KUWAIT STEEL

CODE OF CONDUCT
Dear Fellow Employees and Directors,

In this booklet, you will find our Code of Conduct and Ethics, which is a reaffirmation of our
commitment to conducting our business ethically and to observing applicable laws, rules and
regulations.

With KUWAITSTEEL operating assets in and outside of Kuwait, trading commodities in the domestic
and exports markets, employing a diversified and multicultural workforce - all our actions need to be
based on Respect, Responsibility and Exemplary Conduct.

Our Company’s objective remains to build a solid foundation for future generations.

The Code of Conduct describes how we put these values into practice every day. It explains our
commitments and expectations towards stakeholders and provides guidance for employees and
everyone who works on our behalf.

This Code has my full endorsement, as well as that of the Directors and Senior Management of
the Company. Our Company’s reputation and continued success depend primarily on us working
towards the commitments contained in this document.

The three following priority business principles are equally critical to our success as a responsible
company:

• Commitment to the highest levels of safety and security in our operations as well as protecting
health and the environment;

• Compliance with the highest integrity standards, in particular by preventing corruption, fraud,
and anti-competitive practices;

• Respect for the needs of our multicultural workforce.

Every employee, director, manager, and officer, regardless of location or position in the Company,
must read this Code, understand it, and follow it every day, without exception. It forms a part of
the terms and conditions of employment with us. The adherence to these ethical principles is
fundamental to our future success.

Everyone who works at or with our company should feel confident about our high ethical standards,
honesty, and integrity that starts and ends with each of us. The conde of Code of Conduct is a living
document, the example you set each day brings it to life.

Working together, we will be able to build sustainable growth, create value for all our stakeholders
and reinforce the way how we work together, making a bright future of Steel for all of us.

Faisal Al-Khaldi

DCEO

July 2020
 11. MOBILE PHONE POLICY

TABLE OF CONTENTS
11
Scope of policy
Utility class vehicles, crane and lifting equipment,other mobile equipment

Mobile phones and driving – general remark

Office staff
1. OUR VALUES 8 Technical Staff
2. OUR WORK DECISIONS 8 Camera phones
3. INTRODUCTION 8 Liability for loss or damage
4. COMPLIANCE OBLIGATIONS 9 Confidentiality
5. ADHERENCE TO THE CODE OF CONDUCT 9 Breaches of this policy
6. DISCIPLINE 9 12. CONFIDENTIALITY OF INFORMATION 13
7. CONCERNS & INVESTIGATIONS 9 Confidential and Customer-Specific Information

6 Raising Concerns Company Information 7

How to Raise Concerns Customer information
Investigations Employee information
8. EMPLOYEE CONDUCT STANDARDS 9 Supplier information includes pricing and contract information.
Safety 13. Environmental Laws and Regulations 14
Safety Principles Smoking
Safety Commitment 14. FAVORED TREATMENT 14
Personal Safety Commitment 15. ACCEPTING OR GIVING GIFTS 14
Fitness for Duty 16. HARASSMENT AND DISCRIMINATION 14
9. WORKPLACE VIOLENCE 10 17. COUNTRY LAWS/ GENERAL GUIDELINES FOR EMPLOYEES 15
Weapons in the Workplace Emergencies
Gambling in the Workplace Eating or Drinking at Public places during Ramadan
10. IT POLICIES 10 18. DRESS CODE 15
Computer and System Security 19. COMPANY ASSETS 16
Use of the internet and email 20. PREVAILING LAW 16
Social Media
 1. OUR VALUES WE RESPECT EACH OTHER AND CELEBRATE
OUR DIVERSITY:
4. COMPLIANCE HOW TO RAISE CONCERNS:

OUR VALUES GUIDE OUR BEHAVIOR, AND • Treat fellow employees and customers with
OBLIGATIONS If you encounter uncertain activities at work,
immediately bring them to attention of your
COLLECTIVELY, OUR BEHAVIORS DETERMINE respect. Employees are responsible for knowing and supervisor. If you’re not comfortable raising
HOW WE ARE PERCEIVED AS A COMPANY: • Appreciate and value each other and our complying with the requirements applicable to the issue with your supervisor, go to the next
diverse backgrounds and life experiences.
• KUWAITSTEEL acts with integrity and
• Actively seek to understand and include
work activities, including those described in this level of management within your organization.
communicates honestly and openly. Code and those described in company guidance You may also contact the Human Resources
others regardless of differences. documents (policies, standards, procedures, Department through written communication
• Deal with people and issues openly,
• Effectively collaborate as a member of a bulletins, and manuals). which is always preferred.
directly and respectfully.
diverse team; seek out diversity of thought.
• Take actions that are consistent with words.
• Do the right things. INVESTIGATIONS:
• Foster a climate of trust and openness
between people.
2. OUR WORK DECISIONS 5. ADHERENCE TO THE KUWAITSTEEL takes allegations of misconduct
• Openly give, invite and receive coaching
and feedback.
CODE OF CONDUCT seriously and takes appropriate action. All
reported violations of the Code of Conduct
Apply KUWAITSTEEL’s values to all work are investigated by the Human Resources
decisions. Deal fairly with KUWAITSTEEL’s KUWAITSTEEL strives to demonstrate the highest Department. If required, will seek help from
customers, suppliers, competitors, and standards of ethical conduct. The company any other internal/external departments.
WE ARE PASSIONATE ABOUT MEETING OUR does not grant waivers to its conduct, conflict of
employees. Don’t take unlawful advantage of Never obstruct or fail to cooperate with an
CUSTOMER’S NEEDS: interest and compliance standards.
anyone through manipulation, concealment, investigation.
• Demonstrate a passion for understanding abuse of privileged information, misrepresentation
and meeting the needs of our customers. of material facts, or any other practice involving
unfair dealing.
• Take active responsibility for the quality
of service we provide to customers and 6. DISCIPLINE 8. EMPLOYEE CONDUCT
others. Never knowingly violate laws, regulations,
policies, standards, or procedures, even if you
STANDARDS
• Are open to change and readily implement Failure to comply with this Code or company
better ways of doing things. think doing so would lower costs, increase guidance documents may result in disciplinary SAFETY:
• Have high performance expectations and a earnings, or satisfy a customer. action or termination. On safety matters,
mindset of excellence. KUWAITSTEEL takes a behavior-based approach The safety of the employees, contractors and
8 • Are innovative in identifying new
opportunities and approaches for our
Ensure your decisions and actions do not give the
appearance of impropriety. Consider how your
actions and decisions will be perceived by others.
to discipline. Discipline is considered only
when an employee acts in a reckless manner,
public is our highest priority. The company’s
commitment to a safety-first culture is reinforced 9
customers and ourselves. demonstrates a pattern of carelessness or non- with our Safety Principles. (Please refer to safety
If you’re unsure, ask for other opinions. compliance, puts the coworkers or the public at policies for complete information)
risk by intentionally violating the Code of Conduct.
WE ARE ACCOUNTABLE FOR ALL OF OUR SAFETY PRINCIPLES:
OWN ACTIONS WHICH INCLUDE SAFETY,
PROTECTING THE ENVIRONMENT, AND 3. INTRODUCTION • Nothing is more important than public and
SUPPORTING OUR COMMUNITIES:
This Code of Conduct establishes a set of
7. CONCERNS & employee safety.
• Maintain an absolute commitment to safety standard expectations for employee conduct. INVESTIGATIONS • We must create an environment at
KUWAITSTEEL where employees feel free
for ourselves and others. Employee should not engage in any such activity to raise all safety-related issues without
• Take accountability for actions and that would impair their job performance, cause RAISING CONCERNS:
peer pressure or fear of reprisal.
decisions. damage to KUWAITSTEEL or public property, • We must encourage open and honest
We are all expected to communicate honestly
• Demonstrate through actions a commitment endanger their safety or the safety of others, communication on safety, so that we
and openly with supervisors and others in
to the well-being of the community and the or directly or indirectly affect KUWAITSTEEL’s identify and eliminate unsafe situations and
leadership positions and, in good faith, raise
environment. reputation or image. avoid incidents and injuries.
concerns—including those about safety,
• Can be counted on to deliver and meet
possible misconduct, and violations of laws,
goals and objectives. We acknowledge and reward safe behavior and
regulations or internal requirements.
IF YOU HAVE SUPERVISORY OR MANAGERIAL practices to encourage our employees and to
POSITION, YOU HAVE ADDITIONAL When concerns are raised, employees in reinforce continuous learning.
WE WORK TOGETHER AS A TEAM AND RESPONSIBILITY: supervisory and other leadership positions are
ARE COMMITTED TO EXCELLENCE AND expected to: SAFETY COMMITMENT:
INNOVATION: • Educate your employees on this Code of
• Listen to understand.
Conduct and the requirements applicable
• Take ownership of team goals and are • Take concerns seriously. • We will train, equip and qualify our people
to your employees’ work activities.
accountable for own part in the process. • When appropriate, contact Human to work safely.
• Promote compliance with this Code of
• Promote teamwork among groups. Resources to investigate. • We will design, operate and maintain our
Conduct and other relevant policies,
• Listen to input from teammates to reach the • Take any appropriate action in response to systems with the highest regard for the
standards, and procedures.
best solution. investigation findings in a timely manner. safety and well-being of all.
• Report suspicions or allegations of
• Work to create partnerships and to • Follow up with those employees who raised • We will identify and address the underlying
employee misconduct in accordance with
collaborate across functions. the concern. causes of incidents to prevent them from
company procedures.
recurring.
 PERSONAL SAFETY COMMITMENT: WEAPONS IN THE WORKPLACE: outside of normal working hours, for example, Only the authorized personnel by the
breaks, lunchtime. management is/are permitted to post material
• I will make my personal safety and the Employees are not allowed to bring, on a social media website in the company’s
safety of my coworkers and the public my carry, store, or use any type of weapon on You should not engage in any activity which name and behalf. Employees are not allowed to
highest priority. KUWAITSTEEL’s-owned, leased, or rented is illegal, offensive or likely to have negative publish any materials related to KUWAITSTEEL
• I will make sure I understand how to do the property; in a KUWAITSTEEL’s-owned, leased, effects for the company. i.e journals, books, market studies,etc…Anyone
work safely before I start the job. or rented vehicle or at a job site, whether on or who breaches this restriction will be subject to
• I will speak up about any safety concerns. off duty. KUWAITSTEEL employs software to block some the company’s disciplinary procedure.
• I will look for safety hazards and intervene non-business related and offensive websites.
to stop unsafe acts. GAMBLING IN THE WORKPLACE: You must not use company equipment to • Contact by external parties related to
• I will close out and properly document my access the internet either from within or from media must be immediately addressed
work. Gambling while at work and using company outside the company network using a 3rd party to authorized department. No response
assets for gambling are prohibited, including dial up ISP on your company computer. should be taken from employee against
FITNESS FOR DUTY: during breaks. For purposes of this standard, other parties regardless to the simplicity of
“gambling” is defined as playing a game for Staff should be aware that emails and any the matter.
We recognize that indiscriminate use of alcohol money or property or betting on an uncertain use of the internet and social media websites • Prior approval must be taken from
and drugs can adversely impact the well-being outcome. (whether or not accessed for work purposes) authorized department to participate in any
of individuals, their families and the community may be monitored and, where breaches of this mutli-media matters.
as a whole. policy are found, action may be taken under the • KUWAITSTEEL’s trademark and logos

You are expected to be mentally and physically

10. IT POLICIES company’s Disciplinary Procedure. are not allowed to be used in any media
channel.
fit for work. While on and off duty, you may not COMPUTER AND SYSTEM SECURITY: SOCIAL MEDIA:
be under the influence of alcohol or any drugs
that impair your ability to perform your work
safely and efficiently. Never use, possess,
Employees are responsible for ensuring the
security of KUWAITSTEEL by complying
These days, the reach of social media is
wider than ever. While social media can
11. MOBILE PHONE
sell, offer to sell, transfer, provide, share, or with the company’s information security help KUWAITSTEEL build and strengthen POLICY
purchase alcohol, drugs or any others which standards. Please refer IT policies for complete relationships with our customers, employees
are prohibited by the Law of Kuwait. understanding. and community members, it also has the The purpose of this policy is to outline what
potential to negatively impact the public’s the Company considers to be acceptable and
RESPONSIBILITY: perception of KUWAITSTEEL or your personal unacceptable while using mobile phones at
10 11
DO THESE:
or professional reputation. work.
• Notifying a Supervisor or Human Resources • Use only approved, authorized
if any employee, a Contractor, or other and properly licensed software on When we refer to social media activity, it Mobile phones can be both disruptive (in terms
worker are believed not to be fit for duty KUWAITSTEEL computer systems. includes: of productivity and concentration levels) and
due to the misuse of Drugs, Alcohol or • Connect only KUWAITSTEEL- dangerous (from a health and safety point of
Medications. authorized computers and equipment to • All types of posts and other view). Mobile phone use in the workplace can
• Raising awareness, through the KUWAITSTEEL networks. communications on the Internet; also risk breaches of confidentiality.
dissemination of information, education • Posts on social networking sites such as
DON’T DO THESE: Facebook, Twitter, LinkedIn and others. This policy is linked with the Company’s Health
and training by promoting healthy life styles
• Blogs and other online journals and diaries; and Safety Policy. We, as an employer, have a
among our employees and their families. • Don’t share passwords or other access
• Bulletin boards and chat rooms; duty to ensure that the working environment is
• Motivating those employees who have an credentials with any other person or group,
• Posts of video/audio on media-sharing safe and that safe policies and practices are
alcohol/drug problem, to seek assistance and don’t use another person’s password.
sites, such as YouTube, etc. adopted.
while maintaining confidentiality about such • Don’t attempt to degrade the performance
cases. of KUWAITSTEEL systems or deprive This policy will apply differently to individual
• Adhering to the legal and moral standards KUWAITSTEEL respects your right to members of staff and what is acceptable will
access to authorized users.
as set into force by the laws of State of participate in social media and understands depend on the type of work being undertaken
• Don’t attempt to avoid or attack security
Kuwait. that your time outside of work is your own. and the working environment. We expect all
controls on a computer system or network.
• Zero Tolerance for KUWAITSTEEL and KUWAITSTEEL also values its established employees to adopt a common-sense approach
• Don’t access or download sexually
Non- KUWAITSTEEL employees. brand reputation and goodwill relationships, in this regard.
suggestive or explicit, gaming, file sharing,
which are important corporate assets. Whether
or other inappropriate files or websites.
or not you consider yourself a Tweeter,Blogger SCOPE:
• Don’t store inappropriate or pirated content
9. WORKPLACE VIOLENCE on company equipment.
• Don’t use or accept unofficial email
or Facebooker, it’s important to understand
how to use social media appropriately and All references to “mobile phones” in this policy
effectively. include any personal mobile phone or electronic
KUWAITSTEEL is committed to maintaining addresses i.e hotmail.com,gmail. device capable of remote communication,
a safe and secure workplace and working com,yahoo.com..etc. such as a smart phone or a Personal Digital
If you engage in social media activity that
environment. Acts or threats of physical identifies you as a KUWAITSTEEL employee, Assistant.
violence, harassment, nuisance, damage, and USE OF THE INTERNET AND EMAIL:
or your work at KUWAITSTEEL, even if done off This policy relates to all forms of
similar activities are not tolerated. premises and while off-duty, you could affect
Limited personal use of the internet and of communication, including, but not limited
KUWAITSTEEL’s reputation. to, phone (and video) calls, text (or picture)
email at work is acceptable provided it does
not interfere with or impede your normal duties. messages, emails and instant messages.
Such use should take place substantially
 The “use” of a mobile phone also includes The use of a mobile telephone in the office CONFIDENTIALITY: that you obtained in the course of your
accessing the internet, for any purpose, on a areas of the Company premises is acceptable employment with KUWAITSTEEL is a violation of
mobile phone. for business-related calls. The company will All employees owe the Company a duty of this Code of Conduct and may be illegal.
issue business mobile phones on a need basis confidentiality. Employees should not reveal or Confidential information includes all nonpublic
For the avoidance of doubt, employees are to entitled employees. Former mobile phone disclose any confidential information about the information that is valuable to KUWAITSTEEL
prohibited from using mobile phones to access allowance policy will cease. Company, its business or operations. or harmful to KUWAITSTEEL or our customers
social media sites during the working day. if disclosed. There are four types of confidential
Personal calls are also allowed, but should be An employee using a mobile phone at work proprietary nonpublic information.
LIGHT AND HEAVY VEHICLES, UTILITY CLASS kept to an acceptable level and not affect your may inadvertently risk breaching their duty of
VEHICLES, CRANE AND LIFTING EQUIPMENT, work or that of your team and shall be made confidentiality. For example, by sending a photo COMPANY INFORMATION:
OTHER MOBILE EQUIPMENT: preferably during employees’ breaks only. which reveals the location of a specific job or
contract. Company information includes products
Drivers are strictly prohibited from using mobile TECHNICAL STAFF: & services, financial information such as
phones during the working day. All employees should be mindful of their duty company’s budget, revenue, expenditures, any
Technical staff should refrain from bringing their of confidentiality at all times – particularly when financial reports, company’s official documents,
Mobile phones can be used during breaks mobile phones to control pulpits, workstations, using mobile phones or accessing the internet projects & planning information...etc.
and lunch time periods, provided it is safe and tool areas, cabins etc. If you choose to bring in the workplace (during breaks and lunch time
reasonable to do so. your mobile phone into work (which is not periods). CUSTOMER INFORMATION:
encouraged) it should be stored in your lockers
Any form of social media communication and only be retrieved during breaks. BREACHES OF THIS POLICY: Customer information includes any information
(Whatsapp, Viber,etc..) is strictly for business about a specific customer that can be used
use only and only during standstill of the The use of a mobile telephone in the office The Company will treat potential breaches of to personally identify a customer, including
equipment. areas of the Company premises is acceptable this policy very seriously. Any employee found such things as name, address, Social Security
for business-related calls. The company will to be in breach of this policy will be subject to number, phone numbers, contact names and
MOBILE PHONES AND DRIVING – GENERAL issue business mobile phones on a need basis disciplinary action under the disciplinary policy. billing data such as balance owed or energy
REMARK: to entitled employees. Former mobile phone usage.
allowance policy will cease. Breaches relating to driving and confidentiality
It is against the law to use a hand-held mobile will be treated as a gross misconduct offence. EMPLOYEE INFORMATION:
phone when driving. Personal calls are also allowed, but should be
kept to an acceptable level and not affect your Employee information includes information

12 Employees are strictly prohibited from using

a hand-held mobile phone at any time when
work or that of your team and shall be made
preferably during employees’ breaks only and 12. CONFIDENTIALITY OF about a specific employee, including such
things as name, home address, Social Security 13
driving, or in charge of, a Company vehicle. from either changing rooms or the canteen or INFORMATION number, personal phone numbers, benefits,
designated smoking areas. images, photographs and performance
The Company will not be responsible for You may have access to confidential proprietary evaluations.
any civil or criminal liability resulting from an CAMERA PHONES: nonpublic information on the job. You may
employee being caught using a mobile phone work with information that contains personally • Never disclose such information to another
whilst driving. The majority of mobile phones now have a built- identifiable material about KUWAITSTEEL, employee, shareholder or a third party
in camera (with video functionality). Employees employees or customers. Maintain the without appropriate approval.
It is not illegal to use a hands-free mobile are strictly prohibited from taking any photos (or confidentiality of information entrusted to you • Forward requests for employee information
phone or a sat-nav (satellite navigation system) videographing) at any time during the work day. by KUWAITSTEEL and our customers, except and references to your Human Resources
however they can be a distraction. Employees This applies equally to all staff. when disclosure is properly authorized or representative.
are discouraged from using these devices, legally mandated.
unless they are safely affixed by means of a LIABILITY FOR LOSS OR DAMAGE: SUPPLIER INFORMATION INCLUDES PRICING
mobile phone holder. WHEN DEALING WITH CONFIDENTIAL AND CONTRACT INFORMATION:
The risk of losing or causing damage to a INFORMATION:
The Company applies zero-tolerance in this mobile phone is much greater at work. If • Never disclose supplier information to a
area and any instances of using a mobile phone the individual employee chooses to bring • Never view it for a non-business reason. third party without appropriate approval
whilst driving will be treated as a serious breach their mobile phone into work (which is not • Never use it for personal gain or and a legitimate business reason.
of health and safety and dealt with accordingly. encouraged) it should be stored in a safe and advantage. • You also must comply with any
Employees are only allowed to answer or to private location. • Never share it without appropriate nondisclosure agreement or the
make calls if they are using an appropriate approval. confidentiality provisions of an applicable
hands-free kit, and it is safe and reasonable for The Company will not accept any responsibility • Hard copies of confidential information supplier/vendor agreement.
them to do so. or liability for a mobile phone which is lost, shall only be carried through & • Please exercise caution when using
stolen or damaged on Company premises communicated through sealed envelopes, or handling proprietary information. If
OFFICE STAFF: or during work time. Employees who choose mentioning the word “Confidential” on you have questions, contact the Legal
to bring their mobile phones to work do so at envelope. Department.
Office staff should refrain from keeping their entirely their own risk.
mobile phones on their desks. If you choose to If you are required to share confidential
bring your mobile phone into work (which is not information, make sure that it is appropriately
encouraged) it should be stored in a safe and protected and secure. This obligation continues
private location i.e. a handbag or coat. even after you are no longer employed by
KUWAITSTEEL. Revealing nonpublic information
 13. ENVIRONMENTAL the appearance of obligation. A gift can be
anything of value, including such items as 17. COUNTRY LAWS / EATING OR DRINKING AT PUBLIC PLACES
DURING RAMADAN:
LAWS AND a ticket to a sporting event or play, a non- GENERAL GUIDELINES • Please be aware of the strict rules by the
REGULATIONS business meal, a coffee cup, a free service, a
special discount, or an all- expenses-paid trip to FOR EMPLOYEES government of Kuwait during the holy
a conference or trade show. month of Ramadan. It is strictly prohibited
KUWAITSTEEL is a recognized environmental • Always carry the original Civil ID while to eat or drink during fasting time at public/
leader and is committed to conducting its Note: You may not accept cash or a cash travelling inside Kuwait. open places. Not following the rules may
business in an environmentally sensitive equivalent as a gift. Also, you may not accept • Make sue your Civil ID’s, driving license lead to serious disciplinary action by the
manner. This commitment is consistent with a payment or an item of value that could be are valid. ministry officials including hefty fine and a
our values and our Environmental Policy. It construed as a bribe, or become party to the • Respect traffic rules and always try to jail term.
also makes good business sense. Make sure payment of money or an item of value for the follow them. • Hence, the management of KUWAITSTEEL
that the decisions you make on behalf of purpose of bribery. • Keep your self always updated about the suggests all the employees/contractors for
KUWAITSTEEL reflect this commitment. revisons/changes in the country rules. being cautious and to respectfully follow
KUWAITSTEEL-funded gifts between the country rules. On the other hand, the
For KUWAITSTEEL to be an environmental EMERGENCIES: management will apply company rules if
employees must be made in accordance with
leader, we must first comply fully with all KUWAITSTEEL’s Rewards and Recognition someone found doing this act.
On arrival in Kuwait, employees should
environmental laws and regulations that govern program. • Non-fasting employees can eat & drink only
immediately take note of the emergency
our business. When appropriate, we seek in KUWAITSTEEL Company’s canteen
telephone numbers, the location of the major
ways to go beyond what’s required in how we
hospitals and their facilities, and the quickest
deliver, serve our customers and manage our
operations. 16. HARASSMENT AND route to the nearest hospital with an accident

DISCRIMINATION
and emergency department. 18. DRESS CODE
SMOKING:
Your work colleagues can advise you about the • The purpose of the dress code is to ensure
• Smoking inside all KUWAITSTEEL’s At KUWAITSTEEL, we are committed to best places to go. Keep the telephone number acceptable decorum of the workplace. Any
premises is strictly prohibited including but maintaining a work environment that respects of a taxi service by the telephone in case your clothing chosen by any employee should
not limited inside private offices. Smoking individual differences. Conduct yourself in own transport is unavailable. not be felt offensive by another employee,
is only allowed in designated areas. a professional manner and treat others with attract unnecessary attention. The general
• Electronic cigarettes are to hold the respect, fairness, and dignity. KUWAITSTEEL IN THE CASE OF A MEDICAL EMERGENCY, rule is that your shall dress modestly,
does not tolerate harassment or discrimination, OBSERVE THE FOLLOWING PROCEDURE:
14 15
same concept as a normal cigarette and respect the countries values and respect
undergoes same policy. including behavior, comments, jokes, slurs, health and safety rules once having
• “Shisha” is prohibited in KUWAITSTEEL’s email messages, pictures, photographs, or • If you’re able to, go directly to the nearest crossed KUWAITSTEEL boundaries.
premises, and under no circumstances an other conduct that contributes to an intimidating hospital with an accident and emergency • KUWAITSTEEL requires all employees
employee should decide to do so. or offensive environment. This includes using department. to present themselves in a professional
• Manipulation of smoke detectors is strictly personal electronic devices on company time • If you don’t have your own transport and manner, with regard to attire, personal
prohibited and may result in disciplinary or in company work environments. Remember an ambulance service exists, call the hygiene and appearance.
actions if an employee does so. others may see what you’re doing. ambulance number. The operator will be • KUWAITSTEEL prides itself on the
• Smoking illegal substances is prohibited able to speak both Arabic and English and professional atmosphere it maintains and
and punishable by law. Employees in supervisory and leadership will respond in the language that you use. the positive image that employees present
positions are expected to be familiar with (Although English is widely spoken by the as representatives of the company. This
KUWAITSTEEL standards on harassment emergency services, telephone operators, image is affected by the manner of dress
and discrimination and with relevant federal, etc., it’s useful to know a few appropriate
14. FAVORED TREATMENT state, and local laws. Supervisors who fail words of Arabic to use if the need arises.)
we use within our offices, in the offices
of our clients, and in public when we are
to take action, engage in harassment, or • You will be asked to identify yourself and representing the firm.
Do not use your position to obtain or provide permit harassment to occur not only expose give your address; remember that you • We need to continue to present a
favored treatment for yourself or others with KUWAITSTEEL to liability, they also expose might have to give directions, using nearby professional image toward clients and
whom you have a personal relationship. This themselves to personal liability. Employees also landmarks rather than the street number. the public. It is important that employees
can include any business matter, including can be held personally liable for engaging in • You will also be asked about the type of use their best judgment in dressing
hiring or promoting employees, selecting harassment. medical problem. If it’s life-threatening, appropriately.
contractors or vendors.
such as a heart attack or a serious
You also may not take for your own benefit KUWAITSTEEL has the same expectations for accident, make this clear. BELOW POINTS TO BE TAKEN INTO
any KUWAITSTEEL business opportunity that its contractors, consultants, and suppliers when • Ask for an expected time of arrival of an CONSIDERATION:
is discovered through the use of company they engage in KUWAITSTEEL-related work. ambulance and whether trained medical
property, information or your position. personnel will be in attendance. The • T-shirts with prints are prohibited
answer might persuade you to call a taxi. • Short skirts are prohibited.
• If calling a taxi, make sure that the driver or • Long neck shirts are prohibited.
taxi company understands the urgency of • Sleeveless shirts or T-shirts are prohibited.
15. ACCEPTING OR GIVING the situation. • Colored contact lenses are prohibited.
• Flashy colored hair is prohibited.
GIFTS • Any apparel which prevents the ready
identification of an employee is prohibited
Accepting or giving a gift in a business • Any messy or unprofessional hairstyle is
setting can create a sense of obligation or prohibited.
 • Wearing slippers & sandlas are prohibited
only safety shoes, leather/casual shoes and 20. PREVAILING LAW
athletic shoes are acceptable.
• All non-technical National employees This Code of Conduct is not intended to
may abide the national Kuwaiti dress (i.e. supersede any other applicable legal or
Dishdasha, Ghutra and Eqal). regulatory requirements as per Kuwait Labor
Law. However, since this Code of Conduct
RECEIPT & ACKNOWLEDGEMENT
• All non-technical expat employees should
wear formal work outfits, suits. etc. outlines our expectations regarding employees’
• All technical employees should completely behavior towards their colleagues, supervisors It is my responsibility to read and comply with the policies and
and overall organization. it is to be seen as
wear the safety outfit (PPE) which is
an integral part of the Employment contract.
procedures contained in the Code of Conduct and I acknowledge it
approved by Safety Department.
KUWAITSTEEL may have to take disciplinary with my signature below.
action against employees who repeatedly or
intentionally fail to follow our code of conduct.
19. COMPANY ASSETS Name Employee ID
Disciplinary actions will vary depending on the
violation.
Each of us are responsible for the proper
acquisition, use, maintenance, and disposal of Nothing contained in this Code of Conduct shall
company assets (e.g., materials, equipment, be construed so as to require the commission
tools, real property, information, data, of any act contrary to law and wherever there
intellectual property and funds) and services.
Signature Date
is any conflict between any provision of this
Theft, carelessness, and waste have a negative Code of Conduct and any present or future
impact on KUWAITSTEEL’s success. Do your statute, law, ordinance or regulation, the latter
part to protect the company’s assets and shall prevail, but in such event the provision of
ensure their efficient use. this Agreement affected shall be curtailed and
limited only to the extent necessary to bring it
DO THESE: within legal requirements.

• Acquire assets in compliance with

procurement standards and procedures
• Use company assets only for legal and
16 ethical activities.
• Protect assets—including information, data
and intellectual property— from damage,
unauthorized modification or disclosure,
waste, loss, misuse, or theft.
• Dispose of or transfer assets only with
appropriate written approval.

DON’T DO THESE:

• Don’t misuse or take intangible assets,

including intellectual property or nonpublic
information about KUWAITSTEEL or
others that you obtain in the course of
your job. This responsibility continues
even when you’re no longer employed by
KUWAITSTEEL.
• Don’t install, rearrange, remove, or
tamper with company metering or service
equipment without proper approval and
authorization.
• Don’t commingle company funds with
personal funds.
• Don’t take or misuse company property,
funds, or service.
• Don’t use KUWAITSTEEL assets for private
commercial enterprises or personal gain.
Definitions:
For the purpose of this Code of conduct: --
KUWAITSTEEL means United Steel Industrial
Co. (KSCC) and all its subsidiaries, affiliates
(either current or future) and predecessors.
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