CODE OF CONDUCT

GUIDELINE STATEMENT

ARISTO METAL INDUSTRIES (AMI) is proud of its commitment to always conduct business with the highest
degree of integrity and in full compliance with applicable laws and regulations. This commitment to integrity and
high ethical standards extends to AMI’S dealings with all of its vendors, suppliers, and contractors (collectively,
“Suppliers”). It is through this commitment we seek to ensure that we conduct our business in a responsible
manner. We expect our Suppliers to have a similar commitment. It is the Supplier’s responsibility to achieve and
maintain the minimum standards outlined in this Supplier Code of Conduct (Code), and train employees and
contracted parties on their consequential rights and responsibilities.

AMI will assess its Suppliers’ compliance with this Code, and any violations of this Code may jeopardize the
Supplier’s business relationships with AMI, up to and including termination. This Code applies to AMI suppliers
and their subsidiaries, affiliates, and subcontractors (each a “Supplier”) providing goods or services to AMI.

COMPLIANCE WITH LAWS, CODES, AND REGULATIONS

AMI suppliers must abide by this Code and its principles, and comply with the laws, rules, and regulations of
the Kingdom of Saudi Arabia and the locations in which they operate as well as all applicable treaties and
international standards.

They are expected to be familiar with the business practices of their suppliers and subcontractors, and ensure
they also cooperate in accordance with the standards found in this Code.

ENVIRONMENT, HEALTH, AND SAFETY

It is the responsibility of the supplier to ensure that its facilities are designed and safely operated in compliance
with the established government and industry environmental protection policies and that they do not present
unnecessary risks to the environment or public. AMI suppliers shall provide safe, sanitary, and healthy living
quarters with reasonable personal space for all their employees.

Such compliance shall include, among other things:

• Obtaining, maintaining, keeping current, and complying with all required environmental permits and
registrations.
• Supplier shall comply with the reporting requirements of applicable environmental permits and
regulations.
• Proper handling and disposition of hazardous materials and refuse.
• Monitoring, controlling, and responsibly treating discharges generated from operations.
• Having written safety and health policies and procedures.
• Conducting appropriate employee safety training and providing adequate safety equipment.
• Providing training required to promote sound public health and hygiene practices.
 • Maintaining records of safety training and monitoring safety performance
• Ensuring Suppliers’ employees comply with applicable health and safety rules and regulations and
perform their duties and work in a manner which will not endanger themselves or others.
ETHICAL BUSINESS PRACTICES

AMI and its suppliers shall conduct their businesses in accordance with the highest standards of ethical
behavior. This includes complying with the US Foreign Corrupt Practices Act (FCPA) and other applicable
international anti-corruption conventions. Suppliers are expected to conform to these requirements in each of
the following areas:

FAIR TRADE PRACTICES

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

ETHICAL SOURCING

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

RELATIONSHIPS AND COMMUNICATIONS

AMI Business Ethics Policy requires that all transactions are to be conducted fairly, honestly, and with integrity,
according to the highest ethical standards. Suppliers and their personnel shall avoid even the appearance of
unethical or compromising practices in relationships, actions, or communications with regard to existing or
proposed business relationships with AMI.

AMI views it as conflict of interest and improper business practice for current or former AMI employees to utilize
any confidential or proprietary business, technical, or other information obtained while in the service in AMI to
influence AMI’s existing or proposed commercial transactions for the purpose of gaining a personal commercial
advantage, or benefitting any third party, or to otherwise damage AMI, whether during or after leaving employment
by AMI.
Suppliers shall not encourage or utilize current or former AMI employees in any manner which would cause
them to disclose or provide any confidential, proprietary, or other restricted information obtained while
employed by AMI to influence AMI’s existing or proposed commercial transactions for the purpose of gaining
a commercial advantage.

Suppliers shall not hire, employ, engage as a consultant, procure the service, or allow acquisition of any
ownership interest of the Supplier, except through a permitted passive investment, by any current AMI employee.
The restriction shall also apply to any former employee who has held a position within AMI at the
level of “department head” or higher. The restriction pertaining to former employees shall be valid for a period of
two (2) years following the time that such individual is no longer an employee of AMI.

Suppliers may seek exceptions to these restrictions from AMI. Request for such exceptions should be submitted
to the Chief Compliance Officer. AMI will take appropriate measures to detect any such improper business
practices and will take appropriate action against current or former employees and Suppliers who violate these
restrictions. Suppliers are expected to cooperate with AMI investigations and to provide assistance as requested.

BRIBERY, KICKBACK AND FRAUD

No funds, assets, services, privileges, or benefits shall be paid, rendered, loaned, or promised for payment or
otherwise dispersed by Suppliers or their representatives as bribes, “kickback”, or other payments or inducements
designed to influence or compromise the judgment or conduct of AMI or its representatives.

GIFTS, GRATUITIES AND HOSPITALITY

Suppliers and their personnel shall not offer or provide AMI or its personnel with gifts, gratuities, or hospitality
unless it is unsolicited, involves nominal value and is in line with customary business practices. Nominal gifts are
described as a gift of a general nature having a low value, including such items as logo inscribed pens, caps,
shirts, and coffee mugs. Customary business practice in terms of hospitality would include the acceptance of
reasonable business entertainment and business meals.
Gifts, gratuities, and hospitality offered or extended by Suppliers to AMI personnel which exceed nominal value or
reasonable hospitality are reportable under AMI policies and regulations. Items which are made available to the
general public do not fall under this Policy.

MONITORING AND COMPLIANCE

Suppliers shall be responsible for complying with the standards and requirements of this Supplier Code of Conduct
and to monitor their own business activities. Suppliers shall conduct periodic internal review, inspections, and
audits to ensure their compliance with this Supplier Code of Conduct and it applicable requirements. Additionally,
Suppliers are responsible for ensuring that the standards and requirements of this Code are communicated, and
understood by their personnel working or in support of AMI projects, jobs, contracts, agreements, and orders.
Suppliers will be held responsible for the conduct and action of their employees.

The implementation of this Policy is a shared responsibility between AMI and its Suppliers. Suppliers are to
promptly disclose to AMI, on a confidential basis, all current and potential incidents which give rise to the
appearance of conflicts of interest and instances of unethical or fraudulent behavior by any party including Supplier
employees or AMI employees, related to any AMI procurement and contracts business. Suppliers are to
 cooperate with AMI in any inquiries or investigations pertaining to past, current, or potential instances of unethical
or fraudulent behavior or conflicts of interest related to any AMI business activity.

Suppliers are to promptly notify AMI when they become aware of any actual, or potential violation of this Code of
Conduct and to communicate plans to correct and remedy such violation. Additionally, Supplier employees that
become aware of violations of this Code are to notify AMI.

Potential or actual violations of this Code of Conduct and other ethical irregularities are to be reported directly to
AMI Chief Auditor, and Chief Compliance Officer by email, letter, or telephone as follows:

Email: [email protected]

Phone: +91 9619272709

Address: 94, C.P.Tank Road,

All matters raised in good faith through these reporting lines will be handled in confidential, non- retaliatory manner.

Suppliers shall maintain appropriate records to substantiate compliance with the terms and conditions of this
Code of Conduct and provide evidence to AMI upon request. AMI or it designated representatives may engage
in periodic monitoring activities to confirm Suppliers’ compliance with this Code of Conduct. These monitoring
activities may include on-site inspections of facilities, use of questionnaires, review of publicly available
information, or other measures necessary to assess Supplier compliance with this code of conduct. Such
monitoring activities may be performed in addition to any audit rights which may be set forth in an agreement
with AMI. A Supplier performance assessment will be used by AMI as a factor in the selection of bidders, the
administration of contracts and procurement or possibly restrict Supplier access to new AMI business
opportunities.

Based on the assessment of information made available to AMI, AMI reserves the right (in addition to all legal
and contractual rights) to disqualify any potential Supplier or terminate any relationship with a current Supplier
which AMI has found to be in violation of this Supplier Code of Conduct, without liability.

CONFIDENTIALITY

As part of the process of seeking to provide goods, services, or personnel (including consultants) to AMI or in
providing such goods, services, or personnel under the terms of an applicable Agreement, Suppliers may gain
access to information or material which AMI deems to be proprietary or confidential. Suppliers, in all
instances, shall comply with the obligations of confidentiality which are set forth in the applicable request for
proposal, invitation to bid, other solicitation document, or agreement by and between AMI and the Supplier.

AMI views breaches of confidentiality and unauthorized disclosure or use of proprietary or confidential
information very seriously and reserves the right (in addition to all other legal and contractual rights) to disqualify

any potential Supplier or to terminate any relationship with a current Supplier AMI has found to have violated its
obligations of confidentiality.

All advertising, press releases, or printed matter that references AMI or a Supplier’s relationship with AMI must
be approved by the AMI Corporate Communication Department prior to publication or other use.

APPLICATION

The Supplier Code of Conduct is a general statement of AMI’s expectations and requirements with respect to its
Suppliers. The Code of Conduct should not be read in lieu of, but in addition to, any Supplier obligations set forth
in a) requests for proposals, invitation to bid, or other solicitation documents, or b) agreements by and between
AMI and the Supplier. In the event of a conflict between this Code of Conduct and any AMI solicitation documents
or applicable agreements, the terms of the applicable solicitation documents or agreements shall prevail. The
requirements of this Code of Conduct are not subject to waiver. Neither AMI, nor their personnel or
representatives are authorized to propose or approve conduct inconsistent with this Code of Conduct.