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Introduced in 2013, the ASCS Ethics & Compliance Hotline helps ensure we conduct ASCS business in accordance with the highest ethical standards. Developed to address issues of suspected unethical behavior, the Hotline can also be used as a resource for guidance and questions.

Sometimes you may have a question about something in the Code or just want guidance on “doing the right thing.” If that’s the case, simply call or write the Hotline with your question. If an answer is not immediately available, you are contacted as soon as possible following your call, e-mail, fax or letter.

As always, you are encouraged to resolve issues through your local management team wheneverpossible. If that is not possible, or concerns exist about doing so, you should make use of the Hotline.

The Hotline can be reached from anywhere in the world by telephone or e-mail. Youmay provide your name or other identifying information, or you may contact the Hotlineanonymously, where local law permits. You may also write to the address provided in thisbrochure.

If I contact the Hotline, to report an issue, what happens next?

If you call the Hotline, the person answering your call ask the reason for your call and for as much information as you can provide. Be prepared to be as specific as possible. This speeds up the investigation process.

Once your concern is reported, an investigator is assigned to look into the issue. You are reminded of the need for confidentiality and that no one may retaliate against you for good faith reporting of an incident, filing of a complaint or for participating in an investigation.

Unless you choose to remain anonymous, you may be contacted by the investigator for additional information. Once completed, investigation findings are reviewed by ASCS Compliance & Ethics department in consultation with others and recommendations are finalized. Results and recommendations are then discussed with the appropriate people and implemented.

Are there special procedures for handling accounting issues?

You can report issues to the ASCS Compliance & Ethics department by contacting the Hotline or you can report them directly to ASCS senior management by sending an e-mail to: ethics@ascsgulf.com.

Any Code of Conduct related matters submitted to the above address are automatically forwarded to all independent directors and copies are provided to our General Counsel, the Office of the Owner, and the office of Compliance & Ethics. Concerns and questions relating to accounting, internal accounting controls, financial policy, risk management or auditing matters are immediately brought to the attention of the Compliance Review Board and are addressed in connection with Compliance & Ethics, as well as the Company’s Internal Audit and Legal functions.

Who answers the Hotline?

The Hotline is answered by a member of the Compliance & Ethics team at ASCS headquarters in Abu Dhabi UAE.

What about confidentiality?

We strive to maintain confidentiality of all Hotline reports. However, it may not be possible to guarantee absolute confidentiality. Sometimes, to investigate a complaint, the reporting person’s identity is relevant. Sometimes the reporting person may have discussed the issue with others before calling the Hotline and those friends or colleagues may not hold the conversation(s) in confidence. And sometimes, under very limited circumstances, the law may require the Company to reveal information obtained during an investigation. In all circumstances, however, we ensure no one is retaliated against for reporting an incident, filing a claim, or for participating in an investigation.

What if I don’t have all the facts?

Don’t try to investigate a situation on your own. If you have enough information to reasonably suspect a problem, call the Hotline. The Company looks into the information you do provide, attempts to verify it and takes appropriate action.

What are some of the things investigated by the Hotline?

All potential violations of our Code of Conduct including:

Action that could potentially compromise the safety or integrity of ASCS products
Any action that could prove detrimental to the name and reputation of the Company
Any potential criminal conduct
Company political contributions
Conflicts of Interest
Discrimination
Fraud (i.e. financial)
Harassment, including sexual
Improper financial or accounting practices
Improper sales practices
Insider trading
Theft, bribes, kickbacks
Unauthorized disclosure of Company trade secrets or proprietary information

What if there is an emergency?

Do NOT call the Hotline in the event of an emergency or crisis. For notification regarding an emergency situation, such as product tampering, crisis or any immediate risk to safety you should immediately contact your supervisor or manager and/or the local police or fire department as appropriate.

When in doubt please call, as the Ethics & Compliance Hotline is here to help. You may contact the Compliance & Ethics department from any location through the 24-hour Hotline 800 CALL ASCS (2255 2727) (UAE), or through e-mail: ethics@ascsgulf.com

Code of Conduct Hotline