COMPANY’S POLICY

COMPANY’S POLICY

1. POLICY STATEMENT In keeping with the Code of Business Ethics and Professional Conduct Policy, MANAR ALFAYHAA Co.operates with a zero-tolerance policy towards bribery or any other form of corruption in its practices. Neither MANAR ALFAYHAA Co., nor any employee, person or entity associated with MANAR ALFAYHAA Co., shall offer, pay, promise, authorize or receive any bribes, other illicit payment or benefits to or from any person or entity with whom MANAR ALFAYHAA Co.conducts its business. This includes, but is not limited to government officials, clients, vendors, sub-contractors, suppliers, sub-consultants, partners, consultants or associates. MANAR ALFAYHAA Co.’s Board of Directors and Executive Management will set the example in fostering a culture of compliance with respect to this policy.

2. PURPOSE

The purpose of this policy is to give very clear guidelines on what constitutes bribery, and to distinguish bribery from accepted business practices for the promotion of MANAR ALFAYHAA Co..
3. SCOPE This policy applies to all officers and employees, temporary employees, agents, sub-contractors or sub-consultants of MANAR ALFAYHAA Co.whether employed in the parent company, branch office, subsidiary, joint venture or any other entity to which MANAR ALFAYHAA Co.belongs or is engaged.
4. DEFINITION Bribery: is committed when an inducement or reward is offered, promised, provided, accepted or solicited to gain any commercial, contractual, regulatory or personal advantage for MANAR ALFAYHAA Co., the employee or person or entity associated with MANAR ALFAYHAA Co..

5. RESPONSIBILITY

The Board of Directors holds primary responsibility for implementing this policy and for reporting on its compliance to the Board of Directors. The Board of Directors nominates the Chief Executive Officer (CEO) to be the care-taker of this policy, who in turn has delegated the responsibilities of managing compliance with this policy to MANAR ALFAYHAA Co.’s Compliance Officer. With the assistance of MANAR ALFAYHAA Co.’s Compliance Officer, all offices of MANAR ALFAYHAA Co. and its subsidiaries must establish appropriate mechanisms and procedures within their operations to prevent, detect, investigate and report any violations of MANAR ALFAYHAA Co.’s Anti-Corruption and Anti-Bribery Policy. All employees throughout MANAR ALFAYHAA Co., its branches, subsidiaries and joint ventures, are individually responsible to prevent, detect and report any violation of MANAR ALFAYHAA Co.’s Anti-Corruption and AntiBribery Policy and shall sign an Anti-Corruption and Anti-Bribery Undertaking and participate in regular Anti-Corruption and Anti-Bribery Compliance Training (as may be facilitated by MANAR ALFAYHAA Co.from time to time). Suitable channels of communication will be maintained for employees to seek guidance and to report confidentially any suspicion of corruption. The appropriate communication process is in the first instance to report to VP / MD and HRM, secondly VPHR / GC and finally the CEO. If any instance of bribery or corruption is identified, MANAR ALFAYHAA Co.will take immediate remedial steps in accordance with the MANAR ALFAYHAA Co. employee or project contracts and in compliance with prevailing laws.

COMPANY’S POLICY