Code of Ethics and Business Conduct

    Halfaya Code of Ethics and Business Conduct (“Code”), together with Ethics in Procurement, Complaint Reporting Form and Gift and Entertainment Registration Form, are designed to promote our core business value and enhancing corporate governance. The key objectives of this Code are:

• Promote a culture of transparency and accountability within the company and uphold the observance of good corporate governance practices;
• Enhance the awareness of business ethics at all levels of the employees;
• Encourage employees to conduct themselves in a manner which reflect the highest business standards;
• Encourage all improper, unethical or inappropriate behavior to be timely identified and managed;
• Provide guidance and channels for those who intent to report concerns and/or complaints.

    Each Halfaya employee is required to attend the ethics and business conduct training sessions provided by Internal Control & Audit Department and complete annual self-assessment.

1. Introduction to the Code

    The Code is intended to demonstrate the absolute commitment of Halfaya to the highest standards of ethics and compliance, to ensure adherence with all applicable laws, regulations, corporate rules and policies, and help to timely detect and correct any failures to eliminate misconduct and other wrongdoings.

    It is applicable to all Halfaya’s employees, assignees and trainees at all levels including management.

2. Ethics in Procurement

    Employees having procurement authority shall be charged with the higher standards of loyalty and discretion. In this case, in addition to complying with the Code, procurement personnel must also follow supplemented policies and practices set out in Ethics for Procurement.

    This Ethics in Procurement applies to all staff work in the Contract, Procurement and Logistics (CPL) Department, tender evaluation team members, and those who directly involved or have influence in procurement process.

3. Complaint Reporting Form

    Halfaya encourages staff to raise concerns regarding any ethical issue/misconduct related to work. If any staff believes that another staff has violated, or about to violate, the Code, corporate policies or procedures, or applicable law relevant to work, they shall follow the below steps:

• Discuss and report your concern to the department managers in the first place;
• If the issue or concern raised is beyond department manager’s jurisdiction, or it is believed that it is necessary to inform a higher level, staff are required to fill in the “Complaint Reporting Form” and obtain department manager’s signature to make a formal report.

4. Gift and Entertainment Registration Form

    Gifts, meals and entertainment for business purpose must support the legitimate interests of Halfaya and should be reasonable and appropriate. Please read carefully with the gifts or entertainment requirements in the Code. For any gift or entertainment accepted with prior approval, staff are requested to use the “Gift and Entertainment Registration Form” for disclosure purpose.