BUSINESS ETHICS POLICY

Policy Number: PO-PNC-DOC-02

Section 1 – Scope

This policy applies to all ContractsStrategic Procurement; the Procurement & Support Services employees and includes those, who, in anyway are involved in the procurement and contracting process.

Section 2 - General Policy Statement

In line with the Purchasing Policy, (PO-PNC-DOC-01), the Company upholds fairness in business dealing with all Tasnee Suppliers and values honest and upholds legal conduct in all business relationships. The company expects that all purchasing activities shall be conducted in a highly ethical manner.

Employees engaged by Tasnee in the procurement of materials and serviceshave significant influence over TASNEE’s reputation. Employee’s action in dealing with suppliers will have effect on how the company is viewed by suppliers. Every employee of the Contracts & Strategic Procurement Department; the Procurement & Support ServicesDepartment is therefore expected to:

a)Comply fully with all applicable laws or government regulations.

b)Demonstrate and encourage co-employees with an affirmative attitude concerning TASNEE’s business ethics policies.

c)Conduct business with only reputable suppliers who maintain a sound financial and high ethical standing that meet Tasnee expectations.

d)Demand that relationships with TASNEE’s suppliers be based on mutual respect, honesty and integrity.

e)No staff member is permitted to derive, directly or indirectly, any personal advantage from TASNEE purchases. The highest ethical standards must be observed at all times and the buyers should not put themselves in situations whereby it may construe that their objectivity is compromised.

f)Employees engaged in the procurement of materials and services must act fairly and objectively and in the best interests of TASNEE in conducting business with suppliers.

g) Staff involved in purchasing decisions that have outside interests which are in actual or apparent conflict with the interests of the Company, or who have close family members with such interests, must withdraw from participation in purchasing decisions so affected and must declare their interests to their manager and, as appropriate, under the Code of Conduct.

h)Report any business ethics violation to the appropriate Section Head and/or Manager.

Section 3 - Gift & Entertainment

a)TASNEE’s Purchasing Policy is to award business solely on the basis of best total value. Tasnee Employees are expected to decline any gift offered by supplier or by individuals representing the interest of a supplier in exchange for favor or solicit donation, gifts of any kinds or other financial favors. The only exceptions are gifts of nominal value that are readily viewed as advertising or promotional items and will not influence or interfere with decisions to award orders or performance of duties.

b)Any employee or supplier engaging in such activities or as suspected must be reported to his immediate Section Head or Manager.

Section 4 - Conflict of Interest

As provided under Section 13 of Purchasing Policy, an employee having procurement authority or in a position to influence the selection and/or management of a supplier as mentioned above shall:

a)Avoid or inhibit himself from participating in buying activities with any supplier in which he or a dependent member of his family or close relative has a management or financial interest.

b)Avoid and do not conduct personal business with a supplier.

It shall be made known to Tasnee Suppliers to take all necessary steps and precautions to prevent their employees or representative from making, offering gifts or any other consideration or advantage of any nature to any employee or representative of TASNEE, which could in any way, influence the award of business and results into conflict of interest.

Section 5 - Confidential Information

a)Confidential information includes pricing and cost data, bid or quotation information, formulas or process design information, supply sources, customer information and computer software programs. Employees should consult with their supervisor or manager prior to releasing confidential information to suppliers or other third parties.

b)Employees with buying functions are expected to develop and execute appropriate Non-Disclosure Agreements with suppliers when dealing with confidential information and should be part of the order documentation.

Section 6 - Competitive Bidding

Competitive bidding is utilized to obtain the best and competitive offers. It must be applied to promote fair and objective buying decisions. Information obtained from a competitive bidding must be safeguarded from unauthorized use and should not be shared nor revealed to other party except for the purpose of evaluating the technical acceptability of the offers. It is Tasnee Policy to:

a)Invite bids only from vendors that meet or exceed the technical and commercial requirements of the company;

b)Award contracts to the bidder offering the best total value;

c)Keep information provided by suppliers confidential and not share with competitors.

Section 7 - Employees Obligation

It is the responsibility of each and every employee of Tasnee to familiarize themselves with this policy. Any doubt about issues involving business conduct or any provision of this policy, employee should consult his immediate supervisor or manager for additional guidance.

This Policy is effective from 12.06.2011

This Policy is available at eDMS

Approved:

SALEH F. AL-NAZHA

President

Document Nr:PO-PNC-DOC-01 Revision: 01Tasnee Page 1 of 3

Change Request Nr: 2008-PROCMOC-0002

11/13/2018 11:05 PM