situation that may seem questionable to a Consultant must immediately be referred to an executive officer of KBI.

Relations with shareholders

KBI ensures that its shareholders receive, on a timely basis, and in an effective manner, complete, relevant, accurate and precise information that is consistent with previous published information. It takes particular care to implement international corporate governance standards and principles.

Relations with suppliers

KBI selects suppliers on the basis of objective criteria and demands high performance from them, in order to ensure that KBI’s expectations and those of its customers are fully met.

Under no circumstances will KBI use suppliers that make use of child or forced labor.

Integrity

Under no circumstances may Collaborators damage the reputation of KBI or compromise the integrity of its assets or its information systems.

Paid work of any kind that Collaborators may perform outside the scope of their employment with KBI must not cause conflicts of interest with their duties within KBI.

Similarly, considerable caution is required when purchasing shares, directly or via an intermediary, in companies doing business with KBI. Such restrictions do not apply to listed companies, unless confidential information is used which may be construed as insider trading.

Political and religious activities

KBI does not finance any political parties and any political activities must be carried out exclusively outside the work-place and working hours.

Any religious practices in which Collaborators may be involved must be practiced exclusively outside the work-place and working hours, except in the case of a legal obligation.

BEHAVIOR INSIDE THE COMPANY
Information control

Collaborators must ensure the protection of information acquired in the course of or in connection with the performance of his or her duties. Collaborators are to pay particular attention to respect the internal rules of protection and applicable requirements during both written and oral communication.

Protecting the confidential nature of certain information

In the course of their duties, all Collaborators have access to confidential information, which represents a key asset of the Company. Confidential or classified information is sensitive information which must not be disclosed or communicated outside the Company. Similarly, Company Collaborators may have information concerning the national security of the country in which the company is located. Care must therefore be taken to ensure that such information is protected from third parties.

Respect for other people

The safety and health of individuals are prime objectives for KBI.

The Company is an equal opportunity employer. Recruitment and promotion are based exclusively on professional qualities and performance. The Company respects the dignity and private life of each of its Collaborators. Furthermore, one of the Company’s key values is to create the necessary conditions for all Collaborators to achieve fulfillment in their chosen profession. The Company complies with the rules of protection of personal data known as the "Binding Corporate Rules" (BCR), applicable to the treatment and transfer of data outside of the European Union and the “General Data Protection Regulation” (GDPR) approved by the European Union.

Compliance with the Ethical Guidelines

Each Collaborator is required to review, understand and comply with these Ethical Guidelines.

In the event of a question or any doubt regarding appropriate conduct, it is the responsibility of the Collaobrator to immediately contact a superior or the Company’s Legal Department.

Each Collaborator has an affirmative obligation to comply with these Ethical Guidelines.

KHAMIS BUAMIM INVESTMENTS (KBI) ETHICAL GUIDELINES
KBI COMPLIANCE QUESTIONNAIRE