We are committed to sound business conduct and we therefore manage our business according to our Company Code of Conduct and Principles.

1. Code of Conduct

The Code of Conduct expresses the employee’s professional responsibility toward the Company, and its clients.  The Code requires strict adherence.

1.2 Company Assets
Employees may not use company assets for unauthorized personal benefit. We do not tolerate fraud, theft, loss through recklessness or waste of company assets.

1.3 Accepting Valuable Gifts or Entertainment
Our employees must avoid improper personal benefits for themselves or family members that result from their association with Mezzan Holding Company .  Employees may not accept gifts, money or entertainment that might appear to place them under obligation.

1.4 Bribes and Kickbacks
Our employees and agents may not accept bribes or kickbacks to gain or render orders, services for financial or other benefits.  Our employees and agents must immediately turn down and report any attempt at or opportunity for bribery to the Group HR Manager.

1.5 Facilitating Payments
In certain circumstances, small cash sums or small gifts may be appropriate if customary and necessary to expedite or secure the performance of routine governmental action and permitted under applicable laws of the relevant jurisdiction. However, such payments- referred to as facilitating payments-should be avoided whenever possible, and cash payments should be properly receipted.

2. Company Principles

2.1 Legal and International Regulations
We comply with the laws, rules and regulations of the countries in which we conduct business.

2.2 Public Reporting and Communication
Our financial statements, public reporting documents and other public communication provide full, fair, accurate, timely and understandable disclosure of the Company’s position in accordance with relevant laws and generally accepted accounting principles and standards.

We comply with all applicable laws and accounting rules, financial reporting requirements and requirements of the securities exchanges on which we are listed.

We maintain open and transparent communication with our customers, employees, shareholders and society, while giving due respect to confidentiality.

2.3 Public Activities 
We do not intervene in party political matters, nor do we make gifts or donations to political parties.

2.4 Safety
We provide all employees with safe and healthy working conditions.

We comply with relevant safety laws and regulations, and deploy policies that prevent, identify and eliminate hazards across our company and operations. We aspire to appoint safety representatives and improvement groups throughout our company.

We strive to adopt best practices and to exceed legal safety requirements. We continually measure and assess our safety performance.

2.5 Employees
We seek to attract, develop, reward and retain outstanding individuals who appreciate the value of acting as a team.

We create equal opportunities for all our employees.

We do not condone unfair treatment of any kind. We treat all people with consideration and respect.

2.6 Customers
Employees must be open and transparent within the bounds of client confidentiality.
Service and client trust must not be compromised for personal advantage.

We strive to provide the highest level of excellence in our products and services and effectiveness in our approach to give best solutions and value for money.

2.7 Competition
We believe in open and fair competition.

2.8 Business Associates and Agents
To the fullest extent possible, we require our business associates to observe our Company Principles. We expect our agents- individuals or organizations that legally represent us  to comply with the principles.

2.9 Social Responsibility
We work with our partners and people to provide resources from across our businesses to those in need.

We invest in Education and Health in Kuwait and abroad. We support the environment by actively recycling our industry consumption wherever possible.

We support neighbours in distress whenever we can through direct contributions and by partnering with our customers to leverage our resources where it can make a meaningful impact. 

2.10 Application of these Principles
The Code of Conduct and Company Principles apply to all controlled companies and joint ventures and employees within Mezzan Holding Company . Mezzan Holding Company  expects its agents to comply with the Company Code of Conduct and Principles.

The Board of Directors is responsible for adopting, communicating and enforcing the Company Code of Conduct and Principles. Our internal audit, integrity, risk management and security functions support the board in monitoring compliance.

Any change in the principles or waiver of provisions may be made only by the Board of Directors.  Such changes will be promptly disclosed here.

We will not penalize employees for internally reporting a violation or suspected violation of these principles.

2.11 Violation of these Principles
Violation of these Principles can lead to disciplinary measures, dismissal and, where laws are broken, civil or criminal prosecution.

2.12 If You Have Questions or Would Like Advice
All employee decisions must be made with full recognition and compliance with the Company Code of Conduct and Principles.

Whenever you have a question as to as whether any conduct is permissible, you should check with your supervisor or local manager. If your concerns cannot be addressed locally or if you would like advice on implementing or applying of the Company Code of Conduct and Principles, do not hesitate to contact a member of the Executive Management Team at Principles@mezzan.com or by telephone at +965 99694664.