code of business

Code of business conduct

Kentz Corporation Limited Code of Business Conduct

Dear Colleagues

Kentz continues to see significant growth across its Global Business Units and has recently completed a successful step-up to the Main Board of the London Stock Exchange. Against this backdrop it is vital that we continue to maintain and build on our already well established high standards of business conduct and ethics. The Company has therefore decided to formalise all of the important behaviours expected of Kentz employees into a single Code of Business Conduct (“the Code”).

All Kentz directors, employees, and the people we work with, are required to fully comply with the Code and to use it in ensuring that they maintain the highest standards of ethics in their working lives, wherever they are located and whatever their responsibilities.

The Code cannot cover every situation, but it provides general guidance to which common sense can be applied. When in doubt, always seek appropriate advice and err on the side of caution.

Every person at Kentz has a responsibility to know and follow the Code in all their business dealings; to ensure the reputation and respect that Kentz has amongst its stakeholders is maintained and strengthened.

Kentz relies on its people to ensure compliance with the Code and you must report any potential or actual breaches of it to management in the manner set out in Section 9 of the Code. Our employees are our most important asset and we have set out in the Code our responsibilities to you and the protections available to you in the workplace.

David Beldotti, Chairman of our Audit Committee and an experienced member of the Kentz Board of Directors, has been appointed as Senior Independent Director of the Board to ensure amongst other things that shareholder enquiries in relation to the Code are properly addressed. Tony Lenard, Group Internal Audit Manager for Kentz, has been appointed to act as the Group Compliance Officer and to facilitate the smooth running of the Code. Please contact him directly should you have any queries in regard to the Code.

The Code has been approved, and is fully supported, by the Kentz Board of Directors and will be reviewed on an annual basis and updated as appropriate. You are encouraged to familiarise yourself with the Code as a matter of priority, as you will be required to comply with it always from this time forward.

Christian Brown Chief Executive Officer

Letter from the Chief Executive Officer


Contents


General principles of the Code of Business Conduct

01

The Code of Business Conduct applies to the Kentz Board, senior management and all employees, and aims to ensure that at every level of our organisation, at all times, employees conduct themselves in an ethical way. This includes their dealings internally and externally with third parties to ensure the highest standards of honesty, integrity and fairness and to foster an environment based on such standards, as well as complying with all related legislation in the countries in which they operate.

As a specialist service solutions provider operating on a global basis, Kentz is exposed to the risks of unethical behaviour both internally and externally. Some Kentz operations are in countries where these risks, relative to other countries, are generally greater. However, we know the difference between the right and wrong ways of doing business, and choose to do what is right, treating all our contacts with honesty, transparency and without bias.

Kentz is committed to ensuring the highest legal standards and ethical guidance in all its business activities. This applies to the behaviour of all Kentz directors, staff, sub contractors, agents, consultants, contract labour, vendor and others

representing or acting for, or on behalf of, Kentz, its subsidiaries or joint ventures.

No Kentz employee may take part in or condone any fraud, dishonest practice, bribery or other corruption or any other breach of the items covered by the Code.

The Code emphasises that every Kentz employee must be aligned to the achievement of Group goals.

Kentz is committed to ensuring everyone that is covered by the Code exercises good judgment and common sense in the execution of Kentz’s business and is individually responsible for ensuring that Kentz’s day-to-day business activities are conducted in a fair, honest, legal and ethical manner.

Decisions and transactions by Kentz employees must in all respects be fair and equitable. Actions should be avoided that create any perception that Kentz employees could exert improper influence on behalf of vendors or clients.

Kentz employees and their immediate family members must avoid any interest, relationship or outside activity that could affect, or be seen to affect, their ability to discharge objectively their responsibilities. Full disclosure by an employee should be given, and written approval sought, before entering into any situations where a potential conflict of interest could occur. Where such an interest, relationship or outside activity already exists, full disclosure should also be given by the person concerned.

Kentz employees must not misrepresent themselves including their level of authority or any information concerning Kentz to anyone outside of the Group. They must not misuse or disclose confidential information for personal gain or to prejudice fair competition.

It is Kentz’s policy to carry out all of its activities in an ethical manner.


To avoid any perception of an improper attempt to influence business decisions, and to avoid feeling obligated to donors, gifts must never be solicited by a Kentz employee or their immediate family member. Any payments of cash or cash equivalent is not acceptable, neither are any gifts that exceed nominal value or are prohibited by law.

Kentz is also committed to ensuring it always acts safely and ethically, without compromising its commitment to protecting people and the environment in all its business activities. It will not accept any discrimination or harassment of its people.

Kentz directors and managers have additional responsibility for creating the proper environment and encouraging safe and ethical business practices. They must lead by example and

give those that report to them the support and resources they need to understand and follow the Code’s requirements.

The Group aims to continuously improve its practices to achieve the goals set out in the Code and seeks assistance from all of its employees, vendors, agents, contractors and consultants to achieve this. Its determination to act according to the Code is critical to preserve Kentz’s highly valued reputation.

The Code requires all members of the Kentz team to always act on the side of caution in maintaining Kentz’s level of safety, integrity, social responsibility and ethics and to use their best judgment and discuss the situation with their line manager or a member of the senior management team before making a decision if they are not sure of the right thing to do.

Kentz expects all its vendors, agents, contractors and consultants to conduct all business with the Group in accordance with all parts of the Code, including those related to health and safety and bribery and corruption.

Failure to comply with the Code will constitute grounds for disciplinary action for employees including, where appropriate, termination of employment. In relation to third parties; failure to comply may result in termination of their business relationship with Kentz.

The Code is communicated to all new employees on joining the Group and to existing employees through workshops, posters and briefings by line management.

At least annually, management report on the implementation and operation of the Code to the Board to ensure that it is adequately communicated to all stakeholders and reviewed and updated as necessary.

‘Kentz is committed to ensuring the highest legal standards and ethical guidance in all its business activities.’


Ethical business dealings

Bribery and Corruption No Kentz employee may take part in or condone any bribery or other corruption. The use of improper payments to gain advantage is never acceptable.

All Kentz employees and the other parties noted above must act with integrity at all times, comply with the bribery and corruption laws of the country in which they are operating and not induce or facilitate someone else to break such laws. They must not make or receive improper payments either directly or indirectly through third parties.

In many jurisdictions, bribery and/or corruption is a criminal offence, as are attempts, incitement or conspiracy to commit such an offence and may result on conviction in severe penalties including imprisonment. In addition, Kentz or its officers and directors may also be liable to severe penalties for bribery or corruption by its employees, agents or other representatives. Kentz therefore has a responsibility to exercise due care in monitoring those acting on its behalf to prevent bribery and corruption.

A bribe is any gift, loan, payment or other benefit offered, given or received with the intention of gaining a business advantage or inducing improper conduct by the person receiving it. Specifically, this includes clients or government officials who have the potential to make decisions favourable to Kentz or one of its Group companies. It may include excessive or inappropriate hospitality. The giving or receiving of such gifts,

loans, payments or benefits, both in relation to government officials and private individuals, is specifically prohibited, unless they are only of a small token nature.

The Code cannot outline rules for every situation but requires all employees to err on the side of caution. If an employee is in any doubt about a given situation, they should consult their line manager who may in turn refer it to the Group Compliance Officer. The Group wants to prevent even the appearance of bribery or corruption in relation to Kentz, as acts or allegations of bribery can damage the Group’s reputation.

In this regard, the Group makes no distinction between bribes and facilitation or enabling payments.

The only exception to this would be in the unusual circumstances where there is a real physical threat to an employee or their family. If such a payment has to be made, it should be reported to the Group Compliance Officer at the earliest possible opportunity.

Where a third party agent is to be used to represent Kentz’s business interests, it must first be confirmed that their use is necessary and that the related role cannot be completed internally. Improper conduct by agents and representatives could also damage Kentz’s reputation.

Particular care should be exercised in dealing with agents in countries known for high levels of corruption, where the agent is introduced by a

All Kentz group companies and joint ventures, regardless of location, and all Kentz employees, contractors, agents, consultants, vendors and others representing or acting for, or on behalf of, Kentz are required to comply with the following policies in their business dealings.

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IMS – COR – 1 – 0070, Anti-fraud policy


customer or government official or is suspected of having connections with a customer or government official, where the agent’s commission exceeds the expected market rate for the service provided or where the agent requests unusual payment arrangements, such as payment in cash or in a third country. This could also include payments to charities or other third party bodies.

It is Group policy that all new or renewed agency, contractor, consultancy and vendor agreements include provisions to ensure the agent, contractor, consultant or vendor has read and agreed to comply with the section of Code in relation to ethical business dealings, subject to the penalty of immediate removal from the approved vendor list and termination of their related agreement.

If any customer or prospective customer, their agent or representative seeks any form of bribe, the Code requires this information to be immediately reported to the line manager of the employee concerned and the line manager to report it to the Group Compliance Officer.

Anti-Competitive BehaviourCompetition laws prohibit anti-competitive behaviour and the related penalties can be severe. Kentz requires all of its employees to ensure that their interaction with our competitors is completed with integrity and that they are never in, or deemed to be in, a situation where Kentz can fix prices or enter into other anti-competitive practices with its competitors. It is important for employees to be aware of the related laws and to ensure that suppliers and customers are not engaging in anti-competitive activities that could damage our business.

Vendors, agents, contractors, consultants and industry partners are crucial to Kentz’s success. It is vital that the Group deals with them fairly and treats them with integrity and respect. Kentz chooses all such partners only on the basis of appropriate business criteria including performance, price, qualifications, product quality and deliverability.

Kentz complies with competition and anti-trust laws in the countries in which it operates and will not be involved in any price fixing, bid rigging or other form of anti-competitive behaviour, or misrepresent to third-parties its competitors’ abilities, products or services.

Conflicts of InterestEmployees should avoid situations where they have or appear to have a conflict of interest. Conflicts of interest arise where employees, consultants or agents have personal, family or other interests which affect or appear to affect their ability to be fair and impartial in carrying out their duties. Actual or apparent conflicts of interest can undermine stakeholders’ trust in the Company, even where mitigating factors are present.

Employment, consultancy or directorship agreements outside the Group that may interfere with an employee’s duties at Kentz, especially those with an actual or potential business partner or competitor of the Group, require disclosure and written authorisation by the employee’s line manager.

Employees should preferably not be actively involved in any transaction between the Group and any other business entity in which they or their immediate family have a material shareholding or management role. Where this is not possible to avoid, prior written approval is required by the employee’s line manager or more senior manager if deemed appropriate. An employee is also required to make a full disclosure of any transaction between the Group and any other business entity in which they or their immediate family have a material shareholding or management role, even if they were not involved in the transaction. The hiring or recommendation to hire a relative would also require disclosure. Similar requirements exist when dealing with personal friends.

Consistent with the rationale behind giving and acceptance of gifts, any lavish hospitality may create a conflict of interest or appear to compromise the integrity of an employee or vendor’s decision to award work. While such courtesies may promote successful working


relationships and goodwill, the frequency and scale of hospitality must not reach a level whereby either party might reasonably be seen as being influenced by it in a business transaction.

In the case of any doubt regarding potential conflicts of interest, the employee concerned should discuss the issue with their line manager or the Group Compliance Officer.

Inside Information and Insider Dealing Kentz employees are prohibited from trading in shares in the Group or any other quoted company based on the use of price sensitive and unpublished inside information which, if publicly known, could affect the market price of Kentz or another company’s shares.

In addition, they must not disclose such information to any third party that may use it to deal in such shares.

As Kentz shares are publically traded, there are close periods each year when employees are not allowed to trade in the Group’s shares.

In case of any doubt relating to close periods, or trading in Kentz shares, employees should refer their questions to the Group Head of Communications.

Money LaunderingMoney laundering refers to situations where companies or individuals try to conceal illicit funds, including the proceeds of crime and tax evasion, in a business to try and give the funds the appearance of being legitimate.

Kentz prohibits the use of any of its businesses for such purposes and places a duty on all of its employees to report any suspected or identified cases of money-laundering located or suspicious transactions to their line manager and the Group Compliance Officer.

FraudKentz is absolutely committed to maintaining an honest, open and well intentioned atmosphere within the Group. Thereby it is also committed to the elimination of any fraud within the organisation and to the rigorous investigation of any such cases raised.

Actions constituting fraud include, but are not limited to, misappropriation of funds, supplies or any other assets, impropriety in the handling or reporting of money or financial transactions, deliberate misrepresentation or misreporting of any financial information, performance or results, incorrect characterisation of expenditure and forgery or alteration of business documents.

The Chief Financial Officer will be primarily responsible for the investigation of all suspected fraudulent acts as defined in this policy. The Chief Financial Officer may delegate the detailed investigation to an individual or team of investigators. These investigators could be either internal or external.

If the investigation substantiates that fraudulent activities have occurred the findings will be reported to the appropriate designated personnel and if appropriate to the Main Board through the Audit Committee.

Decisions to prosecute or refer the examination results to the appropriate law enforcement agency for independent investigation will be made in conjunction with legal counsel and senior management.

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but found innocent of any wrongful conduct and to protect the Group from any civil liability.


Health and safety

Management place the health and safety of every employee above any other consideration of job operation or administration, with the goal at every level of the Group to ensure at all times, and in every phase of a job operation, the health and safety of Kentz employees and third parties at the locations in which Kentz operates.

Kentz recognises that responsibility for health and safety requires constant and continuing efforts from a partnership of management, employees, subcontractors and clients.

Kentz accepts its responsibility to lead the promotion and practice of its health and safety programme.

Kentz will comply with all legal and regulatory health and safety requirements and generally accepted work practices in every country in which it operates. In addition, it enforces its own procedures for protection and promotion of the health and safety of its employees and others affected by the Group’s activities. It will also strictly adhere to all site health and safety standards and job work rules and practices at the locations where it undertakes work.

Employees at all levels of the organisation work conscientiously and diligently to obtain the highest standards of occupational health and prevent the suffering and losses which result from unsafe practices.

Kentz promotes and enforces the development, dissemination, implementation, effectiveness and continual improvement of its health and safety programme, which is available to other interested parties.

Kentz pursues rigorous and frequent audits to ensure that each partner in its health and safety programme provides exemplary leadership in the prevention of accidents, injuries and illness to ensure that nobody gets hurt and everyone goes home safe and well.

It is Kentz’s policy to provide and maintain a safe and healthy work environment at all times, with the goal of preventing occupational accidents, injuries and illnesses.

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‘Management place the health and safety of every employee above any other consideration of job operation or administration, with the goal to ensure the health and safety of Kentz employees’

IMS – COR – 1 – 0002 – 3, Health and safety policyIMS – COR – HSE – 3 – 0001, Health and safety and environmental manual


Alcohol and DrugsEmployees should be fit to carry out their duties while on Kentz business. Employees are specifically prohibited from risking the health or safety of themselves or other employees by working while under the influence of alcohol or drugs or having such items in their system. Except in the rare cases where approved by senior management, alcohol consumption by employees is not allowed on Kentz premises or any other sites on which Group staff are working. Breach of these rules can result in severe penalties, including dismissal.

QualityKentz recognises the requirements for quality assurance in the areas in which it operates and has committed to the establishment of an effective quality management system. It aims to ensure all contractual and specification requirements are met for the projects for which Kentz is responsible and to achieve a reliable and cost effective system of management in all its activities.

The quality management system addresses all quality systems requirements identified on the International Organisation for Standardisation ISO 9001. Kentz has defined its quality objectives in its quality manual and these are reviewed periodically to continually improve the effectiveness of the system.

The Group Quality Assurance Manager is responsible for the introduction and implementation of the quality management system throughout the Group.

Kentz management requires the quality assurance department to conduct introductory courses for all employees to ensure the quality management system is effectively communicated and understood within the Group.

IMS – COR – 1 – 0002 -1, Quality policy statementIMS – COR – 1 – 0002 – 5, Drug and alcohol policy statement


Corporate social responsibility

It conducts its business in accordance with applicable local laws and regulations. Every Kentz employee, supplier, agent, contractor and consultant engaged in any of the Group’s operations must comply with the laws and regulations of the country where they are involved. Legal compliance is a minimum and not Kentz’s entire ethical and social responsibility. The Group will operate and expects its employees, suppliers, agents, contractors and consultants to operate in line with industry

standards and to exceed them as economic and operational constraints permit.

Environmental Kentz recognises the responsibilities placed on it by relevant environmental legislation and regulations on the nature, scale and environmental impacts of its activities, products and services.

Kentz is committed to the efficient use of resources; minimising environmental impacts throughout its operations; developing and implementing sustainable solutions that contribute to meeting worldwide energy needs; contributing constructively to global sustainable development; preventing pollution; and identifying, assessing and managing risks to the environment.

Kentz takes statutory obligations and regulations as minimum requirements only. It will provide sufficient resources of time, personnel, finance, training, information and supervision in pursuance of these objectives and do

everything reasonably practicable to ensure its subcontractors do the same.

It is the duty of all personnel, including suppliers and subcontractors, to take all reasonable precautions to improve Kentz’s environmental performance by preventing pollution, reducing waste, minimising hazardous waste and recycling as much as possible.

Kentz strives to maintain leading industry practices and develop, implement and maintain environmental management systems that meet the requirements of the ISO 14001.

Community Kentz recognises the importance of giving back to the communities in which it operates and to building strong and sustainable relationships with them.

It is Kentz’s policy to bring tangible benefits to these communities, after listening to community needs and expectations and allowing for each community’s uniqueness.

Kentz aims to set measurable targets in this area and to continually improve its relationship with the communities it deals with by becoming an active member of the community through involvement in charitable, social, recreational, well being and cultural initiatives.

Outside working hours, Kentz employees are encouraged to participate in charitable, educational, community and civic activities and projects that enhance the quality of community life, as long as these activities do not interfere with their ability to do their job or present any other kind of conflict.

Kentz is committed to being a good corporate citizen in all countries in which it operates, applying the principles of sustainable development, working to minimise its environmental footprint and contributing to the economic and social development in the communities where it is active.

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IMS – COR – 1 – 0002 – 2, Environmental policy statementIMS – COR – 1 – 002 – 6, Community policy statement


Human resources

It is Kentz’s policy to provide its employees with modern and adequate working facilities, professional training opportunities, access to address their social service needs and the means to resolve any human resources problems that may arise.

Kentz aims to motivate all employees to achieve quality internally and externally, reward achievements and good performance, promote a culture of trust and a spirit of teamwork and harmony and to exercise integrity in dealing with its employees.

Diversity and Human RightsKentz operates in many countries with a wide variety of cultures and has a work force drawn from across the globe. It prides itself on its ability to respect different cultures and beliefs and to benefit from the value this diversity provides the Group.

The Group requires all its employees to interact with their co-workers with civility and courtesy, accepting differences without necessarily agreeing with them.

Kentz welcomes the input of all of its employees and promotes active communication between employees and their line managers, with advice given freely and issues raised and resolved in a spirit of openness.

All employees and job-applicants deserve and are given fair and non-discriminatory treatment for both employment and in developing their careers with Kentz, irrespective of ethnic or national origin,

gender, religion, age, sexual orientation, disability or any other factor other than their ability, aptitude, qualifications, skills and performance. Kentz offers equal opportunities for all.

Kentz will not permit harassment of its employees in any form, including that of a sexual nature, and requires that its employees do not behave either openly or covertly in a way that another person may find unwelcome, offensive, upsetting, humiliating, embarrassing or demeaning. If any employee considers that they have been the victim of any form of harassment, they should report it to their line manager for follow up as appropriate. All such issues raised are required to be handled in a sensitive and sympathetic manner.

Kentz will not use forced, compulsory or underage labour. Kentz recognises the right of all its employees to join trade unions where such rights are recognised by law.

Industrial RelationsKentz recognises that, from time to time, issues arise within the Group that occasionally result in industrial disputes. Through effective communication and consultation with employee representatives or, as appropriate, trade unions, Kentz aims to bring about the satisfactory and speedy resolution of such issues. Effective consultation will ensure that the views, opinions, suggestions and recommendations of all parties are considered openly and constructively.

Kentz is only able to provide the consistently high quality services required by its customers because of the strength and quality of its employees and its dedicated and motivated management team. The Group invests time and effort in the development of its people by supporting them through constant appraisal, coaching and training, and by encouraging personal initiative.

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IMS – COR – 1 – 0002 – 4, Human resources policy statement


Information

Confidential information includes, but is not limited to, technical information on products, patents and copyrights, data services and processes, designs and drawings, software codes and programmes, supplier and customer lists, employee information, business plans, legal documentation and unpublished financial information, both forecast and actual.

The release of such information to third parties could damage the Group’s business and reputation and in some cases violate the law. Kentz employees are not permitted to disclose confidential information to customers, vendors and other third parties unless it is in their normal course of duties and where appropriately protected by a written confidentiality or non-disclosure agreement. They are also not permitted to disclose any confidential information they receive from third parties. Kentz respects the intellectual property rights of third parties and will not knowingly infringe such rights.

All confidential Kentz information is required to be clearly marked as such. Employees with access to employees’ personal data must only use it for the purpose for which it was obtained and keep its contents confidential.

Provision of Kentz Information to Third PartiesWhile Kentz seeks to maintain a positive and open relationship with the media, its investors and analysts, only those employees specifically authorised to do so can reply to enquiries from these sources.

Employees are not permitted to enter into any informal “off the record” discussions with any third party.

If any employee receives a request for corporate information or comment from any third party they should refer it to the Group Head of Communications.

Kentz personnel are required to protect confidential information, both relating to the Group and to other companies for which confidentiality undertakings have been given.

06


Assets and accounting

Employees are not entitled to use Kentz assets and resources for personal or third party gain. Employees are also not entitled to take any assets, documentation or reports belonging to the Group, including ones they have worked on, with them when they leave the Group.

07

Employees are required to use the Group’s IT systems responsibly and primarily for the business purpose for which they are intended. They may not use the systems for any external business, illegal or unethical purpose. The systems are monitored to ensure all use is appropriate and legal.

Unauthorised removal or destruction of any Group assets is strictly prohibited. Their use for any material non-directly business related activity requires approval by line management.

AccountingAll Kentz Group company accounts and supporting records must clearly identify and properly describe the real nature of all transactions, assets and liabilities.

All subsidiary company accounts are to be prepared in line with related legislation and generally accepted accounting principles in the country in which the company is located. The Group’s consolidated accounts are prepared in accordance with International Financial Reporting Standards.

Accounting records are required to be retained for at least as long as is required by local legislation.

IMS – COR – 1 – 0031, Computer usage policy procedure


Government relations

Kentz interacts with government and regulatory agencies in an honest and cooperative manner and expects its employees, suppliers, agents, contractors and consultants to do the same. Kentz seeks to establish long term relationships and effective communications with the governments of the countries in which it operates.

08

It is Kentz’s policy to comply with the legislation in each of the countries in which it operates, including that relating to hiring or offering money or benefits to current or former government employees.

No employee should be anything other than honest when replying to a legitimate request for information from any government official.

Kentz will not do business with any company or country that is contrary to United Nations, European Union or United States export restrictions or sanctions or that is blacklisted by the United Kingdom or United States governments.

Employees and third parties covered by the Code are responsible for finding out and complying with the laws applicable to the countries in which they work.

Political ContributionsKentz does not permit any Group funds to be used for political donations or for its assets to be used for any political purposes.

Kentz employees are of course permitted to make such donations using their own money or time, but not to be reimbursed by Kentz for doing this or to do so in a manner that conflicts with their work. They should inform their line manager if they intend to stand for or accept any political party or public office.

‘No employee should be anything other than honest when replying to a legitimate request for information from any government official’


Speaking up

Kentz has its own internal procedures for monitoring compliance with the Code, but also relies on its employees and external bodies “speaking up” where they become aware of actual or potential breaches of the Code.

09

Speaking-up relates to the disclosure of information by an employee or external body if they have a genuine concern about malpractice in Kentz. Instances may include the contravention of internal policies, legal and ethical standards, activities that put at risk the health and safety of Kentz employees or others, breaches of any environmental or regulatory requirements, bribery and corruption, false accounting, fraud and failure to comply with a legal obligation, or a deliberate concealment of information relating to any of the above.

Kentz is committed to ensuring any employee or external body’s concerns of malpractice is taken seriously and investigated. Every effort will be made to protect the identity of anyone speaking out on such matters. However, in exceptional circumstances a person’s identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defence. Where this becomes necessary, any harassment or victimisation of the complainant will not be tolerated.

Depending on the nature of the matter being highlighted, employees should first raise their concerns with their line supervisor or tell an appropriate safety officer or manager. If for any reason they find this difficult they should report the matter to the Chief Financial Officer or the Group Compliance Officer, who are the nominated executives with responsibility for dealing with concerns raised by employees speaking up, and are responsible for ensuring that an appropriate investigation is conducted.

Anonymous allegations are not automatically disregarded but, given the safeguards which are in place for those making allegations under this policy, anonymous allegations are usually less powerful than those from named individuals.

Any malicious allegations proved to be false or materially incorrect may result in disciplinary action being taken against the complainant. Speaking up is not a way of pursuing a grievance about a personal situation.

For exceptional cases, and if disclosure is about a senior executive or director, concerns should be reported directly to the Senior Independent Director who will decide how the investigation should proceed.

Members of the public and outside organisations are encouraged to raise genuine concerns about Kentz relating to the areas outlined within the scope of this document. They should report any matters or concerns to the Chief Financial Officer or Group Compliance Officer, who are the nominated executives responsible for dealing with such concerns and where appropriate for ensuring an investigation is conducted.

The Group will decide how to respond in a responsible and appropriate manner to any matters raised by the speaking up process. An investigation will be conducted as speedily and sensitively as possible. An official written record will be kept at each stage of the procedure.

Failure to report the knowledge of any actual or potential breaches of the Code or to cooperate in any related investigation may result in disciplinary action being taken against the employee concerned.

IMS – COR – 1 – 0070, Anti-fraud policy


Chief Financial OfficerEdward [email protected]+971 506166849 Group Internal Audit ManagerGroup Compliance OfficerTony [email protected]+973 36553504 Senior Independent DirectorChairman of Audit CommitteeDavid [email protected]

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