Supplier

Supplier Code of Conduct

ARAMCO TRADING GROUP SUPPLIER CODE OF CONDUCT

I.             SCOPE

This document establishes a Code of Conduct for current and potential suppliers to the Aramco Trading Group, which includes its subsidiaries. Aramco Trading suppliers shall include vendors, manufacturers, service providers, and contractors registered with Aramco Trading and seeking to provide goods, services, or Personnel (including consultants) to the Group, or are parties to agreements with Aramco Trading for such purposes.

II.            INTENT

Aramco Trading is committed to conducting its business in an ethical, legal, safe, environmentally, and socially-responsible manner. Aramco Trading requires its suppliers to share these commitments and, therefore, has established this Supplier Code of Conduct. The company requires its suppliers to consistently meet the following requirements in order to perform or continue to conduct business with Aramco Trading Group.

III.          SUPPLIER CODE OF CONDUCT

Compliance with Laws, Codes, and Regulations

Aramco Trading suppliers must comply with all applicable laws, codes, and regulations as set forth in applicable procurement documents and agreements (including but not limited to proposals, invitations to bid, solicitations, and resulting contractual and purchasing/selling agreements).

Environmental Health and Safety Practices

It is the responsibility of the supplier to assure that its facilities are designed and safely operated in compliance with the established government and industry environmental protection policies and that they do not present unnecessary risks to the environment or public. Aramco Trading suppliers shall maintain safe, sanitary, and healthy work environments for all their employees at all job sites.

Such compliance shall include, among other things:

§  Obtaining and maintaining environmental permits.

§  Proper handling and disposition of hazardous materials.

§  Monitoring, controlling, and responsibly treating discharges generated from operations.

§  Conducting appropriate employee safety training and providing adequate safety equipment.

§  Maintaining records of safety training and monitoring safety performance.

§  Ensuring that suppliers and employees comply with applicable health and safety rules and regulations and perform their duties and work in a manner which will not expose themselves or others to any risks.

§  Providing the required training to promote public health and hygienic practices.

Ethical Business Practices

Aramco Trading and its suppliers shall conduct their businesses in accordance with the highest standards of ethical behavior. Suppliers are expected to conform with the requirements mentioned in each of the following areas:

§  Fair Trade Practices

Suppliers shall not engage in collusive bidding, price discrimination, or other unfair trade practices.

§  Ethical Sourcing

Suppliers shall source goods or services from others that meet, as a minimum, country or origin standards for health and safety, working hours, pay, employment conditions, and environmental protection.

       Aramco Trading’s Business Ethics Policy governs the fact that all transactions require to be conducted fairly, honestly, and with integrity, according to the highest ethical standards. Abuse or violations of this ethics policy are considered as an act of dishonest conduct.

Suppliers and their Personnel shall avoid even the appearance of unethical or compromising practices in relationships, actions or communications with regard to existing or proposed business relationships with Aramco Trading.

Suppliers shall not encourage or utilize current or former Aramco Trading employees to disclose or provide any confidential, proprietary, or other restricted business information obtained while conducting business with Aramco Trading. It is not permitted to influence Aramco Trading’s existing or proposed commercial transactions to the scope of gaining commercial advantage or to otherwise damage Aramco Trading or to expose Aramco Trading and its subsidiaries to any financial, operational, commercial, and to any legal risks, or reputational damages.

Aramco Trading will take the necessary measures to detect any of such improper business conducts and will take appropriate action against current or former employees and suppliers who violate these restrictions.

§  Bribery, Kickbacks and Fraud

No funds, assets, or services shall be paid, rendered, loaned, or promised for payments or otherwise dispersed by suppliers or their representatives as bribes, “kickbacks” or other payments designed to influence or compromise the conduct of Aramco Trading or its representatives.

§  Gifts, Gratuities and Hospitality

Suppliers and their Personnel shall not offer or provide Aramco Trading or its employees with gifts, gratuities, or hospitality, unless involve nominal value and is in line with customary business practices. Nominal gifts are described as gifts of a general nature having a low value, including such items as logo inscribed pens, caps, shirts and coffee mugs. Customary business practice in terms of hospitality would include the acceptance of reasonable business entertainment and business meals. Gifts, gratuities, and hospitality offered or extended by suppliers to Aramco Trading Personnel that exceed nominal value or reasonable hospitality are reportable under the internal Aramco Trading policies and regulations.

For the avoidance of any doubt, Aramco Trading pays for its employees’ business expenses. Suppliers are not required or requested to incur or reimburse business expenses for Aramco Trading employees.

IV.          MONITORING AND COMPLIANCE

Suppliers shall conduct periodic internal reviews and inspections to ensure their compliance with this Supplier Code of Conduct and its applicable requirements. If a supplier identifies areas of non-compliance, the supplier is expected to notify the Aramco Trading Procurement, as applicable, as to its plans to remedy any such non-compliance.

Aramco Trading or its designated representatives may engage in periodic monitoring activities to confirm compliance with this Supplier Code of Conduct, including on-site inspections of facilities, use of questionnaires, review of publicly available information, or other measures necessary to assess supplier performance. The supplier performance assessment may be used as a factor in the selection of bidders or the restriction of supplier access to new Aramco Trading business opportunities.

Suppliers are responsible for ensuring that the standards and requirements of this Code are communicated and understood by their Personnel working on or in support of Aramco Trading projects, jobs, contracts, agreements, and orders. Suppliers will be held responsible for the conduct and actions of their employees and Personnel.

The implementation of this document is a shared responsibility between Aramco Trading and its Suppliers.

Suppliers are to promptly disclose to Aramco Trading, on a confidential basis, all current and potential incidents which may give rise to the appearance of conflicts of interest and instances of unethical or fraudulent behavior by any party, including the supplier’s employees and Aramco Trading’s employees, related to any of Aramco Trading’s procurement and contracts business. Suppliers are to cooperate with Aramco Trading in any inquiries or investigations pertaining to past, current or potential instances of apparent unethical or fraudulent behavior or conflicts of interest related to any Aramco Trading business activity.

Supplier employees and Aramco Trading employees who become aware of violations of this Code are obligated to notify Aramco Trading. Supplier employees and Aramco Trading employees are to report violations and irregularities directly to the Aramco Trading General Auditor by email, as follows: General Auditor hotline - Aramco Trading Company. Based on the assessment of information made available to Aramco Trading, the company reserves the right (in addition to all other legal and contractual rights) to disqualify any potential supplier or terminate any relationship with a current supplier found to be in violation of this Supplier Code of Conduct, without liability.

V.           APPLICATION

This Supplier Code of Conduct is a general statement of Aramco Trading’s expectations and requirements with respect to its suppliers.

This should not be read in lieu of, but in addition to, any supplier obligations set forth in (a) requests for proposals, invitations to bid or other solicitation documents, or (b) agreements by and between Aramco Trading and the suppliers.

In the event of a conflict between this document and any Aramco Trading solicitation documents or applicable agreements, the terms of Aramco Trading’s applicable solicitation documents or agreements shall prevail.

The requirements of this document are not subject to waiver. Neither Aramco Trading, its Suppliers, nor their Personnel or representatives are authorized to propose or approve conduct inconsistent with this Code of Conduct.