Policies

To give all employees the confidence to raise concerns about behavior and practice and to mitigate risks and losses through the early discovery of irregular activities, Amtaar Contracting & General Maintenance commits itself to break down communication barriers and providing a safe internal communication channel for all employees to express their concerns through the enactment of the Policy, which allows for anonymous disclosures and the protection of information from sanctions under specific conditions. The policy covers all reports or information in relation to actual or suspected criminal activities, unlawful acts or omissions, fraud, violations of the Code of Conduct and other policies, danger to health and safety, insubordination or malpractice in the workplace, including those relative to matters of personal accountabilities and responsibilities. All employees, regardless of position or rank, who are witnesses to anomalies in the workplace are obliged to speak up and report the same personally or in writing to his/her unit head or any of the following officers, verbally or in writing Code of Conducts It is a requirement of Amtaar Contracting & General Maintenance, and its affiliates to comply with the laws of the relevant countries in which it operates. This includes compliance with the applicable competition laws in each country and being held accountable for actions and decisions. Suppliers’ code of conduct (Need to write code)

• Amtaar Contracting & General Maintenance(‘The Company’) has zero tolerance for bribery and corruption. We will actively avoid doing business and being involved or associated with others.
• who will not commit to conducting business without bribery and corruption? Although the UAE has had anti-bribery legislation in place since the late 1980s in the form of the UAE Federal Penal Code (the “Code”), the business community in the UAE has, to a large extent, been unaware of the existence of the code and how its provisions could impact their business operations locally. Although the UAE has had anti-bribery legislation in place since the late 1980s in the form of the UAE Federal Penal Code (the “Code”), the businesses community in the UAE has, to a large extent, been unaware of the existence of the Code and how its provisions could impact their business operations locally. However, following the slowdown of the UAE economy, as a consequence of the global economic crisis, there has been a marked rise in the prosecution of individuals suspected of corrupt practices in the UAE under the Code as authorities seek to enforce this law in order to curb such practices. In particular, certain high-profile cases, which made the headlines, have highlighted the importance of being aware of the provisions of the Code and its implication for businesses in the UAE.
• Due to the political and economic impact of corruption, both locally and internationally, there has been a sustained and concerted effort by the UAE authorities to focus on stamping out corruption at all levels of government. Although the focus of the authorities has primarily been on corruption at the government level, it is important to note that the Code also contains provisions that apply to the private sector. Consequently, a lot more attention is being paid by businesses and individuals to the subject of corruption and enforcement of the Code by the authorities as they seek to understand what measures if any, they can take in order to ensure that their business operations are compliant with the Code.
• 1. Scope of the Code As mentioned above, the Code is the main federal law that regulates anti-bribery practices in the UAE. Articles 234 to 239 of the Code contain provisions that criminalize the bribery or attempted bribery of both public and private sector employees. Under the provisions of the Code, a bribe would be anything that confers a benefit on a public or private sector employee, as the case may be, with the intent to procure that such employee acts in a way that violates the duties assigned to his function or to commit an act which falls outside such duties (a “Bribe” or “Bribery” as the context requires). (a) Public Sector In relation to acts of Bribery committed by individuals in the context of the public sector, the relevant parties who would be subject to prosecution under the Code are those persons who accept, offer or facilitate a Bribe, irrespective of whether they obtain any direct gain from such action. (i) The recipient
• The recipient of a Bribe in the public sector is required by the Code to be a “public officer” who accepts a Bribe for himself or for another person in exchange for committing or omitting an act in violation of the duties of his function or an act which is not part of the duties of his function. This term would include employees working in ministries and governmental departments, chairmen and members of legislative, consultative, and municipal councils, chairmen and members of boards of directors, managers, and all other employees working in public organizations and corporations. In addition, the Dubai Court of Appeal has also recently interpreted the meaning of the words “public officer” to be sufficiently wide enough to include employees of state-owned or semi-state-owned private sector entities who receive Bribes. It is important to note that “public officers” would still be committing an offense and be subject to prosecution under the Code in circumstances where they accept a Bribe but did so without the intent to commit or omit the act required of them by the person who offered the Bribe.
• Accordingly, the mere acceptance of a Bribe by a “public officer” would be sufficient grounds to prosecute that individual without having to prove that he had the intent to commit or omit the act required of him in exchange for such a Bribe. Apart from “public officers” as described above, the provisions of Article 237(vis) of the Code also applies to recipients of Bribes who are not strictly “public officers” but who are nonetheless in a position to influence “public officer” in the performance of their duties in exchange for a Bribe. (ii) The offeror Article 237 of the Code provides that the act of offering a Bribe to a “public officer” or to someone in a position to influence a “public officer” is a criminal offense irrespective of whether the intended recipient accepts the Bribe or not. (iii) The facilitator Also under the provision of Article 237 of the Code, any individual who acts as a middle-man, mediator or contact person between the recipient and the offeror of the Bribe will also be guilty of an offense. It should also be noted that the Emirates of Dubai and Abu Dhabi both have specific anti-bribery legislation in place which are aimed at curbing corrupt practices. In Dubai for instance, the Dubai Government Human Resources Management Law of 2006 contains a number of obligations intended to combat potential corrupt practices and ensure that employees of the Dubai Government adheres to the highest professional and ethical standards whereas in Abu Dhabi, Law No. 1 of 2006, which regulates the Abu Dhabi civil service, prescribes similar rules and standards of conduct for civil servants and also contains a number of provisions that are specifically aimed at curtailing corrupt practices. (b) Private Sector In relation to acts of Bribery committed by individuals in the context of the private sector, Article 236(vis) of the Code states that only the individual who accepts a Bribe, in exchange for committing or omitting an act in violation of the duties of his position would be guilty of an offense under the Code. The recipient, in this instance, is defined by the Code as any member of the board of directors of any private company, institution, cooperative association, or public benefit association, as well as any manager or employee in any of these.
• It should be noted that there is no provision in the Code that makes it a criminal offense to offer Bribes in the private sector or to act as a facilitator in these circumstances. 2. Penalties As set out above, the Code draws a clear distinction between Bribery in the public and private sectors and in keeping with this distinction, the Code prescribes different penalties to be applied to individuals found guilty of Bribery depending on the relevant sector. (a) Public Sector
• Any “public officer” who is found guilty of accepting a Bribe would be subject to a fine equivalent to the benefit accepted by them (provided the fine is not less than AED 1,000), confiscation of the actual benefit accepted and, depending on the circumstances of each case, imprisonment ranging from five to a maximum of ten years. In addition, individuals who are found guilty of accepting a Bribe in exchange for exerting their influence over a “public officer” would be subject to a fine not exceeding AED 10,000 and imprisonment of up to one year. Individuals who offer a Bribe to a “public officer” or to an individual who is in a position to exert influence over a “public officer”, would be subject to a fine equivalent to the benefit they offered as a Bribe (provided the fine is not less than AED 1,000), confiscation of the actual benefit offered and imprisonment not exceeding five years. Similar penalties would apply to any individual who facilitates a Bribe between the offeror and the recipient. (b) Private Sector
• Individuals who accept Bribes in the private sector would be subject to a fine equivalent to the benefit accepted by them (provide the fine is not less than AED 1,000), confiscation of the actual benefit accepted and imprisonment not exceeding five years. Even though the UAE authorities have, as yet, not taken any firm steps toward addressing corrupt practices in the private sector, the Code does allow them to prosecute individuals suspected of such practices. Accordingly, there may eventually, be a shift in direction by the authorities as they move to eradicate corruption not only at the government level but also in the public sector. In doing so, it is conceivable that the authorities may very well in the future expand the provisions and application of Article 236(bis) of the Code to facilitate the prosecution of Bribery in the private sector such that the offeror and facilitator of a Bribe would also be guilty of an offense.
• In conclusion, it is important for international companies which carry on business in the UAE and also have business interests in other countries, for instance in the United States and the United Kingdom, to not only have regard to the provisions of the Code (including any comparable Emirate specific legislation) but to also be aware that there may be specific anti-bribery legislation in place in those countries, for instance, the Foreign Corrupt Practices Act in the United States and the soon to be implemented Bribery Act in the United Kingdom, which they would be obliged to comply with. In appropriate circumstances, certain actions taken by these companies locally in the UAE could be classified as offenses not only under applicable local anti-bribery legislation but also under applicable foreign anti-bribery legislation which could result in multi-jurisdictional prosecutions of these companies.

Purpose The Conflict of Interest Policy outlines the parameters of conflict of interest for employees and/or Contractors,Suppliers of Amtaar Contracting & General Maintenance. Philosophy Employees of Amtaar Contracting are expected to adhere to the highest standards of personal and professional integrity and shall protect the interests of the company. Personal gain shall not conflict with duty and commitment to Amtaar Contracting & General Maintenance. Responsibility The Director/Project Director is responsible for final decisions on any potential or actual conflicts of interest. The Department Heads and Management are responsible for presenting a recommendation on any potential or actual conflicts to the owner. Employees are responsible for declaring any potential or actual conflict of interest. Guidelines An employee shall be considered to have potential conflict of interest where he or she has a direct or indirect financial interest in a matter involving Amtaar Gen. Contracting and where the employee could influence or appear to be able to influence any decision on that matter by AMTAAR. Examples include acceptance of personal gifts beyond moderate courtesy, purchasing decisions for personal gain, and/or written or public statements in conflict with Amtaar Gen. Contracting. Employees and related firms or suppliers are not precluded from selling goods, materials, or services to Amtaar Gen. Contracting provided this activity is consistent with generally accepted competitive commercial practice. All employees must ensure understanding of and compliance with Amtaar Gen. Contracting policies and laws directly affecting his/her employment.

Diversity in all its forms is fundamental to the Group’s business. We operate in a variety of environments and geographies, in numerous roles, for a wide range of clients. To do this effectively we need an equally diverse workforce that understands our customers’ needs and stimulates innovative solutions. Amtaar Contracting values the benefits it gains from an international workforce with a rich diversity of skills, cultural backgrounds, and gender. Our goal is to recruit, motivate, develop, and retain outstanding people that reflect that diversity. We are committed to ensuring that every employee has an equal opportunity to develop and progress at every level in the organization based on personal contribution and ability, with the aim over time of realizing the benefits of diversity in the development of our management and executive leadership. We will continue to monitor the extent to which our staff believes we are meeting this objective and are committed to taking action where necessary or helpful to promote equal opportunity. The Company believes that diversity can bring insights and behaviors that make a valuable contribution to its performance. In considering new members, we will aim to select individuals best able to contribute to an effective, challenging, and cohesive Board by blending a diversity of skills, experience, knowledge, independence, cultural background, and gender. Given constraints on the size of the Company, this will be achieved by taking into account the overall contribution to diversity alongside other desired characteristics in new appointments rather than by setting specific targets on any single dimension of diversity. We would expect this to lead to greater diversity in the Company and its affiliates over time. We will monitor our success in developing the diversity of the Company as part of our annual evaluation of the Company’s effectiveness.

The policy of the Company is to conduct its operations in an environmentally-sustainable manner in order to protect the environment for future generations. In implementing its policy the (Amtaar Contracting & General Maintenance) will seek through its operating companies, to ensure: Compliance with relevant environmental legislation and regulation Prevention of pollution The efficient use of natural resources The minimisation of waste and emissions to air and water Environmental awareness of all employees Effective monitoring of environmental performance Continual improvement in environmental performance issues, and environmental responsibilities are allocated to line management throughout the organisation. This policy will be subject to periodic review to ensure it continues to meet the company environmental requirements.

Introduction The aim of this document is to help develop an understanding and awareness of the risks and consequences of fraud by providing a framework for promoting Amtaar Contracting’s policies and procedures that assist in the prevention and detection of fraudulent activity inside and outside Amtaar Contracting Company At Amtaar, we are committed to the highest standards of personal and corporate behavior. We will not tolerate any incidence of fraud committed by workers or others. We will take immediate and appropriate action (which may include dismissal, reporting to the police, and legal action to recover assets) against those persons committing fraud, irrespective of the length of service or position. This policy applies to Amtaar, all operations of Amtaar Contracting nationwide, and all other parties who are given access to Amtaar’s information and premises. It covers all Amtaar staff, full and part-time, casual and temporary agency staff, and contractors. The policy reflects the minimum standards of Amtaar. Business units may supplement this by adding additional requirements or guidance relevant to their own businesses. Defining and Identifying Fraud Fraud encompasses a wide range of irregularities and illegal acts, all of which are characterized by intentional deception. Normally fraud involves intentional distortion of financial statements, accounting, or other records. This is done in order to conceal the misappropriation of assets or the appropriation of another material gain to which the person or organization is not rightfully entitled. Annex A sets out further information on categories and types of potential fraud. Promoting an anti-fraud culture A culture of honesty, propriety, and vigilance, which is seen to include individuals at all levels, is fundamental to managing fraud. All Amtaar Contracting workers need to be alert to the risk of fraud and irregularity both within the organization and in organizations with which Amtaar companies contract, and report any matters of a fraudulent nature utilizing Whistleblowing procedures. Roles and responsibilities All workers have a role to play in limiting the scope for fraud by adhering strictly to the policies and procedures in place for financial matters including the handling of payments and receipts; for procurement of all goods and services; and for dealing with travel, subsistence, and other claims. Accountant and administration personnel should ensure that adequate internal controls and management checks are in place and are carried out effectively; that workers are fully familiar with financial and other policies and procedures; and that these policies and procedures are followed. Project Engineer, Site Supervisor, and Accountant’sresponsibilities include identifying activities in their area that pose risks of fraud, theft, or corruption, and developing procedures, including surprise checks, which are adequate to counter these risks. Project Engineer, Site Supervisor should also follow up on obvious worker errors or unusual behavior such as an unwillingness to take holiday entitlements for fear their fraud will be detected, inconsistency between earnings and lifestyle, irrational or unreasonable behavior, or an unwillingness to delegate to or involve others in the provision of information. A number of departments and workers have specific responsibilities for the management of systems of fraud control and investigations. Business units are responsible for: Developing and maintaining effective controls to prevent fraud; Subject to the Group Response Plan, assistance in carrying out vigorous and prompt investigations if fraud occurs; Notifying the Director and the Project Director of the discovery of any fraud; Taking appropriate disciplinary and legal action against perpetrators of fraud; and Taking disciplinary action against managers or supervisors where management or supervisory failures have caused or contributed to the commission of fraud. Executives, managers, and supervisors are responsible for: Identifying the risks to which systems and procedures are exposed; Developing and maintaining effective and efficient procedures and controls to prevent and detect fraud; and Ensuring that procedures and controls have complied with Company policies. Individual workers are responsible for: Following company procedures and control; Acting with propriety in the use of Amtaar and client resources and in the handling and use of corporate funds, assets, liabilities, and accounting systems; Acting with propriety in their dealings with suppliers, clients, and Amtaar staff; and Reporting details immediately to their site supervisor, or management staff within Amtaar if they suspect that fraud has been committed or see any suspicious acts or events. Any member of staff may use the Whistle-blowing procedure

Amtaar Contracting & General Maintenance recognises the problems that bullying, harassment and victimisation can cause in the workplace and considers bullying, harassment or victimisation of any employee for any reason unacceptable. We believe that it is crucial that all employees treat each other with dignity and respect in order for them to work effectively and confidently. Fairness and respect for individuals results in the sort of positive atmosphere that generates its own success. The company seeks to encourage employees to behave in an appropriate manner at all times and the support and co-operation of all employees is essential in ensuring the success of this policy. What is Harassment? Harassment is defined as, “Unwanted conduct which has the purpose or effect of violating a person’s dignity, or creates an intimidating hostile, degrading, humiliating or offensive environment for that person.” Harassment, whether it be intentional or unintentional, has a direct effect on the individual concerned and can lower morale and interfere with the effectiveness of people at work. Unacceptable behaviour includes unwanted verbal, non-verbal and physical conduct. All employees need to think about their own behaviour and that of their colleagues and reflect on whether it might be unacceptable or offensive. Directors/Project Directors/Engineers/Site Supervisors and Office Administration personnel have a responsibility to ensure that no form of harassment takes place at the workplace and this includes ensuring that a culture of unacceptable behaviour not be allowed to develop. It is the impact of the conduct and not the intention which determines whether harassment has taken place. The policy concerns the behaviour of employees and third parties at the workplace or in direct connection with employment e.g. with colleagues at a pub or during lunch hour. This may include informal social events beyond the course of business which are not organised by the company and not held on company premises but which are attended by employees. Anyone can suffer from harassment. What is bullying? Bullying is a form of harassment which leaves a person feeling that they have not been treated with respect and that they have been devalued, belittled or threatened. It can be at any level and across any level in the organisation e.g. manager/subordinate, subordinate/manager, colleague/colleague, and team/individual. Victimisation Victimisation occurs when a person is treated less favourably because he or she is suspected or known to have made a complaint or has given evidence about the behaviour of someone who has been harassing or discriminating. If any employee is found to be harassing, bullying or victimising it is a disciplinary offence and may result in suspension or immediate termination.

Amtaar Contracting & General Maintenance is Family Welfare Policy, TB Workplace Program, HIV/AIDS committed to maintain a safe and healthy working Workplace Program environment. Procedures are in place to protect all Inspection and Search Procedures associates from generally recognized workplace hazards such as fire, earthquake, accidents and other natural and artificial errors/mistakes. Amtaar likewise has various substance abuse and health & safety policies, as well as inspection and search procedures. Substance Abuse and Health and Safety Policies Employees who work while under the influence of drugs or alcohol present a safety and operational hazard to themselves and their colleagues as well as pose a risk to the trustworthy and professional image of the Company. Amtaar Contracting also promotes the health and safety of its employees and their families, through the following policies: Drug- Free Workplace Policy and Programs, Policy Against Alcohol Abuse, Policy on Off-Duty Substance Abuse, Employees are mandated to notify security personnel if they see anything suspicious, including the presence of strangers and unattended bags or packages on site. Employees are likewise mandated to subject themselves, their personal belongings and the Company assets under Amtaar Contracting & General Maintenance custody to intensive inspection and search procedures by security personnel, upon entering, while within and upon leaving Site premises. Project location include parking lots, whether owned or leased by the Client/Company. Personal belongings shall pockets, bags, storage media, cars and any other personal property that may be used as repository of cash, jewelry, documents, keys, data and other valuable items.

Amtaar Contracting & General Maintenance considers sustainability to be about taking a broad and joined-up view of the challenges we and our stakeholders face. Sustainability is central to the corporate vision ‘to redefine the future for people and places’.
We are committed to adopting a more intelligent, integrated approach to the use of natural, social, knowledge, and financial capital, to ensure we help
deliver a better future for everyone. It is in pursuit of this we have developed our new sustainability
strategy ‘SustainAbilities’.
SustainAbilities is the action plan that sets out how we will deliver business with and for our
stakeholders -in a way that ensures sustainability is at the heart of operations and that our activities are focused on achieving five key outcomes.
Places that benefit people
Create places and deliver services that enhance people’s lives, that can be valued, that contribute to individuals’ well-being and that is designed and built for the future. Places should be resilient to climate change impacts and respond to society’s changing demands. Public service in the public interest
Set ourselves apart by delivering services that benefit people and demonstrating the value our employees play in society. As the role of government changes, Amtaar Contracting & General Maintenance will increasingly
support front-line public agencies and the third sector and deliver public services directly.
More skills, more opportunities
Build the skills of employees and stakeholders by sharing knowhow, providing opportunities for self-
improvement and enabling individuals to make a positive contribution to society. We will generate wider benefits by adding to society’s collective pool of capacity and
knowledge.

Positive environmental impact
A movement beyond compliance toward making a positive and restorative contribution to the
environment through every project. We are committed to lifting our ambitions, and striving to use natural resources more efficiently, both in our own operations and our work with customers. Sustainable growth
Building a profitable business that takes into account the true costs of business and delivers
sustained value for all of our stakeholders. We will continue to demonstrate leading practices in sustainable procurement and include a wider range of non-financial metrics in decision-making.
This policy applies to all employees and will be embedded through the work of the Sustainability
Board, chaired by General Manager/Director/Project Director. The Sustainability Board leads the implementation of the strategy and monitors progress against the
targets set out, supported by a cross-divisional Sustainability Steering Group. This policy and associated documentation will be publicized to all employees and shared with stakeholders. It will be reviewed on an annual basis and updated as appropriate.

The Board of Amtaar Contracting & General Maintenance is committed to a free and open culture in dealings between its officers, employees, customers, suppliers, and all people with whom the Company engages in business relations. The Board recognizes that effective and honest communication is essential to maintain our business values and to ensure that instances of business malpractice are detected and dealt with. Purpose The purpose of this policy is to encourage everyone, whether they are full-time or part-time employees, agency staff, agents, contractors, suppliers or customers of the Group,to report any business misconduct without risk to themselves. Policy This policy will apply in cases where you genuinely and in good faith believe that business misconduct is occurring, has occurred or may occur within the Amtaar Group. Below are some examples of business misconduct: A CRIMINAL OFFENCE; A PERSON NOT COMPLYING WITH ANY LEGAL OBLIGATION; THE USE OF DECEPTION TO OBTAIN AN UNJUST OR ILLEGAL FINANCIAL ADVANTAGE FOR THE BUSINESS UNIT OR PERSONALLY; A MISCARRIAGE OF JUSTICE; DANGER TO THE HEALTH AND SAFETY OF AN INDIVIDUAL; DAMAGE TO THE ENVIRONMENT; A FUNDAMENTAL BREACH OF INTERNAL CONTROL; INTENTIONAL MISREPRESENTATION DIRECTLY OR INDIRECTLY AFFECTING FINANCIAL STATEMENTS; SERIOUS NON-PROFESSIONAL OR NON-ETHICAL BEHAVIOUR INCLUDING HARASSMENT AND BULLYING; AND DELIBERATE CONCEALMENT OF INFORMATION RELATING TO ANY OF THE ABOVE. This policy is separate from the grievance procedure as described in your employee handbook. Procedure You should, in the first instance, raise the matter with Site Supervisor or, if you do not feel this is appropriate, with your Office Manager/Project Director. Should you feel unable to talk to your Office Manager or your Project Director then you should contact the Office Admin or , in his absence, t respectively, who will treat the matter in confidence. If you consider this inappropriate you contact General Manager. All instances of whistle-blowing to the Office Administrator or Accountant will be reported to the Project Director or General Manager, as appropriate. Investigation Once an allegation of business malpractice is made the Office Administrator, or in his absence, the Accountant will agree with an appropriate investigation plan with the General Manager/Project Director and will endeavor to respond to you within 10 working days setting out what further investigation, if any, is planned. Once the investigation is complete it will be reviewed by the Committee and you will be advised of the results of the investigation as well as any corrective actions which are being taken. The Company is committed to running its operations without misconduct and expects its employees and other stakeholders to share this objective. However, the Company also recognizes that whistle-blowing is a potentially sensitive issue. If you believe that you are being penalized in any way for whistle-blowing or if you do not consider that you have had a satisfactory response to your disclosure you should write to General Manager/Project Director setting out the facts. Safeguards If requested we will take all reasonable steps to protect your anonymity. However, you should be aware that action taken as a result of your disclosure may lead to your identity needing to be revealed. Any whistle-blowing employee is protected against adverse employment actions (i.e. dismissal, demotion, suspension, harassment or other forms of discrimination) for raising allegations of business misconduct. A whistle-blowing employee is also protected even if the allegations prove to be incorrect or unsubstantiated, provided the disclosure is made in good faith and where it is believed the information and any allegation in it are true. Disciplinary Action If any allegation of business malpractice is substantiated, appropriate disciplinary action will be taken against the responsible individual(s), up to and including termination of employment. Furthermore, any act of retaliation or victimization against a whistle-blower employee will result in disciplinary action being taken against the perpetrator, up to and including termination of employment. The malicious use of the whistle-blowing policy will result in disciplinary action against a whistle-blowing employee, up to and including termination of employment.

The way in which we conduct ourselves has a significant influence upon the reputation of Amtaar Contracting & General Maintenance and its people. Amtaar’s good reputation plays a vital part in maintaining the trust and confidence of those with whom we deal and is one of the key components of working in partnership. The protection of this reputation is therefore of fundamental importance. We demand high ethical standards be maintained in the conduct of our business activities. Corruption, bribery and unfair or anti- competitive practices will not be tolerated. We will compete vigorously, honestly and in accordance with competition law. In any contact with competitors our people are required to avoid discussing proprietary, confidential or commercially sensitive information. We will obey the laws of those countries and communities in which we conduct business and, subject to adherence to the foregoing principles, will respect the traditions and cultures of each country in which we operate. These principles of business conduct and business behaviour apply to all our people and to every company in which we have a controlling interest. We also expect all other entities in which we invest to adopt these principles. We will support multilateral action aimed at achieving high common standards of business probity and governance.