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Code of Ethical Conduct

OCI Energy and its subsidiaries are committed to fostering a positive, respectful, and productive work environment where all employees, clients, and partners can thrive. This Code of Ethical Conduct serves as a guideline for maintaining the highest standards of integrity, professionalism, and ethical behavior in all aspects of our business operations.

PROFESSIONAL INTEGRITY

Decision Making: Full understanding of our Code of Ethical Conduct and refer to it when making decisions. If unsure about an ethical dilemma, then consult with your supervisor, Human Resources, or the Legal department for guidance.

Honesty and Transparency: Always act with honesty and integrity in all business dealings. Ensure that all communications, both internal and external, are accurate and truthful.

Accountability: Follow through on promises. Take responsibility for your actions, decisions, and mistakes. Acknowledge and learn from them.

RESPECT & DIGNITY

Respect for Others: Treat all colleagues, clients, and stakeholders with respect, fairness, and dignity. Foster a culture of inclusivity, diversity, and mutual respect.

Harassment-Free Workplace: We do not tolerate any form of harassment, discrimination, or bullying. All employees should feel safe and valued in the workplace.

RESPECT & DIGNITY

Confidential Information: Respect the confidentiality of the company’s proprietary information, as well as that of clients, partners, and colleagues. Do not disclose or misuse any confidential data.

Data Privacy: Follow all applicable privacy laws and policies to protect sensitive personal and business information.

COMPLIANCE WITH LAWS AND REGULATIONS

Legal Compliance: Ensure that all business activities comply with relevant laws, regulations, and industry standards. Stay informed and adhere to applicable legal requirements.

Anti-Corruption and Bribery: Never engage in bribery, kickbacks, or any form of corruption. Report any suspicious activities promptly.

CONFLICT OF INTEREST

Avoid Conflicts of Interest: Avoid any personal or professional conflicts of interest, promptly disclosing any potential conflicts, and taking appropriate actions to address and correct.

FAIR AND HONEST BUSINESS PRACTICES

Fair and Honest Business: Conduct business with honesty and fairness in all interactions with customers, partners, and suppliers. Participate in fair competition and never engage in deceptive or fraudulent activities.

Sustainability: We are committed to promoting environmentally responsible practices and sustainable business operations.

WORKPLACE SAFETY AND WELL-BEING

Health and Safety: Embody our Zero-Incident mindset. Prioritize safety in the workplace and comply with all safety regulations. Report hazards or unsafe practices immediately.

Well-being: Support the mental and physical well-being of yourself and your colleagues. Maintain a healthy work-life balance and encourage a supportive work environment.

USE OF COMPANY RESOURCES

Proper Use of Resources: Use company resources, including time, equipment, and technology, responsibly and for business purposes only.

Intellectual Property: Respect and protect intellectual property, including patents, trademarks, and copyrights. Do not misuse the company’s intellectual property or that of others.

SOCIAL RESPONSIBILITY

Proper Use of Resources: Use company resources, including time, equipment, and technology, responsibly and for business purposes only.

Intellectual Property: Respect and protect intellectual property, including patents, trademarks, and copyrights. Do not misuse the company’s intellectual property or that of others.

REPORTING VIOLATIONS

Open Communication: Report any witnessed or suspected unethical behavior, compliance concerns, violations of this Code of Ethical Conduct, or illegal activities promptly and confidentially using our established reporting mechanisms (e.g. HR, Legal, Ethics Hotline, etc.) without fear of reprisal; OCI Ethics Hotline toll-free at (877) 350-5825.

Confidentiality of Reports: All reports will be treated with confidentiality to the extent possible, ensuring that no employee faces retaliation for speaking up.

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