Sarachin Procurement Policy on Business Ethics

Sarachin is committed to the highest standards of business ethics and corporate compliance. It is Sarachin’s policy to deal only with organizations whose ethical standards are similar to our own, as stated below. The purpose of this document is to give you a sense of our standards of conduct. We also encourage you to review carefully the complete text of Sarachin’s Code of Conduct.

Our Code of Conduct summarizes the standards of conduct that guide our actions; it applies globally to all Sarachin employees as well as to members of the board of directors, agents, consultants, contract labor, and others when they are representing or acting for, or on behalf of, Sarachin. We seek customers and partners who share our values and standards of conduct, and we expect our partners, subcontractors, and suppliers worldwide to be guided by these principles as well.

A basic component of Sarachin’s policy on business conduct is, of course, compliance with law. The Sarachin group of companies and its employees are subject to and must comply with all applicable laws of the Iran and the countries in which they do business. The same applies to our suppliers and subcontractors. Although some Sarachin policies are based on legal requirements, others embody our company’s broader commitment to ethical business conduct.

Sarachin's ethical standard is one of the company's most valuable assets and is a direct result of the conduct of its employees. The company will conduct all business transactions in a proper, fair, impartial, and ethical manner, avoiding even the appearance of impropriety. Sarachin will do business with clients and others who share our values and standards of conduct outlined in our Code of Conduct.

Standards of Conduct

All Sarachin employees will observe and maintain high standards of ethical conduct in their relationships with clients, suppliers, subcontractors, communities, fellow employees, and others, wherever they work. Any action taken by Sarachin or its employees, representatives, or agents must be fully justifiable and not raise questions as to the company’s honesty, impartiality, or reputation, or otherwise cause embarrassment to the company. Sarachin employees must avoid any interest, relationship or outside activity that could affect the employee’s objectivity in making decisions concerning his or her Sarachin duties and responsibilities. These global standards of conduct also apply to members of the board of directors, agents, consultants, contract personnel, licensors, and others, when they are representing or acting for, or on behalf of, Sarachin.

All Sarachin entities and affiliates, and their employees worldwide, will act in full compliance with all applicable laws and regulations of the Iran, as well as those applicable in other countries where a Sarachin entity conducts business, except where compliance with local country law would violate Iran law. Conduct that is prohibited under Sarachin policy or does not comply with laws and regulations may not be accomplished on Sarachin’s behalf by anyone outside the company.

Ethics and Compliance Program

Sarachin will maintain an ethics and compliance program to communicate its commitment to uncompromising integrity in accordance with the corporate values, and to ensure compliance with all applicable laws, rules, and regulations. This program will inform employees world-wide of Sarachin policies and management instructions concerning ethical business conduct and help them to resolve questions and report suspected violations. The reporting process will provide a confidential means of communication separate from line management. Retaliation against employees who come forward to raise concerns will not be tolerated.

The Sarachin ethics and compliance program will include an education and awareness program to provide employees with job-specific compliance training and to raise their level of awareness and sensitivity to key issues. Sarachin will publish its Code of Conduct booklet in a variety of languages to enhance accessibility for its global population. All employees are required to participate in ethics awareness workshops annually and to complete compliance training as assigned.

This policy, the Sarachin Code of Conduct booklet, and related policies and management instructions, constitute the Sarachin standards of conduct. Failure to comply with these standards may result in discipline, including termination.

Responsibilities: Chief ethics and compliance officer
Manages and maintains the Sarachin ethics and compliance program Ensures that appropriate policies, management instructions, and procedures are in place to help employees comply with Sarachin's expectations for ethical business conduct Ensures the existence of an ethics and compliance education and awareness program in appropriate subject areas in order to provide employees with job-specific compliance training and raise their level of awareness and sensitivity to key issues Provides final and dispositive interpretation of the Sarachin standards of conduct to resolve employee questions and confidential inquiries Represents Sarachin's ethics and compliance program outside the company through outreach to external stakeholders Delegates to a network of business-based ethics and compliance officers as appropriate
All Sarachin employees
Comply with the Sarachin standards of conduct and, in so doing, reject any plan, transaction or arrangement involving unlawful or unethical conduct or the appearance of impropriety Participate in ethics awareness workshops annually and complete compliance training as assigned Raise questions if the employee is concerned that the standards of conduct are not being met Avoid any arrangement, agreement, investment, employment, relationship, or activity which is or appears to be contrary to the best interests of Sarachin or its clients or might in any way impair the objective performance of duties or the exercise of independent judgment or action with respect to Sarachin or its clients' interests Seek guidance from the employee’s supervisor or other management, business organization ethics and compliance officer, Human Resources, the Legal Department, or the Ethics HelpLine if the employee has questions or concerns about compliance with the Sarachin standards of conduct Inform the employee’s supervisor or other management, organization ethics and compliance officer, or the Ethics HelpLine if the employee is aware of any incidents or situations concerning potential unethical conduct or conflicts of interest
Sarachin supervisors and managers
Ensure that employees understand and comply with this policy Support implementation of the ethics and compliance program and monitor compliance with the company’s standards of conduct Ensure that employees participate in ethics awareness workshops annually and complete compliance training as assigned Create an open and honest environment in which employees feel comfortable in bringing issues forward Advise others within the organization if employees raise standards of conduct concerns to assure that any ethics and compliance issues and incidents are brought to the attention of responsible management
Sarachin business organizations
Ensure that each new employee (excluding field manual employees) acknowledges having read this policy and Sarachin’s Code of Conduct booklet Notify the appropriate Sarachin counsel and the Chief Ethics and Compliance Officer whenever there is reason to believe this policy may have been violated. Consult the Legal Department whenever there is any question as to the legal implication or consequence of a given course of action Provide a prompt report whenever Sarachin knows or is informed by a reliable source that a client, supplier, subcontractor or other participant (including a Sarachin employee) in a Sarachin project is acting illegally or unethically Implement and reinforce the importance of the ethics and compliance program

Implementation

If there is uncertainty about these standards or guidelines, or if a situation involves unusual or special circumstances, these matters should be submitted to responsible management within the organization for interpretation in consultation with the Chief Ethics and Compliance Officer.

The Chief Ethics and Compliance Officer is responsible for providing policy guidance and issuing management instructions to assist employees in complying with Sarachin’s expectations for ethical business conduct.

Internal Audit, Legal, and other Sarachin organizations may also issue Management Instructions necessary to implement this policy. The Sarachin organizations may, at their discretion, implement this policy further through internal instructions.