We are fully committed to our customers.

The business environment is more competitive and the regulatory demands more complicated than ever before. We’ve set out our commitment to meet these demands in our Code of Business Conduct (‘Code’).The Code does not cover every situation, nor does it set forth every applicable rule of law.

Company policies and practices, as well as good common sense and judgment, influence our conduct.

Beyader shares a set of core values:

• Honesty
• Integrity
• Respect

These values portray the most fundamental elements of our current and future success. We firmly believe in the importance of trust, openness, teamwork and professionalism, as well as pride in what we do. We believe this Code presents an effective balance of short- and long-term interests and the integrationof economic, environmental and social considerations in business decision making.

The purpose of this Code is to:

1. Describe the standards of behavior and business conduct that govern each of Beyader’s operating units.
2. Guide key company policies and principles that control and guide our business.
3. Guide the resolution of difficult questions about business conduct.
4. Guide the way our employees, customers, shareholders, communities, vendors and competitors, and government should relate to each other.

The Code applies to officers, directors and all full-time, part-time, temporary and contract employees of Beyader Construction Company WLL. We also expect our suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners, if any, to behave in the ethical manner described in the Code when working for Beyader.

The Code is a statement of principles, a reference point and a guide. It provides a summary of certain key Company policies, as well as laws applicable to the Company wherever we do business.

Beyader Construction Company WLL does not tolerate any activity that could result in actual or perceived conflicts of interest. Conflicts can arise both when individuals personally benefit or gain and when other persons (including their family members), or organizations with which they have ties, stand to gain.Individuals must not, for the purpose of gaining any advantage for themselves or a person related to them:

1. Disclose or use confidential information.
2. Benefit from a situation or from their position at the Company.
3. Attempt to influence the Company’s negotiations.
4. Favor certain customers or suppliers of the Company.
5. Have an ownership interest in a supplier, customer or another enterprise in business with the Company.

Individuals are expected to act with integrity and competence in all their dealings with Beyader’s customers. Specifically, we will not:

1. Make false or unsubstantiated representations about the quality or value of our services.
2. Disclose the confidential information of our customers.
3. Attempt to influence their decisions with inappropriately expensive gifts or gratuities.

Company employees are expected to be honest and fair in all business interactions withsuppliers, including contractors, consultants and other agents. We expect our suppliers to be aware of and abide by our Code of Conduct and will not knowingly use suppliers who operate in violation of applicable laws or regulations.

Where relevant, suppliers receiving Beyader’s confidential information should commit toconfidentiality obligations in a written agreement, agreeable to the Senior Management of the Company, and which is in line with the principles established in the Code and relevant Company policies and procedures.

Beyader Construction Company WLL actively competes within its marketplace in an ethical and legitimate manner. The Company and its employees do not associate or participate in illegal competitive practices, nor do they disparage Beyader’s competitors and their services.

Beyader Construction Company WLL purchases products and services on the basis ofquality, price and reliability and expect our customers to obtain our products and services on the same basis.

Our employees are instructed not to accept gifts and to avoid even the perception that giving or receiving gifts is connected in any way with favorable treatment.

For the purposes of the Code ‘gifts and entertainment’ includes gifts, trips, services, entertainment and any other gratuitous item, event, benefit or thing of value.

If individuals within the Company are involved in decisions to donate Company assets, including money, goods-in-kind or services, they must disclose any personal benefit that they or their family members may receive as a result.

Company proprietary information must not be disclosed to others, except as required by law or under circumstances permitted by the Company. Individuals within Beyader must not seek to release or disclose the Company’s or our client’s and other relevant parties’ proprietary information.

We do not engage in unethical or illegal means to obtain confidential information or proprietary data belonging to others.

We expect our officers, directors and all full-time, part-time, temporary and contract employees, as well as suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners, if any, to safeguard the security of the Company’s assets and those of our suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners (among others). ‘Assets’ may be physical or intellectual and include equipment, buildings, tools, funds, accounts, supplies, computer programs, information technology, documents, know-how, data, patents, trademarks, copyrights, and any other resources or property of the Company.

Confidential information includes information, whether oral, written, electronic or otherwise, that is prepared by or for Beyader or information from any customers, vendors, suppliers, contractors or third party obtained in confidence under a non-disclosure obligation.

We have an obligation to respect and preserve such information unless disclosure is specifically authorized or legally required.

We create documents and records in the normal course of business. All entries in the Company’s books, records and accounts must be complete, accurate, fairly reflect our business transactions, conform to applicable accounting standards and legal requirements, and be maintained in full compliance with company policy and the law.

Activities such as embezzlement, money laundering and holding “off the books” cash or slush funds are strictly prohibited.

Many Company employees have access to non-public or “inside” information about Beyader or other companies that is not available to people outside the Company. Company policy prohibits employees and contractors from using such information for personal gain.

Beyader Construction Company WLL believes in free and fair markets. We compete in a legal and ethical manner on the basis of the quality of our services. Fair competition violations include mutual understandings with competitors to control prices, boycott certain suppliers or customers, engage in bid-rigging, or allocate products, territories or markets.

We are committed to compliance with fair competition and anti-trust laws that apply in the markets in which we operate.

Corruption is any abuse of an official position for personal gain. Bribery is a form of corruption. Our employees are forbidden from offering, soliciting or accepting a bribe in any form and must not permit any third parties acting on behalf of Beyader to do so.

We purchase all equipment, supplies and services on the basis of merit, treating suppliers, vendors and subcontractors fairly and without discrimination, except in cases where the procurement process dictates that we give preference to certain groups for socioeconomic purposes.

Beyader Construction Company WLL adheres to respective policies and procedures which address such requirements as professional conduct, confidentiality, qualification of bidders and negotiations.

Subject to the applicable laws, Beyader offers equal employment opportunity to qualified individuals and does not discriminate on the basis of gender, pregnancy status, race, religion, age, disability, physical appearance, sexual orientation, nationality, political opinion or social or ethnic origin.

These policies apply not only to hiring decisions but to all terms and conditions of employment.

Beyader Construction Company WLL prohibits the use, sale, transfer, purchase or possession of alcohol and controlled substances in the workplace. Such behavior is a violation of the law and inconsistent with the Company’s goals

Beyader Construction Company WLL enters into various business relationships with third parties to further our business objectives. We ensure that all such parties are reputable, qualified and agree to comply with applicable laws and the business practices reflected in the Code.

Such relationships include those with joint venture corporations, partnerships, project- specificconsortium relationships and third-party professionals such as sales representatives, agents and consultants.

Maintaining the high quality of our projects and products is critical to Beyader’s success. We have a responsibility to assure product compliance for the work we undertake as well as our supervision of our suppliers, our vendors and our subcontractors.

Our primary focus is to achieve a quality product, ethically, safely, on time, and in budget.

Beyader operates in strict compliance with the laws, rules and regulations applicable in the State of Kuwait, including but not limited to the labor, taxation and anti-corruption laws.

We maintain responsible for understanding and complying with the details of and avoiding any action that would cause the violation of all applicable laws, rules and regulations.

Beyader Construction Company WLL is committed to high standards of integrity and to act responsibly and ethically in compliance, not only with this Code, but also with internationally accepted laws, rules and regulations and principles. Beyader shall and expects its contractors, consultants, agents and suppliers to abide by the following principles in all dealings with and on behalf of the Company.

• Comply with all legal requirements and rules relevant to conditions of employment and respect and safeguard worker’s rights.
• Not to engage those under 18 years of age in employment, unless the law prescribes a higher limit.
• Not to use forced labor, including prison labor, indentured labor, bonded labor or any other form of forced labor.
• Provide all employees with the legal minimum wage or the prevailing industry wage (whichever is higher), as well as other benefits that are required by law or labor contract.
• Adopt responsible measures to mitigate the impacts that the workplace has on the environment and will comply with applicable country environmental regulations and laws.
• Treat every employee with respect and dignity and maintain a workplace free from physical, sexual, psychological or verbal harassment or abuse.