At Sadara, we are passionate about our mission and our role as a trend-setter – a leader.

We believe in the potential of our

Company to bring change to the Kingdom of Saudi Arabia in many different and positive ways – from the products we
produce to the jobs and opportunities we will create - we are dedicated to improve the economy of a nation and the standard
of living for its people. However, our mission will not be accomplished unless we are equally focused on “how” we
accomplish it, as well as on the “results” of our collective labor. Values of Integrity, Respect for People and the Protection of
Our Planet are goals of our corporate culture and are reflected through the Sadara Code of Conduct. It is this code of
conduct that guides our behavior both within and outside of our work environment. It is our responsibility to reflect the best
examples of a corporate citizen to not only our business associates, but also to our families and friends; and in that way,
Sadara will help lead the way to positive change.

Best Regards,

________________________________
Ziad Al-Laban, Chief Executive Officer

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 INDEX
INDEX 2

LIVING OUR VALUES 4

Everyone’s Responsibility 4
Responsibilities of Supervisors and Leaders 4
Speak Up and Whistleblowing 4
No Retaliation 4
The Code, the Law and Company Policy 4
PEOPLE 5
Equal Employment Opportunity and Respect in the Workplace 5
Labor Policy 5
Harassment 5
Responsibility 6
Health and Safety in the Workplace 6
Substance Abuse in the Workplace 7
Violence in the Workplace 7
BUSINESS 7
Conflicts of Interest 7
Outside Interests 8
Outside Employment 8
Speaking at Conferences 8
Relatives, Friends and Personal Relationships 8
Gifts and Entertainment 9
Bribery and Corruption 9
Government Officials 10
Business and Financial Records 10
Use and Protection of Company Resources and Information/Confidentiality 11
Intellectual Property 11
Information Technology 11
Third Party Confidential Information 11
Proprietary Information and Records Management 12
Sadara as a Service Provider or Supplier 12
Data Privacy 12
Inside Information and Trading 12
Contract Clause 13
Voiding and Rescinding Contracts 13
Competition 14
Antitrust and Competition 14
Gathering Competitive Information 14

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 Trade Controls 14

CITIZENSHIP 15
Setting the Standard for Sustainability 15
Corporate Citizenship 15
Charitable Activities and Volunteerism 15
Communications with the Public 16
Social Media 16
ADMINISTRATION OF THE CODE 16
Office of Ethics & Compliance 16
Investigation and Response 16
Acknowledgement 17
Waiver 17
Contacts 18

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LIVING OUR VALUES Code, our policies or the law. Even if the facts of the
situation are not entirely clear, each of us still has an
obligation to report an incident of legitimate concern. All
This Sadara Code of Conduct (“Code”) provides a reports of misconduct are taken seriously and will be
framework to make good choices: to abide by the law and treated confidentially, consistent with a full and fair
be highly principled and socially responsible in all our inquiry.
business practices.
Questions or concerns may be discussed with:
It applies to all employees, agents and representatives of o A Supervisor
Sadara Chemical Company and its subsidiaries o A Human Resources Representative
(“Sadara” or “the Company”), and serves as a guide as
o An Ethics & Compliance Committee member
to how Sadara will engage with all individuals and o A Law Department Attorney
organizations who supply goods or services to Sadara. o The Office of Ethics and Compliance – either
(“Suppliers”).
directly or through the website
(http://sadara.com/en/about/Ethics_and_Compli
EVERYONE’S RESPONSIBILITY ance)

During the course of business, each one of us will be

faced with situations where the right answer may not be
obvious. The Code can guide us, but it cannot address NO RETALIATION
every circumstance. Our first responsibility in all
instances is to avoid even the appearance of improper
behavior. We must abide by all applicable laws, respect We respect those who raise legitimate concerns about
the values of our society and, when in doubt, seek suspected improper conduct. We understand that it can
counsel for guidance and assistance as more fully be a difficult and emotional decision to come forth and
explained in this Code. speak up. Sadara therefore has a ‘No Retaliation’ policy
to any reasonable concern raised honestly. We will not
tolerate retaliation against anyone who reports a potential
RESPONSIBILITIES OF SUPERVISORS AND violation in good faith. However, employees have a
LEADERS responsibility to only raise a legitimate complaint (i.e. not
a false claim), and concerns should always be based
Actions speak louder than words, and we hold our upon good judgment and reasonable standards. Contact
leaders to the highest standard. Supervisors are an Ethics and Compliance Committee member or Office
expected to model appropriate behavior, ensure that of Ethics and Compliance if you believe an act or pattern
employees have the resources they need to conduct of retaliation is committed against you or, in your
business ethically, encourage discussion and be presence, against another person.
responsive to all appropriate concerns. We expect our
supervisors and management to live up to and maintain THE CODE, THE LAW AND COMPANY
the trust that has been bestowed upon them by the
Company and its shareholders by demonstrating the POLICY
highest standards of ethical behavior.
Sadara’s corporate policies address many areas covered
within this Code, however, it is important to recognize that
the Code is only a guideline for our employees, whereas
the Company policies and the applicable local laws are
the basis for the matters discussed herein. As a global
SPEAK UP AND WHISTLEBLOWING company, we must follow the laws of many countries and
jurisdictions. If a section of the Code conflicts with
One measure of commitment to our values is how we
applicable local law, then the local law takes precedence.
treat each other. As employees, we have an obligation to
If a section of the Code conflicts with the express
behave in a manner that protects the Company’s
provisions of a Company policy, then the policy terms will
business interests, our reputations and each other. This
take precedence.
obligation includes taking action to promptly report any
conduct inconsistent with the guidelines set out in this

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Please consult the Law Department or the Office of Sadara endeavors to take every step possible to
Ethics and Compliance if you have any questions about guarantee all applicable employment rights given under
local laws, the Code or Company policies. the law; with full understanding that while we
acknowledge that discrimination exists in every labor
market in the world, Sadara can and will take steps to
protect against any unfair advantages or disadvantages
based on discriminatory factors. Sadara’s goal is to
always hire on the basis of “best candidate for the job.”

PEOPLE Discriminatory biased decision-making and treatment,

however, are not always conscious. We have taken our
Every one of you is an important part of us. The real value of commitment to fair employment practices in accordance
any organization is the experience, dedication, skills, with the law to the heart of our corporate culture.
innovativeness of its most valuable resource; its people. The Therefore, vigorous policy, and proactive prevention of
Company is its people.
discrimination – i.e., enhanced outreach, education, and
___________________________________________________
technical assistance to promote compliance – is critical to
ensuring that discrimination plays no part in employment
EQUAL EMPLOYMENT OPPORTUNITY decisions.
AND RESPECT IN THE WORKPLACE
Sadara’s pledges:
o We recognize, respect and will comply with all
When we respect the diversity of our workplace, we
labor, employment and residency laws within the
create an inclusive environment where everyone has the
Kingdom of Saudi Arabia, and elsewhere where
opportunity to perform to their highest potential.
we conduct operations or have staff members in
o Sadara provides employment opportunities to
residence.
qualified applicants.
o We believe that working positively and directly
o Hiring, promotion, compensation and other
with employees best serves their interests.
employment-related decisions are based on job-
o We respect diversity in the work place.
related factors. Sadara has a strict ‘no
o We strive to work cooperatively with duly chosen
discrimination’ policy in its hiring practices.
employee representatives in the common pursuit
o We strive to create an environment of mutual
of the best interests of the employees and the
respect, free from harassment and
Company’s mission.
unprofessional behavior. Bullying or threatening
o We do not use forced or involuntary labor.
behavior, intentionally expressed or implied, is
o We do not use child labor.
unacceptable. This includes any aggressive,
threats – expressed or implied, intimidating or
violent behavior that may create a hostile work
environment. HARASSMENT
o Conduct and statements that are intentionally
degrading, offensive, humiliating or intimidating Harassment is a particularly harmful form of inappropriate
to others are unacceptable. Seemingly innocent conduct and can create a very hostile work environment.
actions can create an environment that may be It can include verbal assaults, name calling, unsolicited
offensive, and we should be aware and sensitive physical contact, offensive jokes, slurs, offensive
of our own behavior and the effect it may nicknames or name calling, physical assaults or threats,
reasonably be construed to have on others. intimidation, ridicule or mockery, insults or put-downs,
offensive objects or pictures, and interference with work
performance by creating a work environment that is
uncomfortable or distressing for an employee. It can also
LABOR POLICY include inappropriate pictures, posters, screen-savers,
videos or e-mail messages.

Respect for human rights and dignity is a cornerstone of

our business. Failing to provide a work environment free of all forms of
harassment is not acceptable. Sadara will take every

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5|Page
reasonable step to ensure that the work environment is oThe more severe the harassment, the less
safe, healthy, and free from harassment. persistent it needs to be, and vice versa.
Accordingly, unless the harassment is quite
The conduct need not be explicit in nature to violate severe, a single incident or isolated incidents of
Sadara’s prohibition against discrimination. If reasonably offensive conduct or remarks generally do not
perceived as hostile, then it must not be allowed to create an abusive working environment. But a
continue. To determine if a work environment is hostile, single, extremely serious incident of harassment
all of the circumstances should be considered. Incidents may be sufficient to constitute a violation,
of harassment directed at other employees in addition to especially if the harassment is physical.
the offended party are relevant to a showing of hostile To protect employees from unlawful harassment, Sadara
work environment. will periodically train employees on the applicable policies
and procedures which the Company has adopted
There are two requirements for conduct to be considered regarding these issues, and will vigorously follow and
harassment: (1) the conduct must be unwelcome; and (2) enforce compliance.
the conduct must be reasonably severe or persistent to
alter the terms and conditions of employment in the mind RESPONSIBILITY
of the alleged victim and from the perspective of a
reasonable person placing himself or herself in the
victim’s position. Employers and employees each have an essential role in
preventing harassment. When employers and employees
both take appropriate steps to prevent and correct
 UNWELCOME CONDUCT: The conduct must be
harassment, offensive conduct generally will be corrected
unwelcome in the sense that the alleged victim
before escalating to the point of violating Company policy
reasonably regarded it as undesirable or offensive.
or local law. If an employee fails to report an incident to
When the conduct involves mistreatment or is
the proper Company representatives, the Company is not
derogatory in nature, to construe it as “unwelcome”
responsible for any outcome. The burden of raising an
usually is not an issue.
issue to the attention of the management or to the Office
of Ethics and Compliance, rests with the employees. Any
 SEVERE OR PERSISTENT: Abusive conduct does
complaint of harassment or discrimination which is not
not have to be so severe that it causes economic or
made in good faith; i.e. a false claim, where the individual
psychological injury. At the same time, conduct is not
intentionally or knowingly makes a false claim to
a violation just because it is uncomfortable, or
management, will subject the employee to disciplinary
inappropriate. The “severe or persistent” standard
action as prescribed by Sadara’s IR manual and the
reflects a “middle path” between these extremes.
Company’s Internal Work Rules.

Harassment will be analyzed on a case-by-case basis, by

looking at all the circumstances and the context. Relevant
factors in evaluating whether harassment creates a HEALTH AND SAFETY IN THE WORKPLACE
sufficiently hostile work environment may include any of
the following (no single factor is determinative): The Company and its employees should always use their
best efforts to maintain a safe and healthy work
o The frequency of the conduct; environment and be committed to eliminating work-
o The severity of the conduct; related injuries and illnesses, both within and outside of
o Whether the conduct was physically threatening, the workplace. Unsafe health and safety practices at
humiliating or inappropriate in nature; home can impact work-related practices and our
o Whether the conduct caused reasonable fear or capacities to perform suitably in the workplace.
concern to the employee in relation to their
o Employees and the Company share the
continued employment or promotion;
responsibility to make safety and health a daily
o Whether the conduct unreasonably interfered
priority.
with the employee’s work performance;
o We support each other in actions to live safely and
o The context in which the harassment occurred,
in good health by utilizing available resources and
as well as any other relevant factor;
observing recommended practices.

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 o We are accountable to take corrective action when are essential parts of the bigger picture. You are the
an unsafe or hazardous situation is brought to our corner stone of this.
attention.
o We are committed to traffic rules and safe driving ___________________________________________________
practices whether while at work, to and from work,
or in our personal circumstances.
CONFLICTS OF INTEREST
SUBSTANCE ABUSE IN THE WORKPLACE
We are expected to avoid situations where personal
Sadara is committed to the safety, health and security of interests conflict, or even appear to conflict, with those of
its employees, our operations and all those who come the Company. This includes any activity that may cause
into contact with them. We will not tolerate substance others to doubt our fairness or interferes with our ability to
abuse in the workplace. Employees are expected to work perform our job objectively. If there is a chance that a
free from the influence of any substance that could affect situation might be perceived as a conflict of interest, we
judgment or safety on the job. must disclose it to a supervisor, HR Services or the Office
of Ethics and Compliance, to initiate steps to get it
In strict accordance with local laws, Sadara forbids use or resolved.
entry of any illegal substances into the places of work.
Anyone who is found in possession of, or consumes such Conflicts of interest can take many forms. This Code
substance in the work place, shall be subject to the does not address every potential conflict of interest
punishments prescribed under the law. Sadara also situation, so we must use good judgment and seek
reserves the right to conduct drug and alcohol testing of guidance when unsure. Common conflict of interest
its employees and contractors, as permitted by local law. situations include:
o Having a financial or personal interest in a
company that does business with Sadara. See
VIOLENCE IN THE WORKPLACE also the section on Outside Interests in this
Code.
Violence or threatened violence will not be tolerated in o Receiving compensation or other incentives in
the workplace. Immediately report to a supervisor or excess of Company policy from a company that
Security any behavior or suspected behavior that has the does business with Sadara.
potential to become violent or that threatens the safety of o Holding a second job that interferes with our
people or property. Sadara reserves the right to search ability to do our job at Sadara.
any item on Company property for reasonable security o Hiring (or influencing the hire of) a supplier,
reasons, including offices, desks, computers, purses, distributor or other agent managed or owned by
briefcases, automobiles, packages and lockers, at any a relative or close friend.
time, as permitted by local law. o Engaging in an intimate or personal relationship
Weapons, firearms, ammunition, explosives and with a person you report to, or who reports to
incendiary devices are prohibited on Company property you.
and in Company vehicles. In some locations, the law
provides limited exceptions when being used in No Sadara employee involved in contracting activities
connection with legitimate business activities, and only by shall knowingly award a contract to a Company employee
individuals who are qualified and expressly authorized by or to a business associate or other organization owned or
the Company to use such devices in connection with substantially owned or controlled by one or more Sadara
performing their work for the Company. employees. This policy or rule is intended to avoid any
conflict of interest that might arise between the
employees’ interests and their Company duties and to
avoid the appearance of favoritism or preferential

BUSINESS
treatment by the Company toward its employees.

OUTSIDE INTERESTS
How we reach our goals is as important to us as reaching
them. Transparency, accountability, integrity and honesty

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As employees, we should avoid investments or other agent if we are in a position to affect Sadara’s
financial interests that could interfere, or appear to business with any of them.
interfere, with our ability to make decisions in the best o Be employed by, or receive any compensation
interest of the Company. from, any competitor of Sadara.
o Serve as an officer or director of any for-profit
We must not: company or organization outside of Sadara
o Hold a financial or personal interest in any without first disclosing and seeking formal
Sadara customer, supplier, distributor or agent if written approval from the Company’s
we are in a position to affect Sadara’s business Management Committee with endorsement of
relationship with them, unless such interest is by the Chief Compliance Officer or the Office of
way of passive investments in securities listed Ethics and Compliance.
on a stock exchange.
o Take any opportunity for business or profit that
belongs to Sadara, or compete with the SPEAKING AT CONFERENCES
Company in any way.

The annual Conflict of Interest Form that all Sadara If we are invited to speak at a conference because we are
employees and contractors are required to complete asks a Sadara employee or because of our expertise arising
each of us to declare any personal circumstances that from our Sadara job responsibilities, we cannot accept
may create a conflict of interest. It is important that we compensation. However, in such a situation, the
respond fully and honestly to the questionnaire; and that Company can accept reimbursement for reasonable
we promptly notify our supervisor or the Office of Ethics expenses. When in doubt, check with your immediate
and Compliance if a situation exists. Supervisor or the Office of Ethics and Compliance.

OUTSIDE EMPLOYMENT
RELATIVES, FRIENDS AND PERSONAL
In general, we may work outside of Sadara in any lawful RELATIONSHIPS
occupation as long as these other duties are performed
outside of normal working hours, do not interfere with our Many of us have relatives or friends who may have
ability to perform our Sadara job, are not in violation of business relationships with Sadara, our customers,
the Saudi Labor or Residency Law and are not readily suppliers, distributors, agents or competitors. These
perceived to violate the Company policies or the circumstances can raise conflict of interest questions,
guidelines as set out in this Code. However, pursuant to because others might think we are favoring these
Saudi Law, non-Saudi employees are prohibited from relationships above the interests of the Company.
engaging in any employment relationship, or other profit We must disclose to our supervisor and the Office of
generating activities, in Saudi Arabia during their Ethics and Compliance any situation in which:
employment with the Company.
o A relative or close friend has a financial interest
in, or works for, a Sadara customer, supplier,
For avoidance of doubt or potential conflict, any outside distributor or agent if we are in a position to
business interests, including employee involvement in affect Sadara’s business with them.
any family business must be disclosed in the Company o An immediate family member or close relative is
Conflict of Interest Form. If you are considering being employed by a competitor of Sadara.
involved in a new business interest at a time after the O We are put in a position where we directly or
annual Conflict of Interest Form has been submitted, you indirectly hire, supervise or otherwise have
can provide a written supplement thereto, addressed to authority over a relative or personal friend.
your immediate supervisor, describing your involvement
in the new interest since the filing of your annual Form.
GIFTS AND ENTERTAINMENT
We must not:
o Be employed by, or receive any compensation Gifts and entertainment are often used to strengthen
from a Sadara customer, supplier, distributor or business relationships, but we should not accept or offer

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8|Page
them if doing so could affect, or appear to affect, impartial o We do not offer or accept entertainment unless it
decision-making. is consistent with customary business practice.
For example, occasional business meals or
Before offering gifts or entertainment to customers or attendance at a theater or sporting events with
others outside the Company, we should understand the airline tickets, in or out of Kingdom, with a
recipient’s rules about accepting gifts and entertainment, customer or a supplier are generally acceptable.
as well as the Company’s policies in giving gifts. o We do not offer or accept entertainment that is
offensive, indecent or inconsistent with our
We do not offer or accept gifts or entertainment that could values or morals.
cause embarrassment to the Company, could be
construed as a bribe or kickback, or are in exchange for In the event gifts or entertainment related to a single
preferential treatment in any business dealing or as occurrence or in the aggregate as a pattern of behavior ,
influencing any governmental decision or action. In all whether offered to us or given by us, shall exceed the
cases they must be proper, legitimate and legal under sum of five hundred Saudi Riyals (SR500); or in the event
applicable law. Common sense will typically provide us there is any question or doubt as to the value, propriety or
with adequate guidance, however, below are some circumstances of any transaction(s) involving gifts or
general guidelines which all employees and Suppliers entertainment, you must get written approval from your
should understand and follow. Manager level supervisor, Business Line head or
Sadara’s Management Committee, as the circumstances
Guidance Specific to Gifts: warrant. You may also seek a written opinion from the
o We never offer or accept gifts in cash or a cash Office of Ethics and Compliance for specific guidance.
equivalent, such as a gift card. See also section on Bribery & Corruption in this Code.
o We do not offer or accept a gift that has a value
which is greater than the value of a promotional If you have additional questions outside the guidance set
item given to all clients or potential clients or forth above, contact your supervisor, the Law Department
which exceeds the sum of five hundred Saudi or the Office of Ethics and compliance.
Riyals (SR500); these values may be subject to
review and revision from time to time, as Certain functions and departments of the Company may
necessary and appropriate. adopt with the approval of the CEO more restrictive rules
o We may accept gifts or discounts offered to a relating to the offer or acceptance of gifts
large group of employees as part of an
agreement between the Company and a
customer, supplier, distributor or agent.
BRIBERY AND CORRUPTION
o Gifts given in relation to special recognition,
service awards, prizes or drawings at business We are committed to maintaining the highest ethical and
events do not require declaration. legal standards in our relationships around the world.
o If offered by Sadara, gifts must qualify as This includes our relationships with governments and
ordinary and customary business expenses in Government Officials as well as with other businesses.
line with the requirements of established Sadara We do not participate in bribery or corruption in any form.
expense approval procedures. No other gifts,
entertainment or hospitality offered by Sadara or Who are Government Officials?
on its behalf, other than as described above, are
allowed. o Employees of any government or government-
o Any offer of a gift that is restricted under this controlled entity anywhere in the world, including
policy must be reported, in writing to the Office low-level administrative officials.
of Ethics & Compliance o Political parties and party officials.
(EthicsHotline@sadara.com), and to the o Candidates for political office.
employee’s immediate Supervisor. o Employees of public organizations, such as the
United Nations.
o Employees of state-owned enterprises.
Guidance Specific to Entertainment:

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We must not offer, promise or give anything of value to a Government Officials, you should discuss your concerns
Government Official or to anyone else, in order to gain or with the Office of Ethics and Compliance.
maintain a business or a business advantage.
BUSINESS AND FINANCIAL RECORDS
Examples of bribes include paying or otherwise
compensating a Government Official to: Business and financial records are essential to Sadara’s
o Award a contract to the Company. success. The integrity and accuracy of these records help
o Obtain advantageous tax or customs treatment. internal decision-making and are the basis of our
o Obtain permits or regulatory approvals. reporting to shareholders, investors, creditors,
o Bypass or break laws or regulations applicable government agencies and other stakeholders.
to the Company.
o Obtain or provide confidential information related We must:
to contractor bidding, selection or awards. o Keep and present all Company records and
reports in accordance with the law and
We must not use a third party—such as a subcontractor, Company policies. These records include
consultant or agent—to pay a bribe. The Company and accounting records as well as any other
individual employees may be liable if a third party pays a electronic or written records, such as expense
bribe on our behalf, even if we did not direct the payment. reports, time sheets, medical claim forms,
personnel reviews and the wide variety of
We are equally vigilant to avoid bribery and corruption in analytical, engineering and technical reports.
transactions with other businesses and private parties. o Establish and maintain a Company-wide system
of strong and effective internal controls.
Similarly, we are strictly prohibited from accepting bribes o Ensure that all Company records accurately and
from others. Employees must never solicit, accept or fairly reflect the underlying transaction.
receive, directly or indirectly, any payment, loan, o Never falsify any document.
extension of credit, guarantee, gift, object of any value or o Record all financial transactions in the proper
any kind of preferential treatment from a third party in account, department and accounting period.
exchange for favorable treatment or consideration with o Ensure that all actions and commitments are in
regards to a transaction or dealing or engagement accordance with Sadara’s Management Guide -
(including the procurement of goods or services) of any Authorization Policy and Delegation of Authority.
kind with Sadara. This prohibition extends to all o Validate that all public communications,
members of our families as well as dependents, and to including reports to government authorities, are
any third party who may benefit at our direction. full, fair, accurate, timely and understandable.
o Raise any concerns about the accuracy of
To avoid even the appearance of improper conduct, Sadara records with finance management or
consult with the Office of Ethics and Compliance before through another appropriate channel.
giving anything of value (including gifts, meals, o Maintain the confidentiality of all records and
entertainment, and business or employment reports.
opportunities) to a Government Official.

GOVERNMENT OFFICIALS
USE AND PROTECTION OF COMPANY
Interactions with Government Officials are subject to RESOURCES AND
complex legal rules. Most national laws set out severe
penalties for bribery and corruption, including large fines INFORMATION/CONFIDENTIALITY
and imprisonment. Even simple acts like providing gifts to
a Government Official can raise suspicions of corruption. Sadara resources are intended for business use, and we
all have an obligation to protect and use them properly.
If you have a concern regarding an interaction you have
observed, or communications you have received from As employees we are expected to:

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10 | P a g e
 o Use Company funds legally and responsibly. o Store sensitive, proprietary or highly confidential
o Safeguard Sadara resources from theft, waste information in protected files on secure servers
and carelessness. provided by the Company.
o Not use Company funds or other resources to o Safeguard all electronic devices at all times.
support an outside business or unauthorized o Protect information security controls.
activity. o Protect Company equipment or systems from
illegal or other offensive or inappropriate
Examples of Company resources include: purposes.

o Company funds, credit cards and other accounts THIRD PARTY CONFIDENTIAL
o Computers, electronic networks and other office
equipment
INFORMATION
o Telephone and mobile communications devices
o Internet access and e-mail The Company has the contractual obligation to third
o Supplies parties not to disclose and to protect and preserve
o Company proprietary information designated confidential information, secrets and
o Automobiles proprietary information given by or otherwise obtained,
including copyrighted or patented materials, systems,
products, information and ideas. We, as Company
INTELLECTUAL PROPERTY employees, are likewise bound by and responsible for
preserving the integrity and expectation of the
Our continued success and future growth depend upon
confidentiality of third party’s confidential information, and
innovative products and solutions. To achieve a
shall exercise all the good care and diligence regarding
sustained competitive advantage for Sadara businesses,
the use and protection of both third-party and Company
we must protect our intellectual property against theft,
resources and information.
misuse and loss. With the support of the Law
Department, we all must take appropriate steps to secure
As employees, temporary or permanent, of a joint venture
intellectual property protection for Sadara inventions,
company, we may from time to time have access to
proprietary information, trademarks, trade secrets and
confidential, sensitive, intellectual property, or copy
copyrighted materials.
righted material of one or both shareholder companies.
Proper permission must be requested and given from the
respective shareholder company prior to extracting,
This includes:
sharing or utilizing information or documents. Consult
o Using the Sadara brand and trademarks,
with Sadara’s Law Department for clarification on these
including the Sadara logo, in accordance with
items.
Company guidelines.
o Reporting to the Law Department any concerns
about Sadara intellectual property being
infringed, misused or misappropriated.
o Respecting the trade secrets, copyrights,
trademarks, patent rights and proprietary PROPRIETARY INFORMATION AND
information of third parties by avoiding unlawful
use or infringement.
RECORDS MANAGEMENT

We are all responsible for maintaining the integrity of

INFORMATION TECHNOLOGY Sadara information and for using it appropriately.
Unauthorized disclosure of Sadara information could
We rely heavily on computer systems and
harm the Company or give an unfair advantage to others.
telecommunications networks. We must protect those
systems from misuse. We will:
This means we;
o Follow the Sadara Information Protection
Policies, and Security and Data Protection
o Classify documents according to Sadara’s
requirements.
policies and procedures.
o Use and protect passwords for computer or
network access.

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11 | P a g e
 o Retain and discard Company records consistent agreements. Please seek guidance before you disclose
with Sadara’s policies, procedures and any Customer-Confidential Information.
schedules.
o Follow all special record-keeping requirements DATA PRIVACY
issued with respect to internal investigations,
litigation and government inquiries.
Consistent with Sadara’s values, we respect the privacy
o Report loss of any Sadara information as soon
of individuals and protect their personal data.
as reasonably possible.
o We handle personal data responsibly and in
o Observe all contractual obligations to safeguard
accordance with applicable policies, any
others’ information, and do not disclose the
contractual obligations and local laws.
proprietary information of others.
o We use personal data only for legitimate
o Limit access to sensitive, proprietary or highly
business purposes.
confidential information to those who are
o We are open and transparent about the
authorized to access such information.
purposes for which we use personal data.
o Do not discuss Sadara information where the
o We protect personal data from unauthorized
conversation may be overheard or
disclosure.
compromised.
o We limit disclosure of sensitive personal data to
those who are under professional obligations of
If it is necessary to share proprietary information outside
confidentiality and who are trained in the proper
the Company, we must first consult our Supervisor to
handling of this kind of information.
ensure that adequate protections are in place, such as a
confidentiality agreement, and to ensure that we can
“Personal data” includes, but is not limited to, any
share the document with outside parties. Parties may
information about another employee that you had access
consult with the Law Department for additional guidance
to as a result of your employment with Sadara.
or assistance in this area.
Protection of “personal data” extends to individuals who
have been employed by Sadara and are no longer
Examples of Sadara proprietary information include, but
actively engaged; and shall extend to preclude specific
are not limited to:
information regarding an individual’s performance record
and or reasons for separation or termination of the
o Research and development (R&D) information
employer/employee relationship.
o Trade secrets
o Personnel records
o Business plans and proposals INSIDE INFORMATION AND TRADING
o Capacity and production information
o Marketing or sales forecast and strategies
Many of us are exposed to information about Sadara—or
o Client and customer list
about companies that Sadara does business with—that
o Pricing lists or strategies
may not be known to the public. This nonpublic
o Supplier data
information may, among other things, relate to business
or manufacturing plans, new products or processes,
We must obtain appropriate approval for external
mergers or acquisitions, serious business risks, sales,
presentations that contain Sadara information. Even after
negotiations or other financial information. Moreover, the
we leave Sadara, we have a continuing obligation to
information we are exposed to may be fact or may be
protect the Company’s proprietary information.
rumor, fiction or otherwise flawed. In line with the
Company’s commitment to the highest standards of
SADARA AS A SERVICE PROVIDER OR ethics, as well as to full compliance with all applicable
SUPPLIER laws and regulations, including the Saudi Capital Market
Law, the Company, when appropriate, will adopt policies
and procedures with respect to the trading of the shares
When Sadara is acting as a service provider or supplier, it
of either the Company or of companies Sadara does
has an obligation to protect the confidential information of
business with. We do not trade in Company securities, or
its customers. This “Customer-Confidential Information”
those of any other company, using material nonpublic
should be shared only with authorized Sadara
information gained through our work at Sadara, nor do we
representatives, as designated in the controlling
disclose this kind of information to others so that they

To report a violation of the Code: http://sadara.com/en/about/Ethics_and_Compliance

12 | P a g e
may trade. Insider trading is illegal and will not be prohibited conduct when it involves the Company or the
tolerated. Company’s assets, employees, contractors, or suppliers.

Material nonpublic information is any information that (c) To aggressively pursue the maximum financial
could affect a reasonable investor’s decision to buy, sell remedies from any person who knowingly engages in
or hold the securities of a company. Insider trading rules such prohibited conduct and from any direct Contractor
are complex. When in doubt, consult the Office of Ethics whose employee, Subcontractor, or Subcontractor
& Compliance or the Law Department. Being an insider Employee provides, accepts, or charges a bribe or
does not mean you are completely restricted from trading kickback.
in the Company’s securities. It does mean that you are
subject to strict limits on when you can trade in the (d) To require a direct Contractor or Subcontractor to
Company’s securities. These restrictions also apply to report in writing to the Company any possible violation of
trading securities of the Company’s shareholders, this policy when the direct Contractor or Subcontractor
affiliates, Sadara joint venture companies, and any other has reasonable grounds to believe such violation may
company in which your work with Sadara has allowed for have occurred.
you to have inside information which is not available to
the general public.
(e) To provide that, for the purpose of ascertaining
whether there has been a violation of this Policy with
CONTRACT CLAUSE respect to any contract, the Office of Ethics and
Compliance, in cooperation with any other Sadara
All Sadara contracts shall include a clause referencing organization deemed necessary, shall have access to
Sadara’s ambition to instill a culture of Anti-Bribe and No- information and may conduct an investigation, when
Kickback in its workplace and a zero tolerance of such necessary, of any facility, books and records, including
illegal practices among its own employees, its Suppliers any electronic data or records, of any direct Contractor or
and other third parties with whom it does business. Such Subcontractor under a contract awarded by such agency.
Contractual clause shall provide, in effect, the following:
(f) To require each contracting agency to include in each
“All Parties to this Agreement do hereby agree to and contract for other than commercial items, a requirement
adhere to a strict ‘No Tolerance’ policy for Bribes or that the direct Contractor shall cooperate fully with any
kickbacks. All Parties agree take reasonable actions and Sadara investigation of a possible violation of the policy.
precautions designed to prevent and detect Bribe or
kickback. All parties agree to notify the other parties in VOIDING & RESCINDING CONTRACTS
writing if they have reasonable grounds to believe any
violation may have occurred. Furthermore, all parties
In the event:
agree to cooperate fully with any investigation of
suspected illicit behavior.”
(1) There has been a final conviction for bribery
or taking a kick-back, conflict of interest,
Sadara pledges:
disclosure or receipt of contractor bid or
proposal information or source selection
(a) To take every reasonable effort to prohibit any person information in exchange for a thing of value or to
from: give anyone a competitive advantage in the
award of a Company contract, or similar
(1) Providing, attempting to provide, or offering misconduct; or
to provide any bribe or kickback; or
(2) There has been Company determination that
(2) Soliciting, accepting, or attempting to accept contractor bid or proposal information or source
any bribe or kickback; selection information has been disclosed or
received in exchange for a thing of value, or for
(b) To aggressively pursue criminal penalties against any the purpose of obtaining or giving anyone a
person who knowingly and willfully engages in such competitive advantage in the award of a
Company procurement contract,

To report a violation of the Code: http://sadara.com/en/about/Ethics_and_Compliance

13 | P a g e
the Company shall have reserved the right to void, Information about our competitors enables us to better
rescind or otherwise terminate the contract for cause, and understand market demands and improve our products
to pursue all legal and criminal remedies afforded to it and services, but we must always gather competitive data
under the applicable laws of the governing jurisdiction. legally and ethically. To obtain competitive intelligence,
The authority to approve actions to void and rescind we will use publicly available information, including
contracts is restricted to the Chief Executive Officer of published articles, market analyses and purchased
Sadara. reports.

o This means we will not seek a competitor’s

COMPETITION confidential information, or accept anyone else’s
confidential information, without their consent.
Our responsibility to conduct business ethically extends
o We will never use illegal or unethical means
to our relationships with customers, shareholders,
(e.g., theft, bribery, misrepresentation or
suppliers, competitors and regulators. This means
espionage) to obtain competitive information.
competing within appropriate legal boundaries and on the
o We will comply with all applicable laws when
basis of price, quality and service.
gathering competitive information.

ANTITRUST AND FAIR TRADE TRADE CONTROLS

Sadara is adamant about winning business ethically and We conduct business on an international scale in a world
obeying all antitrust and trade laws, which demand free that can be dangerous. To prevent terrorism, halt the
and fair competition. We do not have discussions or proliferation of weapons and fight narcotics trafficking and
reach agreements with competitors or others that may other crimes, various governments have established
restrict open competition in business or fair employment. trade controls that restrict certain business transactions
This includes but is not limited to conversations with and the movement of certain goods across national
competitors about: borders.
o We must abide by all trade controls applicable to
o Prices or credit terms. our business.
o Submission of bids or offers. o Trade control laws can restrict:
o Allocation of markets or customers, or division of • Export of certain goods, services and
territories. technology.
o Restrictions on production or distribution. • Business dealings (including import, export
o Boycotts of suppliers, employee candidates or and investments) with certain countries,
customers. entities and individuals.
o Employee compensation packages • Travel to certain countries.
• Exchange of information.
We do not engage in any unfair, misleading or deceptive o As a joint venture with international partners, we
trade practices. We advertise, promote and label our must follow both Saudi Arabian and U.S. export
products and services in a factual, honest and informative controls, trade restrictions, economic sanctions
way. Sadara adheres to strict compliance of all relevant and anti-boycott laws however they may apply to
local and international Competition Laws, Anti-trust and our business activities, as well as local trade
fair trade laws. controls wherever we do business.

All Suppliers, Manufacturers, Contractors, Sub- The laws on this subject are complex and subject to
Contractors, etc. who wish to establish a business frequent change. The penalties for violating trade control
relationship with Sadara, will be required to know and laws can be severe. Consult a Law Department Attorney
abide by the Sadara Supplier Code, as well as sign the before engaging in any transaction that may potentially
Acknowledgement form. involve products or services subject to export controls, a
sanctioned country or a prohibited party
GATHERING COMPETITIVE
INFORMATION
C I T I Z E N S H I P
To report a violation of the Code: http://sadara.com/en/about/Ethics_and_Compliance
14 | P a g e
Sadara understands it is only a part of the bigger whole. CHARITABLE ACTIVITIES AND
We depend on the community as much as it depends on
us. When the community thrives, so do we. VOLUNTEERISM
"Social obligation is much bigger than supporting worthy
causes. It includes anything that impacts people and the Sadara encourages participation in local, national and
quality of their lives." international community processes to fulfill our Corporate

~William Ford Jr., Chairman, Ford Motor Co.

Social Responsibilities.
o If we express personal views in a public forum
___________________________________________________ (such as a letter to the newspaper), we must not
use Company letterhead or Company e-mail, or
refer to our business address or title.
SETTING THE STANDARD FOR o We always comply with all relevant laws
SUSTAINABILITY regulating Sadara’s participation in social or
community affairs, including charitable
contributions.
We are all part of a complex system that requires
balance, innovation and an uncompromising focus on Sadara supports both employee and Company
protecting our planet. Our commitment to each other and participation in a variety of charitable endeavors around
to environmental stewardship requires us to ensure that the world. That participation can range from financial
our products, operations and behaviors adhere at all contributions, contributions of employee time or
times to applicable governmental standards, Sadara resources, to donations of Sadara products, services and
environmental standards and approved compliance other resources.
plans. We will:
o Support our personal community activities on
The product safety and environmental laws are complex, our own time, with our own resources and not as
are subject to frequent changes and vary from country to a representative of Sadara, except when
country. If you have any questions or concerns, you formally appointed and engaged as a sponsor
should seek advice from a Law Department Attorney or representative on behalf of Sadara in a
an HSES subject matter expert to clarify how these laws Company-sponsored activity or event.
apply to your job. o Obtain authorization for any donation to any
charity in Sadara’s name.

CORPORATE CITIZENSHIP
We will not:
o Represent Sadara in any public process or
We are committed to making positive change through forum unless specifically requested to do so by
community partnerships, charitable giving and management.
volunteerism. Through our science, expertise, o Obtain reimbursement from Sadara for personal
innovation, volunteerism and donations, we are taking expenses or donations to charitable activities.
bold steps to help solve some of the world’s most
challenging problems. Through relationships with our
neighbors and partners, we are building better, stronger, COMMUNICATIONS WITH THE PUBLIC
more sustainable communities in the places where we do
business. Our sustainability goals and corporate We strive to communicate with the public in an accurate
citizenship initiatives are a source of pride for employees. and consistent way. To be sure that we comply with the
law and protect our interests, only those who are
o We engage in active dialogue with organizations specifically designated to do so should represent the
representing the communities where we do Company to the public or media.
business. If we receive an inquiry from an outside contact about a
o We support initiatives that address the goals and Company matter, we should direct the inquiry to our local
needs of the community and seek to leverage Public Affairs representative.
our capabilities to support those communities.

To report a violation of the Code: http://sadara.com/en/about/Ethics_and_Compliance

15 | P a g e
SOCIAL MEDIA established by Board of Director’s Ethics & Compliance
Committee (ECC) and its directive and charter are
directly prescribed by the ECC.
Social networks and other forms of social media are
becoming part of the business mainstream. In general,
the rules that apply to new communication tools are INVESTIGATION AND RESPONSE
consistent with traditional communication rules.
Specifically: The Company takes seriously and fully investigates all
potential law or policy violations. The OEC has the
Do: responsibility to investigate all complaints or concerns
o Clearly distinguish between authorized business brought to its attention. Relevant subject matter experts
communication and personal communication. If conduct the investigations. Investigations are conducted
you give a personal opinion on public issues, do in a way that is respectful, confidential and fair. If the
not create the impression that you represent investigator substantiates an allegation, an appropriate
Sadara or are expressing the views of Sadara. management team will review the findings and determine
o Respect trademark, copyright, fair use, trade the final outcome.
secret and financial disclosure laws and
Company guidelines. The Company will protect anyone who raises a concern
o Adhere to Sadara’s values in all authorized honestly, but it is a violation of this Code and Company
business communications. Policy to knowingly make a false accusation, lie to an
investigator, or interfere with or refuse to cooperate in an
Don’t: investigation. We are all expected to be truthful and fully
o Speak on behalf of Sadara unless you are a cooperate in any investigation.
designated spokesperson and have permission
to do so.
o Disclose any confidential information belonging ACKNOWLEDGEMENT
to Sadara, its employees, customers, suppliers
or other business partners. We must initially and periodically acknowledge that we
o Refer to Sadara customers, suppliers or have read the Code and agree to abide by the Company
business partners without their approval. policies and the laws which are the basis for the Code .
o Endorse Sadara products or services without Failure to read or acknowledge the Code does not
prior approval. excuse us from compliance with the Code, our policies or
o Divulge personal data about others, especially the law.
personal data obtained as part of your Sadara
relationships.
WAIVER

ADMINISTRATION OF
The Board of Directors or its designated committee must
approve any modification or waiver of a provision of the

THE CODE Code, and the Company will disclose such modifications
and waivers publicly as required.

___________________________________________________

OFFICE OF ETHICS & COMPLIANCE

The Office of Ethics and Compliance (OEC) is a division

in the Sadara Law Department. The OEC works in
conjunction with the General Auditor and the Audit
Committee of the Board of Directors, Sadara Finance
Organizations, Industrial Relations organizations, as well
as with Security and Safety Organizations. The OEC was

To report a violation of the Code: http://sadara.com/en/about/Ethics_and_Compliance

16 | P a g e
CONTACTS Having a code of conduct, a standard
of courage, discipline, determination
Questions or concerns about proper conduct may be
addressed with:
and integrity makes this company...
 Your Immediate Supervisor or HR Services
representative Our Company!

 Office of Ethics & Compliance

(http://sadara.com/en/about/Ethics_and_Compli
ance)

 Board of Director’s Ethics & Compliance

Committee members:
o Jim McIlvenny,
Jmcilvenny@dow.com
o Ahmad A. Al-Sa’adi,
Ahmad.Saadi@aramco.com
o Peter Holicki,
Phholicki@dow.com
o Faisal Al Faqeer
faisal.faqeer@aramco.com

Or Contact us by mail:
SADARA CHEMICAL COMPANY
Office of Ethics and Compliance
P.O. Box 11811
Jubail Industrial City 2
Jubail 31961, Saudi Arabia

THE FINAL PIECE OF THE

PICTURE IS YOU!

To report a violation of the Code: http://sadara.com/en/about/Ethics_and_Compliance

17 | P a g e