Business Code of Conduct Policy

Business Code of Conduct Policy

HR DEPARTMENT-EGYPT
December 2016

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CEO MESSAGE

Whether it’s improving, ethical safety and reliability, delivering better service and product for
our customers, or earning back their trust and confidence, all of us at LAZURDE are working
hard to ensure that our company is on a solid foundation for the future. Strong performance
is critical to our success, but just as important is how we go about achieving results—with
honesty and respect, without taking shortcuts, and by operating ethically and with integrity in
all that we do.
To help guide and align our behaviors as we make business decisions that impact our daily
operations, we rely on our Employee Code of Conduct, which outlines our values and
describes our standards for conduct, compliance, and avoiding conflicts of interest. It
supports our continuing commitment to honest and ethical conduct and compliance with
both the letter and the spirit of all laws, rules, and regulations, and our company’s policies,
standards, and procedures.
Use our values and this Code as guides whenever you have a question about the right thing
to do. For additional guidance, you should talk to your supervisor or Human Resources
representative, or contact the Internal Audit Manager.
Thank you for your ongoing commitment to delivering safe, reliable, affordable Jewellery
product and related service—and doing so ethically and with integrity.

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L’AZURDE VALUES

Controlling and organizing the rules of conduct and code of ethics in L’AZURDE can be
achieved by encouraging and adopting the following values:

1. Inspire our employees by empowering them with a clear and common understanding of
the ethical boundaries in which we must operate.

2. Engage our diverse workforce by ensuring that we maintain a respectful and welcoming
work environment.

3. Create a sustainable compliance and integrity framework to support innovation in

products, processes and solutions in a highly regulated world.

4. Deliver growth by earning the trust of our employees, customers and business partners
that we will always conduct business with uncompromising integrity.

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I. Code of Conduct Policy

1. PREAMBLE: PURPOSE AND SCOPE

As an international company with a long tradition, L’azurde enjoys an excellent reputation throughout the
world. The operational framework within which we operate is described in this code of conduct, which
we consider to be an integral part of our responsibility-conscious company management and lived
values.
This code of conduct applies throughout the world to all employees and organizations within the
L’azurde group. By complying with the procedures described in this code of conduct, we contribute to
the security of our long-term business success and guarantee at all times a consistently fair and
responsible treatment of our employees, business partners and natural environmental resources.
The essential foundation of all transactions at L’azurde is compliance with all binding statutory
requirements at the national and international level, as well as compliance with voluntarily accepted
obligations. All employees and organizations at L’azurde are obliged to inform themselves regarding the
requirements applicable to their area of responsibility in the company, to apply them and to obtain
additional information and advice from the relevant offices in cases of doubt.
This code of conduct will be supplemented with special guidelines for particular subject areas such as,
for example, the guidelines applicable throughout the world for the procurement of goods and services
(still to be drafted) and the guidelines for the prevention of money laundering (Internal regulations for the
fight against money laundering and the compliance of the precious metals control legislation).

2. ENSURING FAIR COMPETITION

L’azurde expects its employees to comply with the applicable laws for the protection of fair and open
competition. The applicable statutory provisions generally prohibit price or term agreements with
competitors, agreements with competitors for the purpose of market or customer allocation, coordinated
actions with competitors with respect to prices, terms, market or customers, as well as unfair practices.

3. THE FIGHT AGAINST CORRUPTION

L’azurde is convinced of the quality of its products and services and the capabilities of its employees.
The L’azurde group absolutely prohibits bribery of customers with money or objects of value. Employees
of the L’azurde group are prohibited from demanding money or objects of value as consideration for the
acceptance of products or other services, from promising them, and from accepting them. L’azurde has
issued guidelines, which contain binding provisions for all employees of the L’azurde group, for the
prevention of bribery in commercial transactions as well as for the procurement of goods and services
(Guidelines for the procurement of goods and services).

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4. THE FIGHT AGAINST MONEY LAUNDERING

Compliance with the national and international provisions for the prevention of money laundering and
the responsible handling of precious metals are of particular importance to the L’azurde group. L’azurde
has therefore issued to all employees binding guidelines on the prevention of money laundering and the
compliance with the London Bullion Market Association (LBMA) regulation, Dubai Multicommodity
exchange (DMCC) regulations and Saudi Arabian monitory Agency (SAMA), . (Internal regulations for
the fight against money laundering and compliance of the precious metals control legislation).
In our continuous efforts for a rigorous compliance with the "Best Practices" regarding the
commencement and development of business transactions, L’azurde pursues a risk assessed "Know
your customer" business policy. In addition L’azurde initiates the dialogue with all relevant partners,
amongst which also non-governmental organizations (NGO).

5. NO ILLEGAL ACTIVITIES AND VIOLATIONS OF REGULATIONS BY NATIONAL, GCC

AND INTERNATIONAL ORGANIZATIONS

The L’azurde group does not want to be abused for illegal purposes. This applies to any illegal behavior
of its customers, third parties, intermediaries, employees and business partners of the L’azurde group.
The employees are neither to let themselves to be entangled in their working environment into illegal
procedures nor are they to tolerate illegal actions in connection with the L’azurde group. That applies in
particular to the assistance for criminal tax evasion or to other fiscal delicts including tax evasion, both in
the country of the company's headquarter and in other countries, in which the L’azurde group is active.
L’azurde adheres to all national, GCC and multinational laws and dispositions. All employees of the
L’azurde group are obliged to adhere to all official authorization provisions, in particular to valid UN
sanctions in force, foreign trade regulations, export and import embargos, as well as permission
reservations by official authorities. The detailed regulations are described in the "Internal regulations for
the fight against money laundering and the compliance of the precious metals control legislation", as
well as the world-wide valid" Guidelines for the procurement of goods and services".

6. WHISTLE BLOWING

L’azurde is committed to the highest standards of conduct and requires to have strong whistle blowing
policy and procedures in place and well communicated to all employees to conduct themselves at all
times with honesty and integrity in carrying out the organization’s work. However, sometimes
malpractice and wrongdoing may occur. In order to maintain company’s high standards, it is essential
that anyone working for L’azurde feels able to raise any concerns they have about the way L’azurde’s
activities are being conducted.

Whistle blowing is the process whereby a whistle-blower exposes misconduct, alleged dishonest or
illegal activity occurring in an organization. The alleged misconduct may be classified in many ways, for
example a violation of a law, rule, regulation and/or a direct threat to public interest, such as fraud,
health and safety violations and corruption. Whistle blowers frequently face reprisal, sometimes at the
hands of the organization or group which they have accused.

Refer to whistle blowing policy that considers integral part of Code of Conduct Policy.

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7. AVOIDANCE OF CONFLICTS OF INTEREST

Board of Directors Conflict of Interest

Members of the Board must discharge their duties in good faith, recognizing at all times their fiduciary
duty to L’azurde. Directors are required to avoid conflict of interest and may not benefit at the expense of
the company. All Members of the Board shall not disclose any confidential or proprietary information
relating to the Company.

Employees
L’azurde expects from its employees to not exert activities or take over tasks, which go against the
interests of the L’azurde Group.
Secondary employment at a company of a competitor, a customer or a supplier is not permitted.
Financial investments in any companies whether quoted or e not quoted in the stock market, or of a
customer or a supplier are not allowed as well.
Exceptions need to be approved in writing by the management of the company. Financial investments
by close relatives are to be communicated to the management of the company.
Favoritism for specific business partners due to private interests, in particular favoritism for family
members, is prohibited. Even the appearance of favoritism due to private interests is to be avoided.
It is not permitted to make use of one's professional rank or role in order to obtain private advantages,
for example sales discounts. The management may grant exceptions.

8. CREATING AND MAINTAINING SAFE AND FAIR WORKING CONDITIONS

L’azurde accepts responsibility for its employees and attempts to create and maintain an attractive work
environment for its employees.
L’azurde seeks to provide fair wages and reasonable hours of work to its employees in each country,
and rejects all forms of forced labor and child labor.
Occupational safety is a high priority at L’azurde.
L’azurde expects that its employees, in particular its executives, will ensure compliance with the
applicable statutory provisions for occupational safety in each case and that they will commit themselves
to implementing a comprehensive occupational safety.

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9. PREVENTION OF DISCRIMINATION

L’azurde expects its employees to respect different life outlooks, religions and cultural or country-specific
characteristics when dealing with other employees of the L’azurde group, with applicants for
employment, and with business partners.
L’azurde guarantees to its employees a working environment in which discrimination and sexual
harassment are not tolerated.
Similarly political activities are not tolerated within the working environment, neither by L’azurde
employees, nor by third parties.
The selection of applicants and business partners is exclusively based on objective and comprehensible
criteria.

10. ENVIRONMENTAL SAFETY

Environmental safety has a high priority at L’azurde. L’azurde considers itself obliged to deal respectfully
with the resources of nature. Compliance with applicable statutory provisions for the protection of the
environment is therefore self-evident. Beyond that it is L’azurde' constant endeavor to reduce the
quantity of polluting materials and to increase the efficiency of the environmental protection installations.

L’azurde expects the same compliance with applicable statutory provisions from its business partners.
The choice of its business partners is therefore particularly based on these criteria.

11. PROTECTION OF COMPANY ASSETS

The commercial success of L’azurde is based on the innovative ability of its employees and the
knowledge acquired over many decades. As a result, all employees of the company are required to
ensure that operational and trade secrets of the L’azurde group, as well as those of its business
partners, do not become known outside of the L’azurde group. It is neither acceptable to disclose
operational or trade secrets of the L’azurde group without permission, nor to use them for one's own
purposes without permission.
L’azurde expects its employees to treat the assets of the L’azurde group responsibly, and to make
business decisions on the basis of commercially comprehensible risk/benefit analyses. This also
includes the careful verification of the integrity of the business partners of the L’azurde group.
L’azurde places great value on the integrity of its employees. It may be necessary for the Company to
review the financial status and personal integrity of the employee.
All documents of L’azurde, including financial reports, research reports and accounting documents and
invoices in particular, must reflect the relevant facts correctly and transparently.
Employees of L’azurde are not permitted to use business resources for personal purposes, unless such
use is granted to the employees through their employment agreement or their superior allows such use.
In particular it is prohibited for the employees to use L’azurde' IT-systems to view, store or dispatch
pages or messages with legally forbidden contents.

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12. DEALINGS WITH MEDIA

Transparent, dialog-oriented and consistent information for the public - including the media - strengthens
the world-wide image of L’azurde. Official statements at L’azurde, in particular with respect to the media,
may be made for L’azurde only by authorized employees.

13. IMPLEMENTATION AND COMPLIANCE

The validity of the present code of conduct applies to all companies of the L’azurde group. The
implementation and compliance of the code of conduct within the singular companies is responsibility of
the single chief executive officers in loco. He makes sure that his employees are appropriately informed
about the contents and the application of the code of conduct and comply with the present code.
In case of questions regarding content or interpretation of the present code of conduct the employees of
the L’azurde group can contact the chief executive officer of the respective company. The latter may
then again contact the Compliance-Office of the head offices for any inquiries.

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ii. IMPLEMENTATION

1. GENERAL GUIDELINES

 The code of ethics comprises the rules of conduct to be followed by all L’AZURDE employees and
top management daily, in all transactions and in every work location. In a situation with concerns
or doubts about failure to abide by the code of ethics, the Company works on inspiring and
creating the culture of immediate reporting such concerns to proper authorities via several
channels such as line manager, Human Resources, Legal Affairs and Whistleblower Policy for
technical support for handling legal and regulatory violations. The Company focuses on the fact
that it shall not take any penalty or procedures or legal consequence against any person for
reporting his concerns or doubts about any legal or regulatory violations.
 L’azurde code of conduct is the roadmap for our daily business interactions and it reflects the way
we act in achieving our business objectives in a way that promote ethics and professional
behavior standards.
 L’azurde code of conduct applies to all employees including all job categories
 We expect that all employees act, at all times, in the company’s best interest, protect its assets,
and serve the clients, whether internal or external, with the highest level of respect and ethical
standards
 All managers must lead by example and act as role model for their team.

2. COMPLIENCE WITH LAWS, RULES AND REGULATION

 We respect the law at all times. L’AZURDE and its employees are bound by the law. Compliance
with all applicable laws and regulations must never be compromised. Additionally, employees
shall adhere to internal rules and regulations as they apply in a given situation. Those internal
rules are specific to the Company and may go beyond what is required by the law.
 We respect and follow the CMA Trading Rules when buying or selling L’AZURDE securities.
L’AZURDE prohibits the purchase and sale of L’AZURDE shares or securities on the basis of
potentially share price relevant information which is not yet public. Non-compliance may not only
entail disciplinary sanctions, but also result in criminal charges. When in doubt regarding the
interpretation or applicability of L’AZURDE trading rules, employees shall consult with the Legal
or Compliance Function.

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3. COMMERCIAL CONDUCT

 We take pride in L’AZURDE reputation and consider L’AZURDE best interests also in our outside
engagements and activities.
 Business and professional ethical principles should apply to all aspects of business conduct and
should be applied to all stakeholders in all business relationships. Stakeholders include
customers, suppliers, service providers, etc.
 Employees are expected to act in a professional way to gain customer’s trust and loyalty.
 Selection of service providers should pass through a systematic process according to the type of
service in order to ensure impartial selection.

4. CONFLICT OF INTEREST

Employees
 A Conflict of Interest occurs when personal interests of an employee or the interests of a third
party compete with the interests of L’AZURDE. In such a situation, it can be difficult for the
employee to act fully in the best interests of L’AZURDE. Employees shall avoid Conflicts of
Interest whenever possible.
 If a Conflict of Interest situation has occurred or if an employee faces a situation that may involve
or lead to a Conflict of Interest, the employee shall disclose it to his or her Line Manager and or
the HR or the Legal or Internal Audit and Compliance Function to resolve the situation in a fair
and transparent manner.
 It is expected that the employee's time and attention will be completely dedicated and devoted to
the business as specified by the employment contract between L’AZURDE and the employee and
that employees should manage their private affairs in a manner that prevents any conflicts of
interest from arising.
 Employees shall neither compete with the company, nor shall they take personal advantage of
business opportunities that they discover during the course of their employment, unless the
Company expressly waives its interest in pursuing such opportunity.
 Participation of the employee in any other activity that might compromise his/her employment
relationship with L’AZURDE will be considered conflict of interest.
 Conflicts of interest include situations:
1. Where an employee’s private affairs or financial interests are in conflict with his/her
duties, responsibilities and obligations or result in a public perception that a conflict
exists;Which could impair the employee’s ability to act in L’AZURDE’s interest; or
2. Where an employee’s actions would compromise or undermine the trust which the
public places in L’AZURDE.

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Board of Directors Conflict of Interest Policy

Members of the Board must discharge their duties in good faith, recognizing at all times their fiduciary
duty to L’azurde. Directors are required to avoid conflict of interest and may not benefit at the expense of
the company. In accordance with Article 18 of the Corporate Governance Regulations:

i. A Board member shall not, without a prior authorization from the General Assembly, to be
renewed each year, have any interest (whether directly or indirectly) in the company’s business
and contracts. The activities to be performed through general bidding shall constitute an exception
where a Board member is the best bidder. A Board member shall notify the Board of Directors of
any personal interest he/she may have in the business and contracts that are completed for the
company’s account. Such notification shall be entered in the minutes of the meeting. A Board
member who is an interested party shall not be entitled to vote on the resolution to be adopted in
this regard neither in the General Assembly nor in the Board of Directors. The Chairman of the
Board of Directors shall notify the General Assembly, when convened, of the activities and
contracts in respect of which a Board member may have a personal interest and shall attach to
such notification a special report prepared by the company’s external statutory auditor.
ii. A Board member shall not, without a prior authorization of the General Assembly, to be renewed
annually, participate in any activity which may likely compete with the activities of the company, or
trade in any branch of the activities carried out by the company.
iii. The company shall not grant cash loan whatsoever to any of its Board members or render
guarantee in respect of any loan entered into by a Board member with third parties, including
banks and other fiduciary companies.

Members of the Board shall not disclose any confidential or proprietary information relating to
the Company. Such confidential information includes but is not limited to the following:

i. All non-public information entrusted to or obtained by a director by reason of his position in the
Company. It includes, but is not limited to, non-public information that might be useful to
competitors or harmful to the Company or its customers if disclosed, such as:
ii. Non-public information about the Company's financial condition, prospects or plans, its marketing
and sales programs and research and development information, as well as information relating to
mergers and acquisitions, stock repurchases and divestitures;
iii. Non-public information concerning possible transactions with other companies or information about
the Company's customers, suppliers or joint venture partners that the Company is under an
obligation to maintain as confidential; and
iv. Non-public information about discussions and deliberations relating to business issues and decisions
between and among employees, officers and directors.

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5. CONFIDENTIALITY

 We value and protect our confidential information and we respect the confidential information of
others.
 Confidential information consists of any information that is not or not yet public information. It
includes trade secrets, business, marketing and service plans, consumer insights, engineering
and manufacturing ideas, product recipes, designs, databases, records, salary information and
any non-published financial or other data.
 L’AZURDE continued success depends on the use of its confidential information and its
nondisclosure to third parties. Unless required by law or authorized by their management,
employees shall not disclose confidential information or allow such disclosure. This obligation
continues beyond the termination of employment. Furthermore, employees must use best efforts
to avoid unintentional disclosure by applying special care when storing or transmitting confidential
information.
 All L’AZURDE employees are required to protect the confidentiality of any information or data
regarding L’AZURDE operations unless authorized by the appropriate authorities within
L’AZURDE.
 Know how, strategic business plans, financial information, models designs and production lines
related information, technical specifications and all intellectual property must also be kept
confidential and cannot be discussed outside the Company premises.
 All L’AZURDE employees are required to retain all forms of L’AZURDE documentation (e.g.
documents, vouchers, memoranda, etc…) within the premises of L’AZURDE in a considerably
safe area from unauthorized access.
 L’AZURDE employees are not allowed to transport any form of L’AZURDE documents outside the
premises unless specified for business purposes and authorized by their immediate
supervisors/managers.
 Editing of issued and circularized documents by L’AZURDE personnel is to be prohibited unless
the immediate supervisor assumes responsibility and initiates and authorizes such changes.
 Where an employee has reason to believe that there exists an alleged contravention of the
L’AZURDE’s laws or a waste of L’AZURDE’s funds or assets, the employee should bring the
matter to the attention of the supervisor/department head.
 Your obligation to protect L’azurde planning, designs and production secrets and other
confidential information continues even if you leave the company.

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6. OUTSIDE REMUNERATION

 All L’AZURDE personnel are completely prohibited from being employed by other companies,
authorities or institutions.
 Employees who breach this policy are subject to immediate termination under L’AZURDE
Disciplinary Actions (Refer to Disciplinary Action Policy).

7. GIFTS AND OTHER COMPLIMENTARY ITEMS

 Bribery is any act of offering or accepting payments or gifts that would influence the business in
an improper way or results in a favorable treatment.
 All L’AZURDE employees are required to refrain under any circumstances from soliciting or
accepting valuable gifts, kickbacks, bribes, and the like from clients, vendors, or official
authorities, other than gifts of promotional items that have no significant value and that are
routinely distributed, the normal exchange of hospitality, etc…
 Any breach of this policy will be treated as a form of fraud and the employee will be subject to a
disciplinary action up to termination.

8. MEDIA COVERAGE

 Carrying out an interview of any nature with any media channel (radio, television, newspapers,
etc…) is strictly prohibited for any staff members
 Only authorized parties will be entitled for this specific purpose. The CEO will determine
Managers authorized to handle these matters.

9. DRESS CODE

 Employees have to follow a dress code that conveys the professional image of L’AZURDE and
reflects the decency and preventability of the employees.
 Employees are requested to dress formal business attire.
 Hair should be clean combed and neatly trimmed or arranged.
 Employees should not exaggerate use of makeup, perfume or accessories/Jewelry.
 Thursdays are considered dress-down days where a more casual approach can be taken, taking
into consideration that the following attires are unacceptable:

1. Ripped Jeans 2. Flip flops 3. Shorts

4. Slippers 5. Sweat pants

10. COMPANY RESOURCES

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 We insist on honesty and we respect the Company’s assets and property. Corporate resources
both tangible and intangible include :
- Tangible Assets: Machinery, facilities, supplies, equipment, spare parts, raw ingredients,
finished products, vehicles
- Intangible Assets: company Know how, confidential information, intellectual
property and information systems.

 Employees must never engage in fraudulent or any other dishonest conduct involving the property
or assets or the financial reporting and accounting of L’AZURDE or any third party. This may not
only entail disciplinary sanctions but also result in criminal charges.
 We expect from all L’azurde employees to use company resources only for business purposes
and protect them from theft, loss, damage, or misuse.
 PCs and peripheral equipment (printers, screens) should be shut down and de-plugged before
their dedicated user leaves the office at night and/or on weekends.
 Conducting private correspondence on the Company’s letterhead is strictly prohibited.
 The use of the Company’s courier service provider for outgoing private correspondence is strictly
prohibited.
 Loss or theft of company’s laptops (due to careless behavior) may lead to disciplinary actions to
the employee, outlined in Disciplinary Actions Policy.
 All company fixed assets leaving the official premises must obtain an exit permit from the
concerned manager/ and must be registered at the security desk.
 The Company reserves the right to monitor and inspect how its assets are used by employees.

11. TELEPHONE USE

 Our Company Telephones are only used for legitimate business purposes
 We do not encourage the use of company’s telephone for personal uses. However, it’s willing
to tolerate those calls if done for emergencies and those should be always kept brief.
Excessive use of company telephone is strictly prohibited.

12. INTERNET USE

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 Employees have to only use the company’s official e-mail for all business correspondence.
 The Internet facility is intended to support the organization’s business requirements. Any use of
the internet for non-business related issues is prohibited.
 L’AZURDE reserves every right to monitor, examine, and block any incoming or outgoing
Internet connections on the company’s network.
 Downloading media files, games, videos, etc… is strictly prohibited. Downloading software has
to be done through the IT department after a written approval from the direct supervisor.
 Unauthorized users will be given a guest username and password in case there’s a business
need for that.

13. HARASSMENTS

 L’AZURDE does not, under any circumstances, tolerate harassment and is strictly committed to
encourage and maintain good employee relations within a working environment which fosters
team work and encourages employees to give of their best.
 Harassment may be an isolated occurrence or repetitive: it may occur against one or more
individuals. Harassment may be, but is not limited to:
o Physical contact – ranging from touching to serious assault, gestures, intimidation,
aggressive behavior.
o Verbal – unwelcome remarks, suggestions and propositions, malicious gossip, jokes and
banter, offensive language.
o Non-verbal – offensive literature or pictures, graffiti and computer imagery, isolation or non-
co-operation and exclusion or isolation from social activities.
 Harassment of any kind, physical, verbal or non-Verbal is prohibited by company policy and the
Egyptian labor law.
 The Human Resources and Legal departments will investigate any allegations of harassment,
regardless of whether the matter has been raised formally or informally.
 The company will take appropriate disciplinary action outlined in the respective policy as per the
Egyptian Labor law.

14. EQUAL OPPORTUNITIES

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 Our hiring and people development decisions will be fair and objective.
 Immediate family members and partners of employees may be hired as employees or
consultants only if the appointment is based on qualifications, performance, skills and
experience and provided that there is no direct or indirect reporting relationship between the
employee and his or her relative or partner.
 L’AZURDE is committed to provide equal opportunities in employment, with all job applicants
giving them equal treatment in all aspects of their employment, regardless of age, race, color,
nationality, religion, disability, and gender, marital or family status.
 L’AZURDE ensures that all employees enjoy a workplace that is free from discrimination,
harassment and victimization, which the company considers unlawful and unacceptable
behavior, and will not be tolerated under any circumstances.

15. COMMUNICATION

 All L’AZURDE employees are expected to properly communicate with any external parties in a
way that reflects the professional image of the company.
 All employees should comply with the business communication and disclosure standards
and only make public disclosures if they are authorized to.
 Confidential data and information should be sent through extremely safe means of
communication.
 E-mails are considered a formal means of communication and Disciplinary actions will be
imposed on any employee for any kind of E-mail violations, such as, but not limited to:
o Sending or forwarding E-mails with any offensive or racist or remarks
o Forwarding confidential information without any permission

16. WORKING ENVIRONMENT

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16.1 SMOKING

 L’AZURDE intends to promote a healthier environment and protect the health of the non-
smoking employees.
 Smoking is not permitted at any time inside the premises (offices, cafeterias, work spaces,
meeting rooms, hallways, restrooms) or the stores. Employees should only smoke in the
designated smoking area or outside the building premises / stores.
 Violating the guidelines of this policy will hold the employee accountable to disciplinary
actions as per L’AZURDE’S disciplinary actions policy.

16.2 DESK POLICIES

16.2.1 TIDINESS

 For aesthetic, security, and hygiene reasons, offices must remain clean, and as clutter-free
as possible and employees should make use of available storage space to keep paperwork
and other occasionally used items off his/her desk.
 Offices, common areas, and meeting rooms must be left in a clean and tidy condition after
use (i.e. chairs returned, cups, paper and other materials removed, whiteboards cleaned,
electricity and air conditions turned off, etc…).
 Employees should never block walkways between offices and common areas with items such
as: Furniture, boxes or files.

16.2.2 DESK PERSONALIZATION

 Employees may place a limited number of pictures, plaques, calendars, notes, certificates,
etc., within their offices.
 Employees should not post or hang pictures, articles, and other items of a religious, political,
sexual or personally offensive nature or that are commercially or aesthetically inappropriate.

16.2.3 NOISE

 Employees are expected to keep their voice reasonably low, with all conversations within
L’azurde premises. Any other activity causing noise in open spaces should be kept to
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the minimum level. Where noise levels are hard to control, conversations must take place in
hard-wall areas (e.g. break areas, conference rooms, etc…).
 Listening to music while working is permitted provided it does not interfere with productivity
and efficiency at work and that a headset is always used. Employees should avoid raising the
volume level of the headphones beyond the limit that would allow them to interact with their
colleagues, or to hear their desk phones ringing tone.
 Mobile phone ringer should be silent and only Vibrate Mode should be used so as not to
disturb other employees. Mobile phones should not be left in a workstation without first
turning them off or setting them to vibrate to avoid distractions which might disturb or cause
discomfort to their colleagues, the same applies when attending meetings whether inside or
outside the office. Meeting rooms or headsets should be used for all conference calls so as
not to disturb other employees.
 When employees are at their offices, desk phones should be answered promptly. When
employees are out of the office for an extended period, the volume on their desk phone
should be set to silent mode.
 Computer volumes should be set to the off position or to a low level, so as not to disturb or
cause discomfort to your colleagues.

17. UNACCEPTED BEHAVIOUR

 Fraud
 Discrimination or harassment
 Intimidating or threatening behavior
 Improper use of company resources
 Working under the influence of alcohol, illegal drugs on or off L’azurde plants or branches.
 Falsification of time keeping records.
 Fighting or threatening violence in the workplace.
 Any disrespectful conduct.
 Smoking in the nonsmoking areas
 Theft or inappropriate removal or possession of company assets, resources or property.
 Violation of personnel policies.
 Rumor monger and gossip.
 Spreading of religious / political beliefs.
 Unsatisfactory performance or conduct.

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December 2016 HR & Administration Department
 Business Code of Conduct Policy

18. SPEAK UP AND REPORTING VIOLATION

 We take responsibility for ensuring that we all act with integrity in all situations.
 Employees shall report any practices or actions believed to be inappropriate under this Code
or even illegal to their Line Managers or the appropriate members of the HR or the Legal or
Internal Audit and Compliance function. If it is appropriate, in view of the nature of the
reported matter, reports of violations may be made directly to higher levels including the
Group’s Chief Executive Officer and/or Chief Compliance Officer.
 We expect from all employees to follow L’azurde code of conduct. In case you observe any
incident or behavior that concerns you, or represent a violation of the code, you have to
report violation immediately to the Human Resources Department.

 You have several options to contact the Human Resources Department and top
management:
- To contact direct the Group HR & Admin or the Personnel and Administration Manager by phone or
by e-mail
- To send your concerns to the following mail: ceo@lazurde.com (The CEO); and / or
osama.soltan@lazurde.com (The Head of Internal Audit) and / or audit.comittee@lazurde.com (The
Audit Committee). The audit committee email address is accessed only by the audit committee,
which reports directly to the board of the company.

 We’ll treat your concerns with high confidentiality and we’ll investigate on reported violations
and ensure taking all necessary measurements

19. POLICY NON-COMPLIANCE

 We will consult the Code, comply with its provisions and seek guidance where needed.
 It is each employee’s responsibility to ensure full compliance with all provisions of this Code
and to seek guidance where necessary from their Line Manager, or from the HR or the Legal
or Compliance Function. To “do the right thing” and to ensure the highest standards of
integrity is each employee’s personal responsibility that cannot be delegated.
 We are expected to follow the Code and comply with its terms and conditions, in case of any
violation this may result in Disciplinary actions according to the severity of the case, as stated
in the Disciplinary Actions Policy including employment termination

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December 2016 HR & Administration Department