Message from the Chief Executive Introduction 1. Valuing All People 2. Safety, Health and Environment 3. Corporate Social Responsibility

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2 Message from the Chef Executve 4 Introducton 5 1. Valung ll People Respect and Non-Harassment Far Treatment and Equal Opportunty 8 2. Safety, Health and Envronment Polcy and Commtment Substance buse Corporate Socal Responsblty Respect for the Law Communty and Poltcal Relatons Ethcal Busness Conflcts of Interest Brbery and Corrupton Gfts and Entertanment Protectng our ssets aganst Fraud, Theft and Msuse ccurate Reportng Informaton and Confdentalty Confdental Informaton Representng lba, and Contact wth the Meda Use of Informaton Technology

3 Message from the Chef Executve Dear Colleagues, We are all proud of lba s natonal and nternatonal reputaton as one of the leadng smelters n the world, manufacturng the hghest qualty products n a safe and responsble way. The methods we employ to attan these results are as mportant as the results themselves. Great companes are bult on trust. For lba to contnue on ts successful journey, we need the trust and confdence of our employees, customers, partners, nvestors, and the communtes and socety n whch we work and lve. Trust s earned through the demonstraton of consstently hgh standards of behavour and care. It takes tme and effort to buld, but can be destroyed n an nstant through carelessness or a lapse n ntegrty. t lba, we beleve n upholdng the hghest standards of ethcal and professonal behavour n everythng we do. Ths Code of Conduct outlnes We beleve n upholdng the hghest standards of ethcal and professonal behavour n everythng we do the behavour expected of each of us n relaton to our employment. It enshrnes our shared belefs n the basc prncples of honesty, farness, ntegrty and respect for people. We must all promote trust, openness, teamwork, professonalsm and prde n what we do. We wll conduct our busness n a safe, ethcal, professonal, envronmentally sustanable and socally responsble manner. To accomplsh these objectves, we need the loyalty and support of all our employees. Ths code provdes each of us wth a set of basc gudelnes desgned to prevent actons that may reflect badly on the employee or on the organsaton. Snce t s mpossble to descrbe every possble stuaton, employees must use ther judgement so that ther conduct conforms to the ntent and the sprt of ths code. If you suspect that ths Code has been volated, then report t. lba wll not tolerate retalaton aganst those who rase concerns n good fath. s lba employees, we are expected to revew ths code perodcally and apply ts prncples to our daly work wth complete understandng and complance. Introducton Ths Code of Conduct apples to employees and others workng on behalf of lumnum Bahran B.S.C. (lba). By workng for lba, you are agreeng to comply wth ths code. Its purpose s to provde a set of expectatons and gudelnes to all those workng for lba, to ensure that we always uphold the hghest standards of ntegrty and personal conduct n our busness and professonal actvtes, and when dealng wth colleagues, vendors, customers, contractors, government agences and the publc. ny breaches of ths code are unacceptable and may result n dscplnary acton up to and ncludng dsmssal, for those that volate the code, and for those who cover up or hde volatons. In addton, those gulty of msconduct may be subject to legal acton n the case of any breach of law. Ths Code of Conduct s desgned to supplement, not replace, the exstng lba personnel polcy. Ths Code and our Busness Partners Employees must not use a contractor, agent or other thrd party to perform any act whch conflcts wth ths code. Employees who engage thrd partes to work on lba s behalf should ensure that these partes are made aware of the code and should seek ther co-operaton n adherng to the code. You must report any breaches or nconsstent behavour by thrd partes whle they are workng for lba. The dutes of employees who supervse others Employees who have responsbltes to supervse others should: Promote and encourage complance and ethcs by ther own example. Make sure that those who report to them understand ths code. Enforce the code consstently by holdng employees accountable for exhbtng the proper behavours, and reportng any breaches of the code. Support employees who, n good fath, rase questons or concerns by () encouragng employees to report concerns, () addressng concerns that are rased and () ensurng that employees who rase concerns are not subject to retalaton. Tm Murray Chef Executve Offcer 4 5

4 Every employee should feel secure n rasng concerns wthout fear Share Your Concerns It s very common for employees to have concerns about what s happenng at work. Usually these concerns are easly explaned and the ssues resolved. However, t can be dffcult to know what to do. You have a duty to report any breaches or potental breaches of ths code when you become aware of them whether these relate to your own department or others. If you are n any doubt about whether to speak up, ask yourself these smple questons: 1) Is t legal? 2) Does t comply wth ths code and other lba polces? 3) What would my colleagues, manager or famly thnk about ths? 4) How would ths look reported n the newspaper? 5) Does t feel rght? Where do I go for help? Your lne supervsor or manager s usually a good place to start wth a concern. You may also get help or advce from a member of lba s Integrty Task Force, whch conssts of the, Chef Internal udtor, the Chef dmnstraton Offcer and the Legal Manager. However, f you feel uncomfortable usng one of these resources, you may also contact Integrty Lne, as descrbed below, at any tme. Retalaton wll not be tolerated Every employee should feel secure n seekng advce and n rasng concerns. lba wll not tolerate retalaton aganst those who rase concerns n good fath, even f the concern turns out to be unfounded. Ths assurance s not extended to someone who malcously rases a matter he/she knows s untrue. llegatons of retalaton wll be nvestgated, and employees or managers who harass, or retalate aganst those that have rased concerns n good fath wll be subject to dscplnary acton. Retalaton can take many forms, ncludng reducng pay, damagng career opportuntes, ssung dscplne, threatenng or bullyng, etc, n order to punsh someone for reportng a concern or to deter hm/her from reportng a concern. lba s Integrty Lne If you ever feel uncomfortable speakng to others drectly, lba has also mplemented a reportng help lne through whch lba employees, contractors and commercal partners can report n confdence any breaches of lba s Code of Conduct, such as fnancal rregulartes, frauds and other matters that could potentally prove damagng to the company. It s called Integrty Lne, and s operated by an ndependent company that helps busnesses respond to concerns about complance and ethcs. Please note that ths procedure should not be used to report safety, envronmental or securty accdents, ncdents or emergences these should be reported mmedately under other lba procedures. Employee-related grevances are also more approprately handled through the grevance procedure admnstered by HR. The Integrty Lne s desgned to operate on a confdental bass. You should feel free to rase concerns n good fath wthout fear of losng your job or sufferng any form of retrbuton as a result. You can even make your report anonymously. However, we would prefer that you provde your name and contact nformaton, and we assure you that these detals wll be kept absolutely confdental. You can support your report wth documentary evdences and references, whch can be attached to your report on the webste. Callng the Integrty Lne by phone To call from Bahran on an outsde lne dal or t the prompt, dal (toll-free). To call from outsde Bahran, dal Onlne To make a report onlne, go to: Ths webste lnk s also provded on lba s Intranet ste and on ts external webste at: 6 7

5 1. Valung ll People 1.1. Respect and Non-Harassment 1.2 Far Treatment and Equal Opportunty Respect t lba, we respect the belefs and relgous practces of people of all faths. It s the responsblty of each employee to honour and respect the rght of others to practce ther relgous belefs n freedom. Interference wth these rghts and freedoms s a volaton of the Bahran law and ths code. Employees are permtted to wear relgous clothng or jewellery, but out of respect for the belefs of others, employees should refran from dstrbutng or promnently dsplayng relgous materals or symbols n the workplace or at company premses. lba affrms the prncples contaned n the Unted Natons Charter, and n the Unversal Declaraton of Human Rghts. Non-harassment lba seeks to provde a work envronment that s pleasant, healthy, comfortable and free from ntmdaton, hostlty or other offensve behavours towards employees, contractors, vendors or customers. Harassment of any sort, ncludng sexual, verbal, physcal or vsual, s strctly prohbted. The makng of false accusatons and defamatory statements, or derogatory statements about a person s colour, relgon, gender, age, natonal orgn, sexual orentaton, gender dentty or dsablty, whether verbal or wrtten, s also strctly prohbted, as s the dsplayng or dstrbuton of offensve or derogatory materal. If you beleve that you may have been subjected to harassment, you should mmedately report the occurrence to the HR Manager, or to your lne manager, f ths would be more comfortable for you. ll complants wll be treated confdentally and wll be promptly nvestgated. lba s polcy s to provde equal employment opportunty n conformance wth all applcable laws and regulatons to ndvduals who are qualfed to perform a partcular job. We admnster our personnel polces, programmes and practces n a non-dscrmnatory manner n all aspects of the employment relatonshp, ncludng recrutment, hrng, work assgnment, promoton, transfer, termnaton, benefts and salary admnstraton and selecton for tranng. Our employees are lba s greatest assets. s such, all decsons that drectly affect an employee s employment status wll be far and equtable. Ths manfests tself n three ways: 1) dvancement wll be on the bass of mert and performance. Clear and consstent crtera wll be appled to canddates for vacant posts and the most capable wll be promoted. 2) Development s an essental aspect for all lba employees. lba seeks to provde an envronment for mprovng your qualfcatons and sklls n lne wth your employment poston and responsbltes, and lba s polces and plans. 3) The Dscplnary Process wll always be far and equtable. If you are a party to a dscplnary revew, you wll have the opportunty to forward your case or grevance to the HR Department. You wll be consdered nnocent of any alleged volaton unless found otherwse. t all tmes, you wll be kept fully aware of your rghts and optons and wll have access to an appeals process f found to be n volaton. Dscplnary actons wll be prescrbed accordng to lba s Dscplnary Procedure and Gude. Please refer to ths procedure or contact the HR Department for any addtonal nformaton. Employees that have no responsbltes for formulatng or decdng on company polces have the rght to jon any of the lba s labour unons. lba s commtted to the elmnaton of all forms of forced and compulsory labour, and the abolton of chld labour abuse. My boss sometmes acts n a way that makes me feel uncomfortable askng me out for drnks, askng me about very prvate nformaton, or tellng sexual jokes. What should I do? If your boss s behavour s unwelcome to you and you don t feel comfortable dscussng ths wth hm or her drectly, you can rase the ssue and seek practcal support from HR, who wll treat your complant as confdentally as possble whle takng steps to stop the offensve behavours. You can also use the Integrty Lne. job that s openng n my department requres a lot of travel tme. I ve receved an applcaton from someone who s well qualfed, but I am thnkng of crossng her off the lst for ntervewng as I know that she s a mother wth chldren stll at school, and would therefore fnd t dffcult to travel. For more nformaton on ths area, see the HR polces and gudelnes posted on the ntranet, or speak wth your representatve n HR. You cannot make that assumpton. pplcants should be judged on mert, and on whether they have the best sklls, qualfcatons and experence to do the job. You cannot deny her the opportunty to be consdered, or prejudce her applcaton based on any other factor. My manager met wth me yesterday and told me I needed to mprove my performance and attendance, or I wll receve a poor ncrement, and may also face dscplnary acton. I dsagree wth hs assessment of my performance and was qute ntmdated that he threatened my job securty. Is ths a volaton of the Code of Conduct? Managers are expected to manage employee performance and to gve employees honest feedback to ensure employees have the best opportunty to realse ther full potental. Provdng they are done n a respectful way (avodng abusve language), such conversatons would not be consdered a volaton of the Code of Conduct. You should dscuss the stuaton wth your manager and HR representatve so you can fully understand ther reasons for concern and ther expectatons. lba s polcy s to provde equal employment opportunty n conformance wth all applcable laws 8 9

6 2. Safety, Health and Envronment 2.1 Polcy and Commtment Our aspratons are smple: to acheve zero njures and work-related llnesses, and to ensure the protecton of the envronment wherever we conduct our busness. We are commtted to provdng a safe, healthy, productve and comfortable workng envronment for our employees. ll SHE prncples, procedures and practces establshed and documented n the lba SHE Management System must be followed at all tmes. Improvng safety behavour s our top prorty. Everyone s accountable for ther own safety and no one can be nstructed to work unsafely. Unsafe behavour by anyone s not acceptable, as workng safely s a condton of employment. Smply obeyng safety rules s not enough. lba s commtment to safety means that each of us needs to be alert to safety rsks as we go about our jobs. You have a duty to report any accdent, ncdent, or unsafe act or condton that you observe, and to cooperate n any nvestgaton. 2.2 Substance buse You are expected to be n sutable mental and physcal condton whle at work for the effectve and safe performance of your dutes. The use or possesson of any mood-alterng substance (such as alcohol, non-prescrpton or llegal drugs) at the workplace, or on lbaowned or leased busness premses s strctly prohbted, as s the performance of work dutes under the nfluence of these substances. lba reserves the rght to search anyone on lba premses for any of those tems, and to requre employees to submt to medcal testng where there s cause to suspect the use of these substances. We are commtted to provdng a safe, healthy, productve and comfortable workng envronment for our employees Wll I be penalzed f I stop work because I have concerns about the safety of the actvty? t lba, we are commtted to provdng a safe place of work for everyone that ncludes stoppng work f we ever have concerns about safety. lba wll not tolerate retalaton aganst anyone who n good fath stops work that he/she consders to be unsafe t s better to be safe than sorry. One of my colleagues njured hs hand durng hs shft, and t looks qute bad. I overheard the supervsor quetly suggestng that he goes to see a prvate hosptal, and not report t to medcal, as we are just short of achevng a mlestone n our department s safety performance, and ths would mess t up for the team. What should I do? My shoes are damaged, and I have been told that I can only get one par of shoes per year. Can I replace them even though I ve only had them for 6 months? t lba, we have an oblgaton to provde adequate PPE for our employees, and therefore, any damaged PPE must be adequately repared or replaced. I am a mantenance techncan and there s an urgent request to start a job, wthout obtanng a requred permt. Should I go ahead? No. Permt to Work s a necessary requrement for all applcable jobs, whether they are routne, non-routne or emergency. Make sure that a safe envronment s provded before startng the job. ll njures need to be promptly reported to the lne manager, the SHE department, and Medcal. Ths ensures that reportng requrements are met, that correctve actons are dentfed, and that the rsks of accdents reoccurrng are reduced. Speak to your lne manager. If an accdent s stll not reported, you can report your concern va the Integrty Lne. For more nformaton on ths subject, speak to your coordnator n the SHE department, or see the Safety, Health and Envronmental polces and gudelnes located on the lba ntranet

7 3. Corporate Socal Responsblty 3.1 Respect for the Law The responsblty of every one of us s to understand and obey all the laws and regulatons applcable to our role, and report any occurrences or crcumstances that may have legal mplcatons to the lba Legal Manager. You are also requred to obey the laws of other countres when travellng on busness trps or tranng courses. Employees dealng wth mports and exports should ensure that our practces are complant wth the regulatons of the relevant countres, and wth applcable nternatonal trade controls. Employees dealng wth customers should ensure that our practces don t abuse a domnant market poston, and are complant wth competton laws n applcable countres. Never talk wth or exchange nformaton wth compettors to: Fx prces charged to customers or prces pad to supplers ths can nclude settng mnmum or maxmum prces, the amount or tmng of a prce ncrease, or any dscusson or agreement that results n prce coordnaton. Fx terms related to prce, prcng formulas, credt terms, etc. Dvde up markets, customers or terrtores. Rg a compettve bddng process. Employees, partcularly those n Procurement, Fnance and Marketng, should ensure that our practces do not contravene nternatonal Money Launderng regulatons, and should undertake approprate due dlgence enqures regardng counterpartes wth whom funds are exchanged. Be wary of rregulartes n the way payments are made or requested, and avod dealng wth counterparts wth known or suspected crmnal tes, or who appear to lack ntegrty n ther operatons. The responsblty of every one of us s to understand and obey all the laws and regulatons applcable to our role For more nformaton on ths area, speak to the Legal Manager. representatve at another alumnum smelter called me and suggested that we dvde up and ratonalze the market for products we both supply n Europe, by not competng wth each-other n certan countres for certan products. Ths seems to make sense the last thng we need s a prce war. Ths would be classed as ant-compettve behavour, and may have serous legal consequences. You must mmedately speak to the Legal Manager about the conversaton. 3.2 Communty and Poltcal Relatons We recognse that we have an mportant role to play n the welfare of socety and that we have a responsblty to communcate, partcpate and cooperate wth local authortes and wth non-governmental organsatons nterested n the welfare of the socety. We encourage all our employees to accept ths responsblty and take part n dscussons and actvtes desgned to solve communty problems n the best nterest of socety and lba. In dong so, employees should ensure that they do not appear to be actng as spokespeople for lba unless they have pror permsson from lba. Employees as ndvdual ctzens should mantan good relatonshps wth socety, ncludng partcpatng effectvely n professonal socetes, lcensed chartes and communty centres. s an employee, you have the rght to voluntarly partcpate n the poltcal process, and attend poltcal meetngs n your personal capacty, n your personal tme, and wthn the constrants of Bahran law. No one at lba may requre you to contrbute to, support or oppose any poltcal group or canddate. You may not, however, work on, or promote a poltcal campagn durng offcal workng hours, on lba-owned or leased property, or by usng lba-owned or leased assets or systems such as computers, prnters, photocopers, and electronc mal. You should not dsplay or dstrbute poltcal materal n the workplace or on company property. For more nformaton on ths area, speak wth your representatves n the Publc Relatons or Human Resources departments

8 4. Ethcal Busness 4.1 Conflcts of Interest When an employee s personal, socal, fnancal or poltcal actvtes have the potental to nterfere wth, or appear to nterfere wth, the employee s loyalty and objectvty towards lba, a conflct of nterest may exst that must be satsfactorly resolved. We all have a responsblty to always work n lba s best nterests and therefore must avod stuatons and actons that may consttute, or create the appearance of a conflct of nterest. ll potental conflcts must be reported to your lne manager n wrtng as soon as they arse. The smple act of dsclosng the possblty of a conflct of nterest and abdng by the nstructons of your lne manager n that respect release you from the rsk of losng the trust placed n you to act n lba s best nterests. Falure to dsclose a conflct may lead to dscplnary acton. Whle t s dffcult to dentfy all crcumstances leadng to conflcts of nterests, the followng are examples thereof: Holdng (ether drectly, or through a relatve such as a spouse, sblng, parent, chld, uncle, aunt, nephew, nece, grandparent, grandchld or parent- or sblng-n-law), a substantal fnancal nterest n any enterprse wth whch lba has busness dealngs, or s consderng establshng busness dealngs (e.g. supplers, contractors, vendors, compettors, customers and lcensees). substantal nterest s one that mght nfluence or appear to nfluence your judgment; cceptng, drectly or ndrectly, from any vendor or suppler of servces, any gfts or entertanment that are descrbed as napproprate n the Gfts and Entertanment secton of ths code; ctng as a drector, offcer or employee of any non-afflated busness or other nsttuton wth whch lba has a busness relatonshp; Drectng a busness opportunty from lba for your personal nterest; Usng lba assets (e.g. statonery, letterhead, funds, facltes, equpment, tools, personnel) or lba specfc techncal nformaton or expertse for the beneft of other busness or personal nterests; Engagng n outsde actvtes that may adversely affect your mpartalty or judgement or that may nterfere wth or adversely affect your ablty to perform your offcal dutes. For more nformaton on ths area, speak wth a member of lba s Integrty Task Force. lba regularly employs relatves of current employees. relatve should however, not have any busness dealngs wth you, or wth anyone who reports to you. In addton, you should never be n a stuaton where you have the ablty to hre, supervse, affect terms and condtons of employment, or nfluence the management of a relatve. Exceptons requre specfc approval by your lne manager. Never nvest n a current or prospectve suppler f you have any nvolvement n the selecton or assessment of, or negotatons wth, the suppler, or f you supervse anyone who has such responsblty. Never nvest n a customer f you are responsble for dealngs wth that customer or supervse anyone wth such responsblty. We all have a responsblty to work n lba s best nterests and therefore must avod stuatons and actons that may consttute, or create a conflct of nterest Outsde Employment lba s employment contracts generally prohbt employment of ts employees at any other organzaton, except for pro bono work at regstered chartable organsatons. Employees wshng to carry on a prvate enterprse should promptly nform ther lne manager and HR. HR wll grant no objecton letters where t s clear that no potental conflcts exst, and the enterprse wll not affect the ablty of the employee to fulfl hs or her job. Employees and contractors should not use lba workng hours or resources to conduct any prvate enterprse. My brother s a manager for one of our supplers. In my job at lba, I also have contact wth that company from tme to tme, and am thnkng of askng them to quote on a job. Is ths a problem? These crcumstances must be brought to the attenton of your lne manager. It s mportant that all actual or potental conflcts be dsclosed so that any ssues can be antcpated and avoded. I am an employee of lba, and am also nvolved n a famly busness that I beleve can offer servces to lba. We would lke to regster on lba s vendor lst. Do I need to dsclose my relatonshp durng regstraton? Yes, you have to dsclose your relatonshp to your lne manager, HR and the Procurement & Warehousng Department

9 4.2 Brbery and Corrupton Corrupton s any abuse of an offcal poston for personal gan. Brbery s a form of corrupton, and s the offerng, gvng, recevng or solctng of any tem of value to mproperly nfluence the actons or decsons of an offcal or other person wth offcal dutes. Many countres have laws that enable them to crmnally prosecute acts of brbery even when they are commtted outsde ther own countres. We wll not engage n Brbery or Corrupton n any form. You should not offer or ask for anythng of value, ncludng any servce, gft, job or entertanment, and you should not accept any gfts, brbe or anythng of value, whether drectly or ndrectly from any person, n order to mproperly nfluence offcal acts and decsons or to obtan or mantan any prvlege to any company or person. The above prohbton ncludes payments made to offcals to secure or speed up routne legal government actons, such as ssung permts, vsas or releasng goods held n customs, unless these payments are made n accordance wth an offcal prcng lst of the government department. ny nstances of brbery or attempted brbery should be reported to your lne manager, and to the Chef Internal udtor. You should not allow any thrd partes actng on behalf of lba to contravene any of the above. If you have any reason to suspect that agents may be contravenng the above, you should remnd them of lba s polcy as stated here, nsst on ther complance, and report any suspected contraventons. 16 We wll not engage n Brbery or Corrupton n any form For more nformaton on ths area, speak wth a member of lba s Integrty Task Force. We need to get a key pece of equpment through customs quckly. I was told that I could hre a consultant wth contacts to speed up gettng all the permts we need. He requested BD 5000 upfront to use to help smooth the way. Snce we don't really know where the money s gong, do we have to worry about t? Yes, you do have to worry about t. You must fnd out where that money s gong and for what purpose t s beng used, to ensure that ths money s not used as a brbe. The fact that t s beng done by someone else, and that we have no evdence of a brbe s no excuse. Seek the advce of your lne manager or lba Internal udt or Legal mmedately. I m n the process of negotatng a good deal for lba. The other party has ndcated that t would help fnalse the deal f we made a chartable donaton to a cultural organsaton as a good gesture. I ve never heard of the charty he s proposng. Can I go ahead? No. Ths could be a vehcle for brbery, and you should report the request to your lne manager. Donatons can only be made by lba s Publc Relatons Department. 4.3 Gfts and Entertanment Gfts ncludes anythng of value, provded to an ndvdual or members of ther famly, ncludng cash and non-cash tems such as art work, equpment, preferental dscounts, loans, favorable terms on any product or servce, servces, przes, donatons, transportaton, use of vehcles or of vacaton facltes, securtes, partcpaton n stock offerngs, home mprovements, tckets to recreatonal, cultural or sports events, and gft certfcates. Courtesy Entertanment ncludes meals, nvtatons to attend recreatonal, cultural or sports events, and any assocated travel, accommodaton, meals and refreshments. In prncple, there s nothng wrong wth recevng or gvng gfts of apprecaton or goodwll. However gfts or entertanment of sgnfcant value, or n certan crcumstances, can create a conflct of nterest, or at least the appearance of a conflct, whch could tarnsh the company s reputaton. Gfts and entertanment valued at less than BD 50, and of a promotonal nature endorsed wth a corporate logo such as calendars, dares, pen sets and calculators can be accepted, wthout the need to declare them, provded they are not ncluded n the restrctons set out below. If any gft or entertanment valued at over BD 50 or the local currency equvalent, s offered to you by any person connected wth an outsde organsaton, wth any connecton to your job, you must mmedately declare t to your lne manager and manager n wrtng, even f the gft or entertanment s refused. If you are n any doubt about whether the tem s below BD 50 n value, you should declare t. You are prohbted from offerng or acceptng any gft or entertanment of any amount to or from anyone connected wth an outsde organsaton, government department, or anyone else wth whom lba has or may be n the process of developng a busness relatonshp wth, where: the gvng of such a gft or entertanment volates the polces or country laws governng ether party. (specal care must be taken when dealng wth government offcals as some countres do not allow offcals to accept even low value gfts or entertanment). the ntent could be, (or appear to be) to create mproper nfluence, or to nfluence the recpent s objectvty n makng a busness decson. the gft or entertanment nvolves partes engaged n a tender or compettve bddng process. (busness meals may be acceptable, provded that all of the other requrements of ths secton are met). the gft or entertanment s solcted, or s offered for somethng n return. the gft s n cash, or a cash equvalent. the gft or entertanment s ndecent, sexually orented, or otherwse mght adversely affect lba s reputaton. ny gfts or entertanment offered by or to another party, whch together are valued at more than BD 500 n any one year, must be approved n advance by a Chef Executve Offcer. It s acceptable to receve a gft above ths lmt f t would be nsultng to declne t, and provded that t s not ncluded n the above prohbtons, but the gft must be reported to lne management who wll decde whether t can be kept for the beneft of lba, sold, wth the proceeds donated to charty, or returned to the donor. 17 For more nformaton on ths area, speak wth a member of lba s Integrty Task Force.

10 4.4 Protectng our ssets aganst Fraud, Theft and Msuse We wll at all tmes act honestly and wth ntegrty, and safeguard those of lba s assets and resources for whch we are responsble. Msuse of ssets You are responsble for ensurng that lba property that you use or come nto contact wth as part of your work s not damaged, msused or wasted. You also have a duty of care to report the abuse of lba property by others. Fraud and Theft Fraud and theft are volatons of the law and of ths Code. lba vews fraud as an extremely serous matter and s commtted to the promoton of an ant-fraud culture throughout the organsaton. Protect lba s funds as you would your own: guardng aganst msuse, loss, fraud or theft. Ensure that all transactons are properly authorsed and accurately and completely recorded. Types of fraud and theft nclude but are not lmted to: sgnng, cancellng, creatng, destroyng or amendng documents by fraudulent means. assumng a false name or capacty. dsposng of property wthout beng authorsed by ts owner. makng false clams to qualfcatons and experence. msappropraton of funds or assets, e.g. budget or expenses ncludng petty cash etc. delberate msnterpretaton of nformaton. unauthorsed use of lba or contractor manpower, vehcles and equpment. attempts to conceal any of the above. Reportng fraud or theft You have a duty to report detals mmedately f you suspect that a fraud has been commtted or see any suspcous acts or events. These should be reported to your lne manager (unless you feel uncomfortable dong so), and to a member of the Integrty Task Force (ITF) The ITF s comprsed of the Chef Internal udtor, the Chef dmnstraton Offcer and the Manager of Legal and s responsble for oversght of any reported or suspected fraud. Whenever a fraud s reported or suspected, the ITF wll assess whether an nvestgaton s warranted, and wll determne who wll lead the nvestgaton. You should co-operate fully wth whoever s conductng nternal checks, revews or fraud nvestgatons. lba wll not tolerate retalaton aganst those that rase concerns n good fath, even f the concern turns out to be unfounded. If you feel uncomfortable communcatng wth any of the above, you can use the Integrty Lne reportng system descrbed n ths code. Your dentty wll be kept n confdence and wll not be dsclosed wthout your consent. We wll all tmes act honestly and wth ntegrty, and safeguard those of lba s assets and resources for whch we are responsble 4.5 ccurate Reportng ll nformaton that lba employees create, whether fnancal or non-fnancal, and whether paper or electronc, must accurately reflect transactons and events. Fnancal data (e.g., books, records and accounts) must conform to Internatonal Fnancal Reportng Standards, and other relevant Generally ccepted ccountng Standards. Never make a false or msleadng entry n a report, document, record or expense clam. In the event that estmaton s requred to be ncluded whle recordng transactons, best judgment should be used n conjuncton wth adherence to IFRS gudelnes. Make sure that other nformaton (e.g., Safety, Health or Envronmental performance, HR records, qualty data, regulatory flngs and other essental company nformaton) must also be accurate. Co-operate fully wth Internal udt, provdng them wth accurate nformaton and, on request, allow them unrestrcted access to employees and documents. t the same tme ensure that the confdental nformaton secton of ths Code s compled wth, by ensurng that no unauthorsed access or nformaton s provded to any thrd party that has no jursdcton. If you are asked to provde nformaton n connecton wth a government or regulatory agency enqury or nvestgaton, you must make sure that any nformaton you provde s truthful and accurate, and that lba s legtmate nterests are protected. Seek advce from the lba Legal Manager f you are uncertan regardng a non-routne request. It s the last week n the quarterly reportng perod. My boss wants to make sure we meet our numbers for the quarter, so he asked me to record an unconfrmed sale now that won t be fnalzed untl next week. I guess ths won t hurt anyone should I do what he says? No. Costs and revenues must be recorded n the correct tme perod as requred by the matchng prncple n IFRS. If the sale s not yet complete, t would be a msrepresentaton and could amount to fraud to nclude t n an earler perod

11 5. Informaton & Confdentalty 5.1 Confdental Informaton Many of our employees have been placed n postons of trust n whch they are exposed to or have access to employee payroll data, personnel records, vendor and servce contracts, operatonal data, lcence agreements, fnancal nformaton and other types of senstve nformaton that s consdered confdental or personal n nature. Protectng our Knowledge It s vtal to control the flow of data and nformaton from wthn lba, and to protect and mantan the knowledge that we have. Delberate msuse of lba s knowledge for personal gan or for the beneft of a compettor s a serous breach of ths code. Whether you are a current or former employee, you are remnded of the covenants of confdentalty n your employment contract, and that revealng any type of confdental or senstve nformaton s a volaton of that trust. If you have any questons or doubts about what s consdered confdental nformaton or may consttute a volaton of trust, you are urged to seek advce from your lne manager. Current and former employees may not release any communcatons, documents or nformaton that could n any way be consdered as senstve wthout pror wrtten approval from lba. Personal Informaton Many countres have strngent rules restrctng the sharng or transfer of personal data relatng to employees, customers and other ndvduals. ccordngly, when sharng personal nformaton wth those outsde lba, you must obtan pror authorsaton to do so from your supervsor or the company s management. In order to ensure the accuracy and objectvty of nformaton concernng current or former employees, you are requred to refer any calls or wrtten requests to release nformaton such as personnel, medcal and other records, to the HR Department. ny employee who reveals or releases nformaton about a current or former employee wthout specfc authorsaton wll be subject to dscplnary acton. Informaton s to be retaned and dsposed of, n accordance wth lba s document retenton polcy. For more nformaton on ths area, see the IT and HR polces and gudelnes located on the lba ntranet, or speak to your representatves n those departments. Copyrghts or Confdental Informaton of others Do not brng to lba any confdental documents, ncludng computer records, from pror employers, or share nformaton relatng to pror employers that s confdental. Do not knowngly nfrnge a vald ntellectual property rght of another party. Insder Tradng Tradng n shares on the bass of nsder nformaton (materal nformaton not avalable to the publc, such as major nvestment decsons, contracts, exposures, ncdents, or fnancal results) s llegal. Do not trade n the shares of lba or any other company on the bass of nsder nformaton, and do not dsclose nsde nformaton to anyone outsde the company wthout pror approval. If you thnk you may have nsder nformaton, speak to the Legal Manager about requrements that may apply to you, before tradng n shares

12 5.2 Representng lba, and contact wth the meda lba seeks to develop a postve relatonshp wth members of the meda, government offcals, communty leaders and busness partners. To ensure consstent communcatons wth all our key external audences, t s crtcal that these communcatons are managed n a coordnated way. ll publc relatons actvtes and contact wth the meda and senor government offcals must be handled only by or wth the approval of the Chef Executve Offcer. You must be careful to dstngush between speakng personally, and n an offcal capacty on behalf of lba. If you do not have explct authorty to make statements to the meda and you receve enqures from a meda representatve, you must make no comment other than to refer the meda representatve to the Publc Relatons Department. Formal speakng engagements on behalf of the company must be cleared by your Chef, n consultaton wth the Publc Relatons Department. 5.3 Use of Informaton Technology The IT system belongs to the company, and should be used solely for lba s purposes. In gvng employees and authorsed contractors access to systems and technology, we expect these employees and contractors to be responsble n ts use. You must comply wth lba s Computer Usage, and other IT polces, and be careful not to be nvolved n unauthorsed actons such as: ccessng or attemptng to access data or fles of others held on ther PCs or drectores. Tamperng wth software or hardware. Illegal downloadng or copyng of copyrghted software. Releasng of confdental data or sharng of confdental nformaton wth others. ttemptng to ntrude or hack nto lba s computers or PCs. Unauthorsed use, sharng or dsclosure of user ID s and passwords. You should be aware that lba may montor computer use, ncludng emal, and data stored n personal and other folders, to verfy complance wth ts computer users polces. ny volatons wll be subject to dscplnary acton. For more nformaton on ths area, speak wth a member of the Publc Relatons Department. For more nformaton on ths area, see the IT polces and gudelnes located on the lba ntranet, or speak wth your representatve n the IT department

13 sk before actng: 1) Is t legal? 2) Does t comply wth ths code and other lba polces? 3) What would my colleagues, manager or famly thnk about ths? 4) How would ths look reported n the newspaper? 5) Does t feel rght? Where can I go for help? Speakng wth your lne manager s always a good place to start. You can also speak wth a member of the Integrty Task Force, whch conssts of: The Chef Internal udtor The Chef dmnstraton Offcer The Legal Manager If you would prefer, you can also make use of Integrty Lne, where you can report n full confdentalty Callng the Integrty Lne by phone To call from Bahran on an outsde lne dal or t the prompt, dal (toll-free). To call from outsde Bahran, dal Onlne To make a report onlne, go to: Ths webste lnk s also provded on lba s Intranet ste and on ts external webste at: