Code of Ethics ORASCOM
Code of Ethics ORASCOM
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CODE OF ETHICS
INTRODUCTION
This Code of Ethics (the “Code”) contains the policies that relate to the legal and ethical standards of
conduct that the directors, executive officers , senior financial community and all other employees of
ORASCOM CONSTRUCTION LIMITED and its subsidiaries (the “Company”) are expected to comply
with while carrying out their duties and responsibilities on behalf of the Company.
This Code is intended to focus the Board of Directors of ORASCOM CONSTRUCTION LIMITED (the
“Board”) and management on areas of ethical risk and their obligations and responsibilities that directly
relate to their financial and accounting roles. It should be read in conjunction with the Company’s Code
of Business Principles and Conduct.
No code or policy can anticipate every situation that may arise. The Company expects each director,
executive officer and employee to act with honesty and integrity, to exercise independent professional
judgments and to deter wrongdoing in the conduct of all duties and responsibilities on behalf of the
Company.
This Code was approved and adopted by the Board and is available on the corporate website.
STANDARD OF CONDUCT
act in accordance with the Company’s high standards of honesty, integrity, and fairness to foster a
business climate that maintains such standards.
adhere to the Company’s Code of Business Principles and Conduct, and any applicable code of
conduct, including the Company’s Insider Trading Code.
Employees should comply with the laws, rules and regulations applicable to the Company.
CONFLICT OF INTEREST
Employees should avoid conflicts of interest between themselves and the Company. A “conflict of
interest” can occur when the private interest of an Employee interferes in any way - or even appears to
interfere - with the interests of the Company as a whole. A conflict situation can arise when an Employee
takes actions or has interests that may make it difficult to perform his or her company work objectively
and effectively. Conflicts of interest also arise when an Employee or a member of his or her immediate
family receives improper personal benefits as a result of his or her position in the Company. Any
situation that involves, or may reasonably be expected to involve, a conflict of interest with the Company
should be disclosed promptly to its immediate or next higher level manager or to the reporting officer in
accordance with the Company’s Whistleblower Policy.
CORPORATE OPPORTUNITIES
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Employees are prohibited from (a) taking for themselves personally opportunities that are discovered
through the use of corporate property, information or position, (b) using corporate property, information
or position for personal gain, and (c) competing with the Company.
CONFIDENTIAL INFORMATION
Employees should maintain the confidentiality of information entrusted to them by the Company or its
customers, except when disclosure is authorized or legally mandated. “Confidential information”
includes all non-public information that might be of use to competitors, or harmful to the Company or its
customers, if disclosed.
INSIDER TRADING
Employees may come across information that is not yet publicly available, but which could be valuable
to investors. None should disclose or use non-public information that a reasonable investor would
consider important when deciding whether to trade. All Employees must comply with the Company’s
Insider Trading Code.
Employees should accurately reflect the transactions of the Company in its books, records, accounts and
reports and should maintain an adequate system of internal controls and disclosure controls to promote
compliance with the laws, rules and regulations applicable to the Company. Falsification of any
Company record is prohibited. All reports, documents or communications authorized or legally mandated
for disclosure to the public should be full, fair, accurate, timely and understandable.
Employees should promote ethical behavior and should encourage other Employees to talk to
supervisors, managers or other appropriate personnel when in doubt about the best course of action in a
particular situation.
The Company has adopted a Whistleblower Policy that provides a comprehensive procedure to report any
suspected criminal or unethical conduct within the Company. The Company’s Whistleblower Policy is
available on the corporate website.
ACCOUNTABILITY
Employees are each held accountable for Code compliance with regard to issues within his or her control.
Sanctions for a breach of this Code shall be determined by the Board or the appropriate officer as
designated by the Board. Sanctions may include serious disciplinary action, suspension from office or
dismissal, or other remedies all to the extent permitted by law and as deemed appropriate under the
circumstances.
Any amendments to or waiver of this Code shall be made only by the Board. If an amendment to or
waiver of this Code is made or granted, appropriate disclosure will be made as required by applicable
laws and stock exchange regulations.