Coconduct e Revision

TASWEEQ CODE OF CONDUCT
Qatar International Petroleum Marketing Company Limited (Tasweeq) Q.J.S.C. - COC - 01 Tasweeq Code of Conduct V 1.8 June 16, 2013
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Qatar International Petroleum Marketing Company Limited (Tasweeq) Q.J.s.C
COC - 01 Tasweeq Code of Conduct V 1.8 June 16, 2013
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1. Introduction 3
2. Application of the Code of Conduct 4
3. Complying with Laws and Regulations 4
4. Code of Ethics for the Chief Executive Officer, Executive Director Finance, Executive
Director Planning and senior Finance staff
5
5. Books and Records 7
6. Conflict of Interest 8
7. Competition / Antitrust Law 9
8. Bribery, Corruption and Improper Payments 12
9. Gifts and Entertainment 13
10. Money Laundering 14
11. Business Communications 15
12. Protection and Use of Assets 16
13. Discrimination and Harassment 17
14. Protection of Privacy of Personal Data 18
15. Drugs and Alcohol 18
16. Health, Safety and Environment 19
17. Clarifications, Reporting, Complaints and Other Issues 20
18. Appendices
21
Appendix I 21
Appendix II 21
Appendix III 22
Appendix IV 23
Appendix V 24
CONTENTS
2013 Qatar International Petroleum Marketing Company Limited (Tasweeq) Q.J.S.C. All Rights Reserved.

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1. INTRODUCTION
TASWEEQ operates pursuant to specific mandates
established by Law of the State of Qatar. That Law provides,
among other things, that:

TASWEEQ shall only act in accordance with this Law and the
following Core Principles, which are hereby determined to be
in the national interest of the State of Qatar. TASWEEQ shall
establish a business model, governance structure and
operating policies that are consistent with such Core
Principles:

THE CORE PRINCIPLES ARE:
*
Provide an effective and efficient marketing arm in support
of the Governments petroleum development activities

Compete more effectively in global markets
Maintain a positive investment environment in the State of
Qatar for foreign investors
Maximise the global market value of the Regulated Products
exported from the State of Qatar
Maximise the effectiveness and efficiency of the marketing
operations for the benefit of the Government and the
Producing Entities
Treat all Producing Entities and their shareholders in a fair
and equitable manner
Ensure that all services of material value are acquired at
arms length on competitive terms
Avoid adversely affecting production operations
Ensure effective management and mitigation of commercial
risk
Maintain high levels of ethics and business integrity
Provide a high level of transparency in relation to its
business conduct and internal operations.
And comply with all applicable legal requirements.
TASWEEQs Memorandum and Articles of Association,
have been prescribed by the Council of Ministers in
conformity with the Law and Core Principles.

TASWEEQ Directors, officers and employees shall
at all times act in conformity with the State of
Qatars policy and legal mandates, shall apply high
standards of integrity in all business transactions,
ensure that sound commercial practices are applied
and shall observe this Code of Conduct both to the
letter and spirit. In the event of conflict between any
provision of this Code of Conduct and the Law,
Memo and Articles of Association the latter shall
prevail (1).

The Code of Conduct is intended to be comprehensive
and easily understood. In some instances, however,
additional guidance might be required for unusual or
unanticipated circumstances or for those directly
involved with certain particular areas. Employees shall
in those circumstances in first instance seek further
guidance and clarifications from their direct supervisors.

The Code of Conduct seeks to provide guidance and
confidential channels to raise concerns, seek advice or
report violations.
1. The Law and the Memorandum and Articles of Association, are attached to this Code of Conduct. This Code of Conduct may be supplemented by Interpretive Guidance which may be issued
from time to time. Additional contemporaneous interpretative materials are in the possession of the General Counsel, who is available to assist in resolving any questions of interpretation which
may arise.
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2. APPLICATION OF THE CODE OF CONDUCT
The Code of Conduct has been developed to carry out
TASWEEQs mandates and to ensure that all business
dealings are conducted with required ethical standards and
in compliance with applicable laws and regulations. The
obligations under the Code of Conduct apply to, Directors,
officers and employees of TASWEEQ as well as to the
relationships with customers, government officials,
Producing Entities and their shareholders, officers and
employees, third-party contractors, vendors, and
consultants. Adherence to its spirit, as well as its specific
provisions, is absolutely critical for all who conduct
TASWEEQ business, or act on behalf of TASWEEQ or
those who maintain other relationships with TASWEEQ.
TASWEEQ will ensure that third parties are aware of the
contents of the Code of Conduct by providing them with a copy
and by drafting specific references to and its requirements
under the Code of Conduct in all contracts and agreements
entered into with third parties.

In some areas covered by this Code of Conduct, the required
standards and obligations are supplemented by additional
material in the attached Appendices.
3. COMPLYING WITH LAWS AND REGULATIONS
TASWEEQ, its Directors, officers and employees are
required to comply with all laws and regulations applicable
to its operations. TASWEEQ business activities may also
take place or have effects outside the State of Qatar and
thus may be subject to the laws, rules and regulations of
jurisdictions other than those of the State of Qatar. These
laws, which may vary in different jurisdictions, affect
TASWEEQs behavior and the dealings with customers,
contractors and competitors in general. TASWEEQ, its
Directors, officers and employees are responsible for
understanding these laws and regulations and shall obtain
Legal Counsels advice as required. Compliance is an
operational obligation of all Directors, officers and
employees when conducting TASWEEQ business
activities and they are personally accountable for applying
the highest standards under all circumstances.
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4. CODE OF ETHICS FOR:
THE CHIEF EXECUTIVE OFFICER, EXECUTIVE DIRECTOR FINANCE,
EXECUTVE DIRECTOR PLANNING AND SENIOR FINANCE STAFF
TASWEEQ has a Code of Conduct applicable to all
Directors, Officers and employees and is committed to
uncompromising integrity in the conduct of its business
and of its financial reporting.

The Chief Executive Officer (CEO), Executive Director
Finance, Executive Director Planning, Treasurer and the
Accounting Manager are bound by the provisions set
forth therein relating to honest and ethical conduct,
including the handling of conflicts of interest and
compliance with applicable laws, rules and regulations.

In addition to the Code of Conduct, the CEO, Executive
Director Finance, Executive Director Planning, Treasurer
and Accounting Manager are subject to the following
additional specific policy for dealing with matters related
to Internal Control, Financial Reporting, Disclosure and
Audit.

RESPONSIBILITY
The CEO, Executive Director Finance, Executive Director
Planning, Treasurer and Accounting Manager are
responsible for:

Maintaining accounting records in accordance with
accounting and reporting policies and applicable laws
and regulations, and ensuring that accounting records are
proper, supported, classified, and do not contain any false or
misleading entries.

The protection of confidential or commercially sensitive
information acquired in the course of the performance of
their responsibilities except when otherwise authorized or
legally obligated to disclose.

The retention and/or proper disposal of records in
accordance with established policies and applicable legal
and regulatory requirements.

The prevention of inappropriate communication or
collaboration with competitors or others.
THE SYSTEM OF INTERNAL FINANCIAL CONTROLS
Providing in, all official reports, documents and
communications, including - written and oral disclosures, -
statements and presentations, complete, accurate, timely
and understandable disclosure.

WHILE PERFORMING THEIR DUTIES THEY SHALL:
1. Promptly bring to the attention of the Audit Committee, any
information they may have concerning (1) significant
deficiencies and material weaknesses in the design or
operation of Internal Control over financial reporting which
are likely to adversely affect TASWEEQs records, processes
and reported financial data, and (2) any fraud, whether or not
material, that involves management or other employees.

2. In all circumstances correctly and to the best of their
knowledge represent the facts. They will be considered to
have knowingly misrepresented facts if they (1) make, or
permit or direct another to make, materially false or
misleading entries in financial statements or records (2) fail
to correct materially false and misleading financial
statements or records (3) sign, or permit another to sign, a
document containing materially false and misleading
information or (4) falsely respond, or fail to respond, to
specific inquires of the External Auditor or regulatory
authorities.

3. Not take any action to influence, manipulate, or mislead
independent public or certified public accountants engaged
in the performance of an audit or review of the financial
statements. This having as consequence that (1) The report
on the financial statements is not warranted in the
circumstances, due to material violations of generally
accepted accounting principles, generally accepted auditing
standards, or other applicable standards (2) The auditor
cannot perform the audit, review or other procedures
required by generally accepted auditing standards or other
applicable professional standards (3) The auditor cannot
communicate relevant matters to the Audit Committee.
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4. CODE OF ETHICS FOR:
THE CHIEF EXECUTIVE OFFICER, EXECUTIVE DIRECTOR FINANCE,
EXECUTVE DIRECTOR PLANNING AND SENIOR FINANCE STAFF
(Continued)
4. Never let business dealings on behalf of TASWEEQ be
influenced, or even appear to be influenced, by personal or
family interests.

RESPONSIBILITY FOR REPORTING OF BREACHES
Planning, Treasurer and Accounting Manager shall
promptly bring to the attention of the Audit Committee and
the Ethics and Compliance Committee

Any information they may have concerning evidence of a
material breach of applicable laws, rules or regulations, or
any breach of this Code of Ethics.

Any information they may have concerning conflicts of
interest(actual or apparent) between personal and
professional relationships, involving management or other
employees who have a significant role in financial
reporting, disclosures or internal controls.

INVESTIGATION
TASWEEQ is committed to complying with the letter and
spirit of all applicable laws, rules and regulations and
intends to prevent the occurrence of conduct not in
compliance with this Code of Conduct and to investigate
and halt any such conduct that may occur as soon as
reasonably possible after its discovery.
ASSURANCE OF COMPLIANCE
Planning,Treasurer and Accounting Manager will attach their
confirmation to the Code of Conduct in the following format.

I have read and understand the <CODE OF ETHICS FOR
THE CHIEF EXECUTIVE OFFICER, EXECUTIVE DIRECTOR
FINANCE EXECUTIVE DIRECTOR PLANNING AND SENIOR
FINANCE STAFF>. I will adhere in all respects to the
standards and requirements described and I further
confirm my understanding that for any breach of the Code
of Ethics the disciplinary processes and measures apply
and may ultimately result in dismissal.
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5. BOOKS AND RECORDS
All financial transactions shall be accounted for in
the books of account in an accurate and timely
manner. All accounting entries shall be made
according to established internal controls and
supported by appropriate documentation.

ACCOUNTING AND REPORTING REQUIREMENTS
TASWEEQ is required to follow strict accounting
principles and standards, to report financial information
accurately and completely, and to have appropriate
internal controls and processes to ensure that
accounting and financial reporting complies with
applicable laws.

DOCUMENTATION
Employees shall not intentionally cause documents to be
incorrect and shall not create or participate in the
creation of any records that are intended to conceal
anything that is not proper.

CONTRACTUAL ARRANGEMENTS
All contracts shall be in writing and fully reflect the
undertaking and can only be entered into after
comprehensive legal review. Officers and employees
shall not make unusual financial or commercial
arrangements with a customer, supplier or any third
party, for payments on their behalf to a party not related
to the transaction.

DOCUMENTATION OF COMPLIANCE
Dialogue regarding significant commercial decisions,
discussions with substantial customers and actual or
potential competitors should be consistent with the legal
mandates and with this Code of Conduct and should,
insofar as possible, be in writing or memorialized in
writing. Major Actions should be supported by
documentation of consistency with the mandates
and this Code.

REPORTING
Dishonest, - internal reporting to management, Internal
Audit or during an internal investigation, or - reporting to
third parties,
such as external auditors, is strictly prohibited. This also refers to
not only reporting information inaccurately but also to arranging
and presenting it in a way that is intended to mislead the
recipients.

RECORDS MANAGEMENT
Records and documents are kept for the operation of TASWEEQ
business undertakings and also to meet legal, audit and
regulatory requirements.

All employees shall comply with the TASWEEQ guidelines and
standards in respect of Records Management for the retention
and disposal of documents, information in any media, including
both hard copy and electronic records including email.

AUDIT
All records shall be made available for inspection by Auditors
and / or any other relevant body.
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6. CONFLICT OF INTEREST
All persons in the employment of TASWEEQ shall be
subject to the following principles to guide their behavior
and conduct whilst carrying out their duties in respect of
TASWEEQ commercial business activities or representing
TASWEEQ in any other manner.

GUIDING PRINCIPLES
All officers and persons in the employment of TASWEEQ:

Shall strictly comply with the TASWEEQ: - Code of Conduct
and this Conflict of Interest Policy

Shall perform their duties with high standards of honesty,
integrity and fairness and promote a business environment
which adheres to the same standards.

Shall not have commitments or engage in business activities
or interests outside TASWEEQ: that would affect the proper
conduct of their duties. Participation in non-profit charitable
activities and societies shall be exempted from the
aforementioned.

Shall not have any direct or indirect interest in companies
that enter into contracts with, supply or render services to
TASWEEQ:. Where family members have such interests
these shall be disclosed in writing.

Shall not provide unduly favorable conditions to parties
dealing with TASWEEQ:, which would be detrimental to the
interests of TASWEEQ:.

Shall not make decisions in respect of any transaction or
dealing in which a conflict of interests arises or could arise.
In the event that such circumstance arises, management is
to be notified and shall appoint another employee without
a conflict of interest to perform the activity. A formal report
explaining the conflict or potential conflict of interest shall
be submitted to the Ethics and Compliance Committee.
Shall not accept on their own behalf, spouse or other
relative, favors from third parties in whatsoever form with
respect to the business dealings of TASWEEQ: The
acceptance of business gifts of minor nominal value,
invitations to work related lunches, dinners and
entertainment of reasonable occurrence and value are
acceptable as per the gifts and entertainment policies.

AUTHORIZED EXCEPTIONS
All exceptions to the Conflict of Interest policy shall be
approved by the Board of Directors subject to a formal
recommendation from the Ethics and Compliance
Committee. The Ethics and Compliance Committee has the
sole authority to consider and then recommend exceptions to
the Conflict of Interest policy.
The decision shall be in writing with relevant detail and clear
indication of the expiration date of the permitted exception.

A report of permitted exceptions will be drawn up annually
and considered in the Board of Directors meeting.
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7. COMPETITION / ANTITRUST LAW
DEALING WITH COMPETITORS AND PRODUCING ENTITIES,
SUPPLIERS AND CUSTOMERS
TASWEEQ officers and employees shall conduct all
business undertakings in accordance with the principles
of fair competition and adhere to both the letter and
spirit of applicable competition/antitrust laws and
regulations. TASWEEQ officers and employees shall
avoid any practice that may result in or be perceived to
result in restriction of competition or be perceived to be
doing so.

The objective of competition/antitrust laws, which are also
known as monopoly, fair trade or cartel laws, is to promote
competition and prevent interference with the orderly
functioning of a competitive market system. Competition
must provide the opportunity to compete on price and quality,
in an open market free of anti-competitive restraints.

As the exclusive marketer for Regulated Products exported
from Qatar, TASWEEQ will have involvement with the
Producing Entities, whose shareholders are Qatar Petroleum
and other major International Oil Companies, all of which
may be competitors of TASWEEQ. TASWEEQ officers and
employees must be aware that direct and indirect
relationships with actual or potential competitors raise
antitrust sensitivities and must strictly adhere, both in the
context of relationships with these entities and in connection
with independent actions, to the rules, procedures and
guidance set forth in this Code. TASWEEQ officers and
employees therefore must, at all times, act in compliance
with all applicable competition/antitrust laws.

The competition/antitrust laws are extremely context
dependent. This means that conduct otherwise prohibited or
problematic can be permissible if it can be demonstrated that
it is, in fact, beneficial to free markets or will promote open
competition(2). However, given the serious consequence of
infringing these laws, legal advice should be sought before
any such assumption is made.

Under competition/antitrust laws, companies may not enter
into formal or informal agreements with others which restrict
the functioning of the competitive market, such as price fixing
or dividing clients or territories. Illegally monopolizing or
attempting to monopolize an industry or unlawfully abusing a
dominant position also may constitute a violation of
competition laws, even though there may not be action jointly
with other companies.

CONSEQUENCES OF VIOLATION OF COMPETITION
LAWS AND REGULATIONS
Competition law violations have very severe consequences.
The companies involved can face material fines, whilst
criminal prosecution of individuals may result in personal
fines and or imprisonment. In addition violations may also
result in extremely costly litigation and damages.

DEALING WITH COMPETITORS (INCLUDING
PRODUCING ENTITIES AND THEIR SHAREHOLDERS)
TASWEEQ officers and employees shall not, directly or
indirectly, disclose to, seek from or exchange with
competitors or potential competitors any commercially
sensitive information. They shall not discuss or reach any
agreement or understanding with any competitors or
potential competitors or otherwise participate in the following
or any other matters which might unlawfully restrict or
impede the orderly operation of markets or functioning of the
competitive system:

PRICES - selling prices, price levels or trends, future price
changes or their implementation, or any terms of sale (e.g.,
discounts, promotions, rebates, etc.).

COSTS - including any specific elements of past, present or
future costs to TASWEEQ, a supplier or any competitor.

VOLUMES - of goods or services provided by suppliers
and/or sold to customers.

SALES - (or refusals to sell) to specific customers (i.e., any
division or allocation of customers among competitors or
any group boycott of a customer or potential customer).
2. Always keep in mind that the prime purpose of this section of the Code is the protection of competition and the free operation of markets. The prohibitions and proscriptions of problematic conduct identified in
this section may, in some particular circumstances, be shown to be inappropriate based on demonstration that the conduct or action in question would actually be pro-competitive or beneficial to competition. The
application of this exception to the general rules of this section is a matter requiring careful consideration and review by counsel.
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(Continued)
RESTRICTION ON SELLING - of particular products,
product categories or services or in specific geographical
areas.
PURCHASES - (or refusals to purchase) from any specific
supplier (e.g., any group boycott of a supplier or potential
supplier).
The adoption by any company of CONTROLS OR
LIMITATIONS on products, services, markets or business
methods or practices.

TASWEEQ officers and employees must understand that an
agreement or understanding need not be in writing to constitute
an antitrust violation. An agreement or understanding can be
inferred from circumstantial evidence, i.e., a competitor meeting
followed by an across the board price increase.

DEALING WITH SUPPLIERS
TASWEEQ officers and employees shall not allow a supplier or
a suppliers shareholders to:

Dictate or control RESALE PRICES of the suppliers
product.
Restrict or influence the TERRITORY into which or the
CUSTOMERS to whom TASWEEQ sells on the products.
Restrict TASWEEQ from marketing/selling those
COMPETING PRODUCTS.

DEALING WITH CUSTOMERS
When dealing with customers, TASWEEQ officers
and employees shall not:
Dictate prices at which the customer will resell the product
(RESALE PRICE MAINTENANCE).
Apply any TERRITORIAL or END USE CUSTOMER
RESTRICTION on the customer, i.e. seek to restrict or
influence where and to whom the customer sells the
products - either directly or indirectly (e.g. by creating
incentives which influence customers conduct to similar
effect).
Apply any form of COERCION in the marketing of its
products including forcing the sale of a second or tied
product, forcing a customer to purchase all of its supply
through TASWEEQ, or forcing a customer to deal exclusively
with TASWEEQ.
Offer a customer prices, terms or promotional allowances
services that amount to MORE FAVORABLE TERMS than
those offered to competing customers absent a legitimate,
legally sufficient justification.

GOVERNMENT TECHNICAL COMMITTEE
CONSULTATIONS AND INDUSTRY ORGANIZATION
MEETINGS BETWEEN COMPETITORS
In Technical Committee Consultations, industry association
or similar meetings, involving competitors, communications
shall at all times be strictly limited to those required for the
legitimate purpose of the meeting. In particular, TASWEEQ
officers and employees may discuss and/or develop common
approaches to:
New regulations, terms and conditions or legislation.
Participation in industry-wide litigation or presentations to
judicial and regulatory bodies.
Trends in public opinion (e.g., product concerns, industry
image, etc).
Institutional advertising (i.e. advertising the merits of the
industrys products and services as a whole).
Representation of the industry organization as participant or
observer.
Information about the industry that is of a general nature.

TASWEEQ officers and employees may develop common
standards for products and services, but only in the context
of industry recommendations to, or response to requests
from, regulatory bodies in connection with the adoption of
such standards as legal requirements.

TASWEEQ officers and employees SHALL NOT do the
following at Technical Committee Consultations industry
organization or similar meetings among competitors:
Exchange business statistics.
Discuss or agree upon the elimination of existing
competitors or the impact new entrants would have on
competition.
Exchange competitive information that results in members
not determining their individual business policies on their
own.
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(Continued)
COMPETITION GUIDANCE
There may be circumstances in which TASWEEQ officers or
employees are uncertain as to the appropriate course of action.
In these situations appropriate advice should be sought prior to
commencement of the conduct or action in question.

PRICE OR MARKET MANIPULATION, SENSITIVE
INFORMATION
TASWEEQs legal mandate establishes it as a Trading
Company and requires it to operate in conformity with the
Articles of Association.
The mandate and model establish TASWEEQ as the exclusive
marketer of all Regulated Products produced in Qatar. The
entities producing the Regulated Products include either
directly or through joint venture shareholdings subsidiaries
of International Oil Companies who themselves may market
same products in competition with TASWEEQ. Certain of the
Regulated Products may be traded on Exchanges. Though
TASWEEQ may not take speculative commercial risk in paper
or physical markets with Qatari or non-Qatari product, selected
and controlled use of appropriate hedge instruments to support
physical deliveries of Qatari exports may be employed to
mitigate risk and exposure.

In this context, TASWEEQ Officers and Employees must avoid
participation or the appearance of participation in any action,
transaction or collaboration for the purpose of impairing,
obstructing or defeating normal market functioning. Care
should be exercised: to
avoid any appearance or actuality of improper collaboration,
collusion or information sharing for the purpose of fixing
prices or manipulating markets.
avoid any appearance or actuality of independent action to
manipulate prices or markets in violation of applicable legal
requirements.
assure the protection of confidential, proprietary or sensitive
information which may impact markets or prices.
insure that information which is made available to the public
is accurate, complete and properly disseminated
(Preferential release of commercially sensitive or valuable
information is in most cases problematic and shall be
avoided unless fully justified by circumstances and
protected by procedures).
assure that all product transactions entered into have
valid business purposes and do not present any
appearance of improper efforts to influence product prices
or market behavior.

Any practices which have the effect of either creating the
false impression that certain market activity is occurring
when in fact such activity is unrelated to actual supply and
demand, or any tampering, including physical or economic
withholding of supply, may be considered manipulative and
should not be engaged in unless fully justified by legitimate
business and market considerations.
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8. BRIBERY, CORRUPTION AND IMPROPER
PAYMENTS
BRIBES AND KICKBACKS
Bribes and kickbacks are not appropriate business
behavior and are not allowed.

TASWEEQ does not give or receive, whether directly or
through another party, bribes or other improper advantages
for business or financial gain. No employee may offer, give
or receive any gift or payment which is, or may be seen as
being, a bribe. Any demand for, or offer of, a bribe must be
rejected immediately and reported.

FACILITATION PAYMENTS
TASWEEQ recognizes that certain facilitation payments,
which could occur outside of the State of Qatar, cannot be
avoided completely or immediately, however procedures to
limit their use to small payments for routine actions shall be
in place. Appropriate actions will be taken to fully eliminate
all such payments within a reasonable timeframe.

AGENTS AND INTERMEDIARIES
TASWEEQ shall request all agents and other
intermediaries to abide by and conduct their activities on its
behalf in a manner which is fully compliant with this policy.
The contracts established with agents shall provide for, -
an explicit condition not to pay bribes of any sort or make
facilitation payments and - appropriate provisions to
terminate agreements when any breach occurs. Where
services for routine administrative tasks in respect of -
obtaining permits and expediting customs formalities and
similar services, are retained under contracts, full details
shall be on record of the names, terms of employment
and payments to those agents. All records shall be
available for inspection by auditors and if and when
required by relevant authorities.

POLITICAL CONTRIBUTIONS AND SPONSORSHIPS
TASWEEQ does not make contributions to political
activities, parties, party officials or candidates.
CHARITABLE CONTRIBUTIONS AND SPONSORSHIPS
When charitable contributions are made or sponsorships
established, due care shall be taken to ensure that these are
not used in a manner which would disguise any form of
bribery or could be seen to do so.

FINANCIAL RECORDS AND AUDITING
Supporting documents and accounting records must
accurately describe and reflect the nature of the underlying
transactions. No undisclosed or unrecorded account, fund or
asset will be established or maintained. All records shall be
made available for inspection by Auditors and / or any other
relevant body
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9. GIFTS AND ENTERTAINMENT
In certain circumstances it may be customary or appropriate
to exchange gifts and entertainment with customers,
suppliers, and other business relationships. When receiving or
giving gifts, hospitality and entertainment by TASWEEQ
officers and employees, the objectives, intentions and values
of such arrangements shall be assessed within these
guidelines and undertaken within acceptable practices. In
general all such arrangements shall be - limited to reasonable
and bona expenditures and - not improperly affect, or might
be seen to improperly affect, the outcome of a business
undertaking.

GUIDELINES

Business relationships shall be on an arms length basis and avoid
excessive or lavish gifts or events that may give the appearance of
undue &.Employees may give or accept customary business
amenities, such as meals and entertainment, provided the
expenses involved are kept at a reasonable level and are not
prohibited by known business relations own practices.

RECEIVING GIFTS

Gifts of a commercial or promotional nature are generally
acceptable only if their value does not exceed QR 500. The
following, irrespective of their value, are allowed to the extent they
are not listed in the below section Not Allowed: (i) Promotional
premiums and discounts offered by airlines, hotels, car rental
agencies and restaurants if they are based upon membership in
bonus programs that are offered to travelers generally; (ii) gifts of
the same type distributed at events to all attendees, e.g.
inaugurations and signing ceremonies; and (iii) gifts that are given
to attendees of events through a process governed by chance, e.g.
an attendee gives his business card to or is given a number by an
event organizer or company and the attendee is randomly selected
to receive a gift through a lottery.

NOT ALLOWED:
* Regardless of its value, any form of a gift that obligates an
employee to act in a particular manner with regard to a business
decision. This is considered to be a bribe.
* Soliciting a gift.
* Gifts in cash.

If such gifts are received, the respective supplier or client may
be reminded of TASWEEQs policy if this would not result in an
awkward business situation.
MARKET VALUE OF GIFT
If a recipient is not sure of the value of an item, the employee
shall if possible attempt to determine the fair market value.
As a general rule, if an employee is unable to determine that
fair market value is within the permitted range or if any doubt
exists about whether the gift is excessive in value, the item
shall be turned over to the General Counsel to determine its
value. If the value is greater than the permitted threshold the
General Counsel shall hold the gift in trust on behalf of the
Ethics and Compliance Committee. The Ethics and
Compliance Committee will approve what can be done with
the gift, which may include distribution at general staff
meetings, auctioned at TASWEEQ with proceeds given to a
charitable organization, or directly given to a charitable
organization.

CLARIFICATIONS AND REPORTING
In the event that, when receiving gifts or gratuities, this could
be perceived to be a & of interest, even if the employee does
not believe this would constitute a breach of the guidelines,
they shall inform their manager. Whenever unsure about the
appropriate conduct in any particular circumstance,
employees shall discuss this with the Law Department.

GIVING GIFTS AND GRATUITIES
Similar rules as for receiving gifts apply to the giving of gifts
and due consideration shall be given to business relations
own rules in respect of receiving gifts and entertainment.
Employees shall:
* Take care to avoid giving gifts that are intended to be
innocent but may be seen to be a bribe.
* Inform their managers and obtain approval when
considering giving gifts or gratitude and specifically when
unsure about the appropriate conduct.

Under this Gift and Entertainment Section, the CEO may
approve giving gifts and business amenities of higher value,
provided the gifts and business amenities are not prohibited
by law or known business relations own practices.
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10. MONEY LAUNDERING
TASWEEQ will adopt and follow relevant international
standards and not condone, facilitate or support money
laundering. All officers and staff will comply with all
applicable laws that prohibit money laundering. Before
entering into contractual arrangements with new
counterparties and other relationships as well as when
carrying out occasional transactions a comprehensive
assessment will be made.

BACKGROUND
Money laundering is the process by which individuals or
entities try to conceal illicit funds, or otherwise make these
funds look legitimate.

Trade-based money laundering is defined as the process of
disguising illicit proceeds and moving funds through trade
transactions. This can be achieved amongst others, through
the misrepresentation of price, quantity or quality of imports
or exports. Trade-based money laundering techniques are
frequently used in combination with other money laundering
techniques to further obscure the money trail.

Most countries around the world have laws against money
laundering which prohibit the acceptance or processing of the
proceeds of criminal activities.

In order to ensure that business relationships are only
entered into with counter parties that apply similar standards
and integrity as TASWEEQ, officers and employees shall
apply rigorous screening procedures before counter parties
are considered for commercial undertakings or other
relationships.

KEY ACTIVITIES:
Assess the integrity of potential counterparties and other
business relationships
Communicate with counterparties the expectations in
respect of compliance with TASWEEQ standards
Continue to monitor counterparties business practices and
transactions throughout the course of the relationship to
ensure that the transactions being conducted are consistent
with the counterparties business, including when necessary,
to understand the source of funds.
When suspicions arise in respect of the integrity of a
counterpartys business dealings or intent, Legal counsel
and the Ethics and Compliance officer shall be consulted in
order to agree the appropriate response and measures
which are merited under the specific circumstances,
including terminating the relationship and reporting to the
relevant authorities.

REFERENCES
The Financial Action Task Force on Money Laundering
(FATF) is an inter-governmental body founded in 1989 by the
G8. The purpose of the FATF is to develop policies to
combat money laundering and terrorist financing. The FATF
currently has 33 members, comprising 31 member countries
and territories and 2 regional organizations, amongst them
the GCC.

The Middle East and North Africa Financial Action Task
Force (MENAFATF) is the regional initiative of promoting
and implementing international standards to counter money
laundering and financing terrorism in the region.

Note: Detailed guidance is provided in Counterparty Due
Diligence and record keeping.
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11. BUSINESS COMMUNICATIONS
TASWEEQ and the State of Qatar shall be represented in
the best and most professional manner in all internal and
external communications and preserve the
confidentiality of TASWEEQ information.

COMMUNICATION FORMAT FOR BUSINESS PURPOSES
A written format shall be preferred to ensure proof and
safekeeping. Written communications must contain a clear
identification of TASWEEQ, its address and the individuals
contact details.

MAKING COMMITMENTS
Specific authorizations shall be established for employees
who can enter into commitments.

E-MAIL
E-mail can be used to communicate internally and with third
parties for general information. E-mail should not be used for
time critical business communications with counterparties.

Employees shall exercise due care, caution and etiquette in
sending an e-mail message, these shall not contain material
that is racist, sexist, pornographic, offensive, threatening,
abusive, defamatory, fraudulent, or otherwise inappropriate.

In E-mail communications TASWEEQ and the individuals
contact details shall be contained in the footer. All email
messages shall contain the following disclaimer:

If you have received this e-mail by mistake, please e-mail
the sender by replying to this message, and deleting the
original and all copies. This message is confidential and
may be legally privileged and is intended solely for the
addressee. Access to this message by another person is
not permitted so if you are not the intended recipient,
any disclosure, copying, distribution or action taken or
omitted to be taken in reliance on it, is not allowed and
may be illegal.

TELEPHONE
In order to have records of all trades that are conducted by
telephone, the specific telephone lines will be equipped with
recording devices and all negotiations shall be recorded.
FAX
Fax is the recommended method for communications that
require delivery (and action) within twenty four hours, e.g.
business critical communications.

INSTANT MESSAGING (IM)
IM can be used to communicate internally and with third
parties for general information, indications, and discussions
about deals. IM cannot be used to conclude commercial
transactions.

TELEX
Due to its high cost and declining reliability, the use of telex
should be restricted to essential circumstances.

INTERNET
Downloading data or accessing information from the Internet
that is unprofessional or inappropriate for business use, is
not permitted.

PERMITTED PERSONAL USE
Information and communication systems, including e-mail
and connections to the Internet, shall primarily be used for
appropriate business purposes but limited personal use is
permitted.

MONITORING THE USE OF E-MAIL AND INTERNET
All employee e-mail and Internet usage may be the subject of
monitoring without notice.

CONFIDENTIALITY AND CLASSIFICATION OF
COMMUNICATIONS AND DOCUMENTS
UNCLASSIFIED Information that may be shared without
restrictions.

INTERNAL USE ONLY Information that can be freely
sharedwith employees, but not with third parties.

CONFIDENTIAL Information that should be shared with
selected employees only.

PERSONNEL PRIVATE Staff information that should be
shared with selected employees only.

CLASSIFIED Information that should only be made available
on a strict need-to-know basis.
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12. PROTECTION AND USE OF ASSETS
All officers and employees shall take due care to protect
TASWEEQ assets and ensure their efficient use for their
intended business purposes.

TASWEEQ ASSETS
Assets comprise of, property, company funds, proprietary
information as well as time.

USE OF TASWEEQ ASSETS
All officers and employees are responsible for ensuring that
TASWEEQ assets are not misused or wasted and shall,
devote the necessary time to their work in order to fulfill the
job responsibilities.
not perform non-TASWEEQ related work or solicit personal
business on TASWEEQ premises or while working on
TASWEEQ time.
not use any TASWEEQ assets for personal benefit and
activities except when specifically authorized for limited,
occasional or incidental personal use.
not remove, loan, alter or destroy C property without
proper authorization.
use corporate credit cards only for business purposes.

PROTECTION OF PHYSICAL ASSETS
All assets are of great value to TASWEEQ, thus their protection
is critical for achieving TASWEEQ business objectives. All
employees are personally responsible for protecting any property
entrusted to them directly as well as taking due care to protect
TASWEEQ assets in general. They shall be alert to situations or
incidents that can lead to the loss, misuse or theft of TASWEEQ
property.

PROTECTION OF INFORMATION RESOURCES AND
INFRASTRUCTURE
Computer hardware, LAN/WAN infrastructure, ERP platform,
Business software applications and Telecommunication
systems are key assets. They are intended for business use
and all information processed, transmitted or stored within
these assets belongs to TASWEEQ.

All employees are responsible for following relevant security
policies and protecting these resources from,
unauthorized access.
fraudulent manipulation.
Alteration.
exposure to viruses.
theft, damage or destruction.
unauthorized disclosure or use.

Occasional and reasonable personal use is permitted
and will be monitored to ensure amongst others that, it
does not interfere with employees duties, is not related
to a personal business or illegal activity and that no
significant additional costs are incurred.

PROTECTED TASWEEQ PROPRIETARY
INFORMATION
The laws allow TASWEEQ to protect proprietary
information from the use by outsiders. It is the obligation
of all employees to,
protect TASWEEQ proprietary information from
unauthorized disclosure or distribution.
use proprietary information only in connection with
TASWEEQ business.

Proprietary information is related to:
information used in trading activities including pricing,
marketing and customer strategies.
marketing plans.
Sales, marketing and other corporate databases.
software bought or developed in-house.

THIRD PARTY INFORMATION AND RIGHTS
All employees shall respect the property rights of third
parties and while conducting TASWEEQ business
activities shall
not install unlicensed software on TASWEEQ
computers and networks.
not use copyrighted materials without specific
permission from the copyright owner.
only copy documents and materials which are not
copyrighted or after having obtained specific
permission to do so.
not use any confidential information, including
computer records, from prior employers.
Page of
13. DISCRIMINATION AND HARASSMENT
TASWEEQ is committed to diversity and inclusiveness in
its work environment where mutual trust and respect is
fostered, employees and others are treated fairly and with
dignity, where recruitment is based on the qualifications
and abilities needed for the work to be performed and
in compliance with the requirements for hiring Qatari
Nationals.

GUIDING PRINCIPLES
The guiding principles for all officers and employees when
dealing with each other as well as with, contractors, suppliers,
customers or others are,
respect individual freedoms and human rights.
do not discriminate against any one and treat all persons
fairly regardless of such factors as race, color, national origin,
sex, marital status, age, religion, political belief, physical
handicap or disability, or status.
do not engage in unwelcome sexual advances or sexual
harassment.
do not intimidate or humiliate other people.
do not use inappropriate language or verbal abuse.

Employees who believe they have been subject to harassment
should report the issue immediately through HR to the Ethics
and Compliance Committee. Employees who observe others
being subject to harassment should also report the issue
immediately through the same channels.
Page of
14. PROTECTION OF PRIVACY OF PERSONAL DATA
TASWEEQ will acquire and retain employee personal data
only when it is required for the effective operations of
TASWEEQ or when required by law and to adequately protect
the confidentiality of personal data and information.

ACCESS AND DISCLOSURE
Access to personal data shall be restricted to officers and
employees who have specific authorization and a clear business
need for that information.

Unless subject to compulsory disclosure by authorities as part of a
formal criminal investigation personal data shall not be disclosed
to anyone outside TASWEEQ without specific authorization by
the Executive Director HR, Legal counsel and the written permission
of the individual concerned. In all events the individual shall be
informed of the information being disclosed and purpose for which
it is disclosed.
Officers and employees who have access to personal
employee data shall only use it for the purpose for which
it was obtained and apply the highest standards of
confidentiality when using it.

All employees shall have the right to view the entire
contents of their personnel file maintained by the
company.

SECURITY
Employee data will be kept in a secured and access
restricted environment, whilst all electronically held data
will be subject to strict IT security processes and
procedures.

RETENTION
Personal data shall not be retained longer than required
by law or required for a clear business reason, in the
latter case specific authorization is required.
15. DRUGS AND ALCOHOL
TASWEEQ is committed to comply with the law and related
regulations in respect of possession and use of illegal
drugs and alcohol.

POLICY
It is forbidden to possess or consume illegal drugs or alcohol
or misuse legitimate or controlled drugs while working in
TASWEEQ premises or any other work related location or
installation.

As a condition of continued employment with TASWEEQ,
employees must comply with all applicable substance abuse
policies, guidelines and/or procedures.

These restrictions are established to comply with the law and
other applicable regulations as well as for the well-being and
productivity of TASWEEQ and its employees.
Page of
16. HEALTH, SAFEFTY AND ENVIRONMENT
TASWEEQ, its officers and employees shall, conduct its
business in a manner that protects the safety of
employees, others involved in its operations, customers,
the public, and the environment. This policy seeks to
protect the environment and prevent all accidents and
injuries through active participation of every employee.

TASWEEQ WILL:
Establish management systems, provide training and conduct
operations in a manner that safeguards people, property and
the environment.
Ensure management actively supports and participates in the
implementation, measurement, review and improvement of
systems, policies, procedures, standards and performance at
all levels of the organization.
Develop performance goals and communicate same to all
employees.
Develop and maintain the required skills and competencies
to successfully achieve established goals.
Identify and effectively manage principle risks associated with
the operational activities of the company.
Require reporting of all HSE incidents to management in
writing; Comply with all applicable laws and regulations, and
apply responsible standards where laws and regulations do
not exist.
Stress to all employees, contractors, and others working on
its behalf their responsibility and accountability for safe
performance on the job and encourage safe behavior off
the job.
Favor the selection of its service providers and customers
on the basis of their ability to comply with its HSE policy.
Provide guidelines and requirements for safe and
effective third party services management.
Provide feedback on third party performance to
encourage continuous improvement of service provided
and ensure that deficiencies are corrected.
Undertake appropriate reviews and evaluations of its
operations
Page of
17. CLARIFICATIONS, REPORTING, COMPLAINTS
AND OTHER ISSUES
CLARIFICATIONS
If an employee has any doubt in respect of the application or
interpretation of the Code of Conduct he shall in first instance
consult with their line manager or Legal counsel as appropriate.

REPORTING OF SUSPECTED BREACHES
Employees shall report suspected breaches of this Code of
Conduct, other TASWEEQ Policies, laws and regulations, and
any knowledge of untruthful or inaccurate records, statements or
transactions that do not serve a legitimate commercial business
purpose.

You may file a complaint by email to:
ethicshelpline@tasweeq.com.qa or by mail to Chief Executive
Officer, c/o Secretary of the Ethics and Compliance Committee
(General Counsel), P. O. Box. 24183, Doha, Qatar
Any person reporting a suspect circumstance or case should
have no concern for potential retaliation. Employees are required
to fully cooperate with internal investigations of suspected
breaches of this policy. Anyone involved directly or indirectly in
any retaliatory act or intimidation will be subject to sanctions
which reflect the severity of such act and behavior.

DISCIPLINARY MEASURES
Sanctions for breaches of this Code of Conduct, other TASWEEQ
Policies and of laws and regulations shall be considered and
assessed by the Ethics and Compliance Committee. The
considerations and application of sanctions will be according to
the established TASWEEQ disciplinary procedures, and may
include dismissal. Where required by law related information will
be made available to the relevant Authorities and the individual(s)
involved may have personal liability under law for their actions.

COMPLIANCE
Management and employees shall be diligent in selecting and
monitoring contractors, agents and other third parties.
The Ethics and Compliance Committee shall ensure
compliance with this Code of Conduct, Policies and laws
and regulations.

Resources shall be made available for implementing the
Code of Conduct and establishing and maintaining proper
systems of control and reporting procedures.

ANNUAL COMPLIANCE ASSURANCE DECLARATION

All officers and persons in the employment of TASWEEQ
Shall provide written assurance of compliance with or any
deviation to the Code of Conduct, Policies and laws and
regulations, this in the format, content and date as from
time to time will be established by the Ethics and
Compliance Committee.

The declaration shall be confidential and shall only be
disclosed and discussed with relevant managers on a
need to know basis.
Page of
18. APPENDICES
Appendix I
BOOKS & RECORDS
Definition
Record
Record A Record is information which is created or received as evidence of a business
transaction or activity and is required for legal, tax, regulatory or accounting purposes.
Appendix II
CONFLICT OF INTEREST
Definitions
Conflict of Interest
This exists when a persons personal interests interfere in any manner with the interests of
TASWEEQ.
Companies that enter
into contracts with,
supply or render
services to TASWEEQ
Relate to customers, contractors and any form of service providers to TASWEEQ
Direct interest As a shareholder or partner in the entity or any affiliated company of such entity.
Indirect interest
Directorship, trustee, agent, advisory role or any beneficiary relationship to the entity,
for instance as important supplier or contractor to the entity.
Family members Spouse, children, parents, parentsin-law, brothers and sisters.
Page of
Appendix III
COMPETITION/ANTITRUST LAW DEFINITIONS AND CONCEPTS
Anti-competitive agreements and activities between competitors
Price fixing
Agreement between competitors in respect of the prices they will charge to customers or pay
to suppliers for goods and services.
Market sharing /
allocation
Agreement between competitors to divide sales territories or allocate customers
(e.g. not compete).
Restricting output Agreement between competitors to restrict production or output or close production facilities.
Collective boycotts Agreement between competitors not to deal with another person or company.
Territorial or end use
customer restriction
Supplier and customer agree that customers will not sell on the products in certain territories
or to certain customers or customer groups.
Tie-in sales
The sale of one product to a customer on condition that such customer must purchase a
second product, which it may not want to or can buy elsewhere under better terms.
Re-sale price
maintenance
Agreement between a supplier and a re-seller that fixes the minimum re-sale price of the
product(s).
MONOPOLY
Dominance
The ability to act independently of the normal competitive constraints imposed by customers
and competitors - a position of significant economic power in a market.
Abuse
Conduct which exploits customers, e.g. excessive pricing, discrimination in terms offered
without objective justification OR Conduct which excludes competitors from the market, e.g.
predatatory pricing, discount strategies aimed at market foreclosure.
ANTI-COMPETITIVE AGREEMENTS WITH SUPPLIERS/CUSTOMERS
Page of
Appendix IV
BRIBERY, CORRUPTION AND IMPROPER PAYMENTS
Definitions
Bribery
Is the offering, promising, giving or accepting of any undue pecuniary orother advantage to or
by:
a public official, at national, local or international level, a political party, party official or candidate,
and a director, officer, employee or agent of a private enterprise in order to obtain or retain a
business or other improper advantage.
Extortion or solicitation
Is the demanding of a bribe, whether or not combined with a threat if the demand is refused.
Bribery as used in the policy shall include extortion.
Kickbacks
Consist of payment in cash or in kind, including goods, services, the use of another companys
property, or forgiving any sort of obligation provided to a customer or supplier for the purpose of
improperly obtaining or rewarding favorable treatment in connection with a sale or purchase.
Agents This refers to agents, subcontractors, consultants and other third parties.
Facilitation payments
Small payments which are made to secure or expedite the performance of a routine or
necessary action to which the payer has legal or other entitlement.
Page of
Appendix V
GIFTS AND ENTERTAINMENT
Definition
Gifts and Entertainment
Anything of value, not only material goods, but also services, promotional premiums and
discounts, such as
- loans, - favorable terms on any product or service.
- services, - prizes, - transportation, - use of another companys assets, - use of vacation
facilities. - stocks or other securities, - participation in stock offerings, - home improvements,
- tickets, and - gift certificates.
FURTHER GUIDANCE AND EXAMPLES
In addition to applying the guidelines one shall ask the following questions to further assist
in determining whether a gift
or entertainment is appropriate:
Is the intent only to build a business relationship or offer normal courtesy?
Or is it to influence the recipients objectivity in making a business decision?
ALLOWED NOT ALLOWED
Gifts
Gifts of nominal value, such as pens, calendars or small
promotional items.
Gifts with a value above policy limit.
Meals
Occasional business meal discussions with a customer
or supplier.
A free private meal for an employee and spouse.
Entertainment
Occasional attendance at ordinary sports, theatre
and other cultural events.An invitation to an
entertainment or sporting event such as a golf-
tournament may be appropriate if it demonstrably
helps to build or maintain a business
relationship..
To accept an invitation to attend certain events, where travel
accommodation and other expenses are paid by a customer,
supplier or business relation.
Giving gifts
Plaques, awards and prizes that are part of official
TASWEEQ initiatives and relationship programs.
Free access to or use of TASWEEQ resources, assets,
excess goods or materials.

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