Our Code of Business Conduct

“Our Code, Our Conduct”

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A Message from Amin H. Nasser
Saudi Aramco’s achievements are grounded in the diligence and dedication of its people,
the vast energy resources with which it is entrusted, the strength of the Company’s
systems and processes, and the tireless efforts of previous generations of Aramcons.

One of the most critical enablers of our past and future success is the ethical behavior of
our employees and the integrity of our organization. No company can be a leader unless
its people demonstrate consistent ethical conduct and close adherence to its core values.
That’s why we have set high standards of personal and professional behavior for
ourselves as well as those with whom we conduct business.

Of course, in our complex, fast-paced work environment, and given the incredible
diversity of our operations, it’s impossible to dictate the appropriate course of behavior
for every sensitive or questionable situation that might arise. That’s why our Code of
Conduct makes clear the high standards that we demand of ourselves and our business
associates, regardless of circumstances, and which help us maintain our individual and
institutional integrity.

I encourage every employee to read, utilize and refer as necessary to the Code of
Conduct, to challenge yourself to meet the high ethical standards we set for ourselves,
and to hold others accountable for their adherence to this code. Our shared success
today and in the future rests on our values of accountability, citizenship, integrity,
safety, and excellence, and that we are all judged by the decisions we make and the
actions we take every single day.

Amin H. Nasser
President & CEO

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Table of contents

A Message from Our Commitment to Shareholders

Amin H. Nasser…….……………………….2 and the Company

Our Values………………………………………4 Accurate records and disclosures………13

Use of assets……………………………………13
Introduction Confidential information………………….13
External communications…………………14
Our Code, Our Conduct……………………..5 Information and operational technology
systems…………………………………………..14
Our Commitment to Integrity Conflicts of interest………………………….14

When the right action is not clear……….6 Our Commitment to the

Speak up…………………………………….…….7 Communities Where We Operate
Non-retaliation………………………………….7
Our responsibilities as employees……….8 Compliance with Laws……….…………….15
Additional responsibilities of Human rights…………………….……………15
managers…………………………………………8 Charitable activities…………………………15

Our Commitment to Safety and Questions………………………………………16

Environmental Protection

Safety and environment…………………….9

Our Commitment to Each Other

Respect……………………………….…………10
Personal privacy…………………….……….10

Our Commitment to the Global

Marketplace

Competition and antitrust………….….….11

Anti-bribery and anti-corruption….……11
Gifts, meals and entertainment….………11
Anti-money laundering…………………….12
Insider trading…………………………..……12
International trade compliance…………12

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Our Values
We are committed to living our corporate Values at all times.

Our behavior is what defines us — as a company, as employees, as people. Everything

we do is anchored by our Values: integrity, excellence, safety, accountability, and
citizenship. Our Values are the foundation of Our Code of Business Conduct and the
way we do business. When faced with any decision, we consider how each option aligns
with these values.

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Introduction

Our Code, Our Conduct

Our Code of Business Conduct applies to the employees (often referred to as “we”, “us”
or “you” in this Code), directors, and contract employees of Saudi Aramco, its
subsidiaries and controlled affiliates (the “Company”). It outlines fundamental
standards of legal and ethical behavior. We expect that anyone doing business with the
Company or acting on its behalf will follow these principles.

The purpose of Our Code of Business Conduct is to help us fulfill the ethical
commitments we have made to each other, our Company, our stakeholders, and
ourselves. The Code does not and could not address every possible ethical or legal
situation. We provide many more detailed policies and procedures to guide you in those
situations.

Protect yourself and our Company by always doing the right thing and using the Code
and our Values to act as your guide. A violation of the Code may result in negative
consequences, up to and including termination and even legal action against you or us.

By behaving legally, ethically, and responsibly, we can all play a part in upholding our
reputation around the world.

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Our Commitment to Integrity
We are committed to acting ethically and following legal standards in conducting our
business.

When the right action is not clear

Not all business decisions are clear. We provide the summary guide below to help you
evaluate difficult or ethics-related decisions and point you in the right direction.

If you find yourself in a situation where the right thing to do is not clear, ask yourself the
questions below. If the answer to any of these questions is not a clear “Yes”, then stop
and talk to your supervisor, another manager, or call the Hotline.

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Speak up
We rely on people in every part of our business to speak up about issues and concerns to
improve our operations and act with integrity. People who come forward with concerns
play an important role in maintaining our ethical workplace. You are expected to report
suspected violations of the law, policies, and the Code.

To encourage an open, candid culture, we offer several channels for you to ask questions
and speak up:

 Your supervisor or manager

 Another member of Management
 Personnel
 Compliance
 Internal Auditing
 Business Ethics
 Corporate Security
 The Hotline

Non-retaliation

Regardless of the channel you use to speak up, we are committed to addressing the issue
fairly.

The Company will not tolerate retaliation or discrimination against any person for raising
a genuine concern or assisting in an investigation.

Retaliation can take many forms, including threats, intimidation, harassment, bullying,
humiliation, negatively changing work responsibilities or conditions, or raising issues
against someone maliciously or in bad faith. Anyone found to have engaged in retaliation
is subject to disciplinary action, up to and including dismissal.

If you feel you have been retaliated against for raising an issue or concern and feel that
you cannot raise this issue through other reporting channels, please contact the Hotline.

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Our responsibilities as employees
Each of us has a responsibility to:

 Read, understand and follow Our Code of Business Conduct

 Know the laws and policies that apply to us and follow them
 Ask questions if we are not sure about the right thing to do
 Report situations that we believe violate the Code
 Cooperate with any investigation of potential violations of the Code, law, or
regulation

Additional responsibilities of managers

Supervisors and managers have additional responsibilities to:

 Be a role model of our Values and the Code

 Communicate with your team members so that they understand our Values, the
Code, and the policies and procedures that apply to their jobs
 Listen to concerns about potential violations of the Code, and address them
without retaliation
 Hold yourself and your team members accountable for acting in accordance with
the Code and our Values

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Our Commitment to Safety and Environmental
Protection
We are committed to conducting our operations safely and to protecting the
environment of the communities in which we operate.

Safety and environment

We are committed to providing a safe workplace. We are also committed to protecting

the environment and promoting safety in the communities where we operate. We strive
to conserve natural resources and minimize the environmental footprint of our
activities.

To do your part in keeping each of us safe:

 Follow all safety, environment, and emergency preparedness standards that

apply to you and your job
 Stop your work or the work of others if you see an immediate safety threat
 Report any actual or potential health, safety or environmental issues immediately
to your supervisor and any others designated at your facility - never assume that
someone else has already reported it

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Our Commitment to Each Other
We are committed to providing a respectful workplace for all our employees and those
with whom we work.

Respect
We are committed to treating each one of our employees and others with respect. To
maintain a respectful workplace:

 Treat others with dignity

 Do not engage in discrimination
 Do not harass
o Do not bully or behave in a hostile or intimidating manner
o Do not engage in or tolerate harassment of any nature
o Be considerate in all your communications - offensive messages,
derogatory remarks, and inappropriate jokes are never acceptable

Personal privacy

We respect the privacy of those who work for the Company, those who have worked for
the Company, those with whom we do business, and those we support. Your role is to:

 Protect the personal data of fellow employees and others with whom we do
business and support
 Obtain and use personal data only for legitimate business purposes, and only if
you have a legitimate business need to know
 Follow any privacy policies and procedures applicable to you

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Our Commitment to the Global Marketplace
We are committed to adhering to the law everywhere we do business.

Competition and antitrust

We will comply with all competition laws that apply to us. These laws are designed to
promote fair competition. You must always follow applicable laws, Company policies
and procedures, and except where permitted by them, you must never:

 Enter into an agreement with competitors, formal or informal, that sets prices for
customers, or allocates distribution, customers or territories
 Agree with competitors, formally or informally, to use or refuse to use a given
company as a business partner

Anti-bribery and anti-corruption

We do not bribe or accept bribes or kickbacks. To ensure we make business decisions

based on objective criteria, and to avoid violating laws prohibiting bribery and
corruption:

 Never offer or provide bribes or kickbacks in any form

 Never request or accept a bribe or kickback
 Be especially careful when interacting with government officials, which include
employees of state-owned enterprises. Anything of value can potentially be
considered a bribe, not just cash or expensive gifts. For example, making
contributions to government officials’ favored charities or employing their
relatives may violate the law under certain circumstances.
 Use agents and others acting on our behalf only after they have been approved
under all applicable Company policies and procedures. Do not use a third party
to do what the Company could not lawfully do itself.
 Report any request for, or offer of, a bribe or kickback
 Follow all applicable Company policies and procedures

Gifts, meals, and entertainment

Gifts, meals, and entertainment are customary in many parts of the world where we do
business. Offer, give or accept a gift, meal or entertainment only if it:

 Has a legitimate business purpose or is provided on a customary gift-giving

occasion
 Is legal, reasonable in value, and consistent with customary business practices
 Would not cause embarrassment to the employee or the Company if publicly
disclosed
 Is permissible under our policies and procedures and the policies and procedures
of the donor or recipient’s employer, as applicable.

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  Is not intended to and would not be viewed as a bribe, kickback, or other
improper payment

Anti-money laundering
We comply with laws which prohibit money laundering. Money laundering involves
hiding proceeds of criminal activity, or making them appear as if they were legitimately
acquired. To help prevent money laundering:

 Know our business partners and counterparties

 Follow all applicable Company policies and procedures
 Promptly report any suspicious transactions

Insider trading
Various laws prohibit trading stocks and other securities based on “material”
information that is not publicly known. “Material” means information that investors
would find valuable in making decisions about whether to buy, sell or hold a stock or
other security. To protect yourself and the Company:

 Do not buy or sell Company stocks, bonds or any other financial investments if
you are in possession of material information about the Company that is not
known to the investing public
 Do not buy or sell stocks, bonds, or any other financial investments involving
other companies if you are in possession of material information about such
companies due to your employment at the Company and such information is not
known to the investing public
 Do not provide material non-public information to others, including friends and
relatives

International trade compliance

Products, technology, software, and information are all subject to trade compliance
laws. We comply with all export controls, economic sanctions, customs, and anti-
boycott laws. To help us comply, your responsibility is to:

 Make sure all imports and exports are accurately classified, valued, and labelled
and receive the necessary approvals
 Understand the trade control laws that apply to the countries and parties with
which you are dealing
 Abide by our trade compliance policy and procedures

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Our Commitment to Shareholders and the
Company
We are committed to being responsible stewards of our assets.

Accurate records and disclosures

Accurate business records are essential for us to manage our Company. Financial
disclosures based on these records must always be truthful and complete. Regardless of
your position, it is important for you to:

 Be honest, accurate, and complete in every record you create or approve,

including safety, time, expenses, human resources, and every other type of
business record
 Accurately record all funds, transactions, and assets - never keep funds or assets
off the books for any reason
 Remember that email and other electronic communications may be business
records, so avoid exaggeration and language that would be embarrassing or
harmful if read by someone outside the Company
 Create, retain, protect, and dispose of records according to the policies and
procedures of your business

Use of assets
We are all responsible for the proper use of Company assets. Assets include facilities,
equipment, tools, vehicles, supplies, resources, and information. To safeguard our
assets:

 Follow the applicable procedures to ensure safeguarding our financial, physical,

and other assets
 Do not take or use our assets for your personal benefit, or allow them to be sold,
given away or used by others without proper authorization

Confidential information
Our confidential information must be protected. To keep confidential information safe,
you have a responsibility to:

 Recognize the many types of proprietary or confidential information, including

any non-public plans, financial data, reserve estimates, processes, formulas, and
information about employees, other individuals, and business partners
 Not communicate this information outside the Company without proper
authorization, and not share it internally unless the other person has a legitimate
business need to know
 Take care in discussing our business in any public setting

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  Be sure that your external emails, texts, web postings, and social messages are
appropriate and don’t reveal confidential information

External communications

We are committed to making timely, full, and accurate disclosures in public filings and
in communicating to the media and external parties. Each of us has a responsibility to:

 Keep Company confidential information confidential and safe - do not share

confidential information through social media channels
 Avoid being seen as speaking on behalf of the Company, including in
communications with investors or the media, unless your communication has
been specifically approved by Investor Relations or Corporate Affairs

Information and operational technology systems

Without secure technology we could not do business. To protect our information and
operational technology, you have a vital role to:

 Only use Company-provided computer equipment, phones, and internet/intranet

services as permitted
 Safeguard your Company equipment, especially when you are not at one of our
facilities
 Be vigilant against cyber-attacks and scams. Do not click on suspicious links or
open suspicious looking emails or messages. Use caution when downloading files
and do not download from unknown sources.
 Promptly report any potential or actual loss of our information, potential or
actual unauthorized access to our technology, or any potential or actual breach of
our systems or data

Conflicts of interest
We rely on our employees to avoid situations in which their personal interests may
conflict with the Company’s business. An actual, potential or even perceived conflict of
interest could jeopardize both your reputation and the Company’s. Follow established
procedures to identify, avoid and disclose any potential conflicts of interest, such as:

 Owning or acquiring a personal interest in a business that competes with, does

business with, or seeks to do business with the Company or any of our vendors,
contractors, subcontractors or customers
 Acting as an independent consultant to, holding a position in, or engaging in
activities of any of our vendors, contractors, subcontractors, or customers
 Taking advantage of any Company property, information or opportunities for
personal gain

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Our Commitment to the Communities Where We
Operate
We are committed to being a good corporate citizen everywhere we do business.

Compliance with Laws

The first responsibility of being a good citizen is to obey the law. We comply with the
applicable laws and regulations everywhere we conduct business. To help us comply,
you:

 Are responsible for obeying laws and regulations where you work. Failure to do
so could lead to negative consequences for you and/or the Company.
 Must promptly report any actual or potential violation

Human rights
We are committed to the health and safety of our employees. We require our suppliers
to demonstrate a similar commitment and to source all goods or services from third
parties that meet, as a minimum, country of origin standards for health, safety, working
hours, pay and employment conditions. To help us comply, your responsibility is to:
 Follow all applicable labor laws and regulations in the countries in which we do
business
 Promptly report any actual or potential violations

Charitable activities
We have a long history of providing charitable, educational, humanitarian, scientific and
other support to the communities in which we operate or do business. We donate and
partner with vetted organizations and institutions only. To help us be a good citizen,
only make charitable contributions on behalf of the Company as authorized, and in
accordance with our donations program and guidelines.

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Questions?
If you have any questions about this Policy, please contact the Corporate Compliance
Department at [email protected] . You may also contact the Saudi Aramco
General Auditor Hotline.

The Saudi Aramco General Auditor Hotline number and email address are as
follows:

+966-13-874-3333
[email protected]

Policy Version History Approvals Effective Date Last Date

Owner Reviewed
Law 1.0 Board May 2018 N/A

If you are using a paper copy of this document, please verify that it is current.

The use of terms such as “Company,” “Saudi Aramco,” “organization,” “it(s),” “our(s),”
“we,” and “us,” and of abbreviated titles, are used for convenience and do not describe the
individual status of any legal entity or corporate relationship, or to indicate that Saudi Aramco is
conducting commercial activities outside the Kingdom of Saudi Arabia. In addition, nothing in
this Code creates a contract of employment.

Document Reference:
“Corporate Policy – Global: Our Code of Business Conduct – CP-1(GB)”

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