Al Arabiya Investment Code of Conduct outlines the following issues:

Compliance with Laws, Rules and Regulations

The Board of Directors and Executive Management are required under this section to comply with all laws, rules and regulations applicable to the Company’s business and all regions in which it operates.

Conflicts of Interest

This section prohibits events that may result in a conflict of interest. Whenever such a conflict does appear, it should be immediately disclosed to the Group Regulatory Compliance department and recorded in a register.

Insider Trading

This section prohibits the use of non-public material information or sharing such information to trade shares and make a financial gain.

Corporate Opportunities

This section states that all staff, including Executive Management and Directors, may not use corporate property, information, or position for personal gain, and may not compete with the Company directly or indirectly.

Competition and Fair Dealing

Each Director and member of Executive Management should respect the rights of and deal fairly with the Company’s customers, suppliers, competitors and employees. No Director or member of Executive Management should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other illegal trade practice.

Political Contributions

The Code of Conduct prohibits any political contribution, directly or indirectly in the countries in which Al Arabiya Investment operates or is looking to operate. This includes: (a) any contributions of Company funds or other assets for political purposes, (b) encouraging Directors or individual employees to make any such contribution; or (c) reimbursing Directors or employees for any contribution.

Discrimination and Harassment

Each Director and member of Executive Management should be committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment based on race, color, religion, sex, national origin or any other protected class.

Health and Safety

Each Director and member of Executive Management has responsibility for maintaining a safe and healthy workplace for all employees and officers by following environmental, safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions. Violence and threatening behavior are not permitted.

Record Keeping, Financial Controls and Disclosures

All of the Company’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect the Company’s transactions, must be promptly disclosed in accordance with any applicable laws or regulations and must conform both to applicable legal requirements and to the Company’s system of internal controls.

Confidentiality

Directors and members of Executive Management must maintain the confidentiality of proprietary information entrusted to them by the Company or its customers or suppliers, except when disclosure is authorized/required by laws or regulations or when a disclosure is made in the ordinary course of business on a need to know basis.

Protection and Proper Use of Company Assets

The obligation of Directors and members of the Executive Management is to protect the Company’s assets includes the Company’s proprietary information. Proprietary information includes intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or unauthorized distribution of this information is a violation of Company policy. It could also be illegal and result in civil or criminal penalties.

Waiver of the Code of Business Conduct

Any waiver of this Code for Executive Management or Directors may be made only by the Board of Directors of Al Arabiya Investment. It will be promptly disclosed as required by law or regulation.

Improper Influence on Conduct of Auditors

Al Arabiya Investment prohibits its officers and employees from directly or indirectly taking any action to coerce, manipulate, mislead or fraudulently influence Al Arabiya Investment Independent Auditor(s) for the purpose of rendering the financial statements of Al Arabiya Investment , materially misleading.

Financial Reporting

The Company expects Directors and senior management to take financial reporting responsibility very seriously and provide prompt and accurate answers to inquiries related to the Company’s public disclosure requirements.

Annual Acknowledgement

To help ensure compliance with this Code of Business Conduct, the Company requires that all salaried employees and officers review the Code of Business Conduct and acknowledge their understanding and adherence to it, in writing, on an annual basis.