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1. 1
CONTRACTING AND TRADING CO. (C.A.T.)
SAUDI ARABIA
BR. C.A.T. INTERNATIONAL CO. LIMITED

2. Training Agenda
1. PURPOSE OF THE TRAINING
oAwareness of C.A.T. Code of Conduct requirements.
oAwareness of S.A. Supplier Code of Conduct requirements.
oAwareness of Reporting Procedures / Non Compliance Consequences.
2. C.A.T. GROUP CODE OF CONDUCT
oObjective.
oCode of Conduct Summary.
oMonitoring and Compliance/Reporting.
oNon Compliance Consequences.

3. Training Agenda
3. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT
oScope.
oIntent.
oSupplier Code of Conduct Requirements.
oMonitoring and Compliance / Reporting.
oNon-Compliance Consequences.
oConfidentiality and Application.
QUESTIONS AND ANSWERS (Q/A)

4. 1. PURPOSE OF THE TRAINING
Awareness of C.A.T. Code of Conduct requirements:
oC.A.T. Employee.
oC.A.T. Suppliers and Subcontractors.
oRequirements.
oMonitoring and Reporting Procedure/Records.
oNon Compliance Consequences.

5. PURPOSE OF THE TRAINING
Awareness of Saudi Aramco Supplier Code of Conduct Requirements:
oC.A.T. and all Employees.
oRequirements.
oMonitoring and Reporting Procedure.
oCompliance Records.
oNon Compliance Consequences.
oCompany.
oPersonal.

6. C.A.T. GROUP
CODE OF
CONDUCT

7. 2. C.A.T. GROUP CODE OF CONDUCT
Objective
oPromote ethics, honesty and professionalism.
oConfirm compliance with customer’s requirements.
oConfirm commitment to conduct business in ethical, legal, safe,
environmentally and socially responsible manner.

8. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oConflicts of Interest:
 C.A.T. employee main concern to act in the interest of C.A.T. ONLY (no personal
interest)
 NO engagement in any business relationship with competitors
 NO circulation of any information deemed confidential to C.A.T.
 Employee RESPONSIBILITY TO DECLARE any private participation with businesses
outside the scope of C.A.T.

9. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oCompliance with applicable Laws, Codes and Regulations.
oEnvironmental Health and Safety requirements.
oEthical business practices:
 Fair Trade Practices.
 Ethical Sourcing.
 Relationship and Communications.
 Gifts, Gratuities and Hospitality:
C.A.T. Employee shall not accept any gifts, gratuities, hospitality or anything
perceived to influence the professional relationship.
Acceptable gifts, gratuities or hospitality should not exceed 60 USD once per year.
More should be immediately returned

10. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oEthical business practices:
 Fraud and other Wrong Doings:
The importance and obligation of all C.A.T. employees to understand and comply
with the rules and regulations.
Employees to be aware of the numerous types of fraud and indicators.
Types of fraudulent misconduct: e.g. misrepresentation or concealment of facts.
Not executing one’s responsibilities: loss of and waste of company assets and
resources.

11. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oEthical business practices:
 Payments to Customers and Government Officials.
No employee, or third party, should promise, offer or pay money or provide
anything else of value to a Customer representative or government official in order
to influence any act or decision.
Any gifts or entertainment expenses or any contributions that may be of benefit to a
Customer’s representative or government official are strictly prohibited.
No funds, assets, services, gifts or excessive hospitality shall be offered /accepted by
C.A.T. employee.

12. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oEthical business practices:
 Record Management.
All data entered into C.A.T. System by C.A.T. employee shall be true and accurate.
All Communications with third parties via emails and official letters shall be
accurately and truthfully systemized.

13. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oEthical business practices:
 Confidentiality of information.
Under no circumstances should any C.A.T., Customer or any other stakeholder
information be shared with any other external party unless deemed required by
court of relevant jurisdiction.
Such information is shared internally on a need-to-know basis only.
Prior written Customer’s or Stakeholder’s permission is required when disclosing
information.

14. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oAnti-Money Laundering Policy.
oWhistleblowing and Whistleblower Protection.
 Whistleblowing is the act of reporting any form or misconduct commonly in
reference to any breach of legal requirement or engaging in immoral behavior.
 Examples of Acts:
Breach of a legal requirement - e.g. health and safety obligations owed by C.A.T.
General malpractice - such as immoral, illegal or unethical conduct.
Breach of audit (or other applicable) regulations.
Breach of the codes of conduct of C.A.T, C.A.T. Customer and other relevant
institutions.

15. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oWhistleblowing and Whistleblower Protection.
 Failure to promptly report a suspected or known violation is considered an
unethical behavior.
 It is an obligation to report and reporting can be anonymously.
 The identity of the whistleblower and the disclosure contents are protected.
 Whistleblowing records shall be documented in an accurate and timely manner
and kept confidential.

16. C.A.T. GROUP CODE OF CONDUCT
Code of Conduct Summary
oAnti- retaliation Prohibitions.
 No one in C.A.T Group and irrespective of the hierarchy is allowed to commit an
act of retaliation against any employee or any stakeholder for complying with
this Code of Conduct.

17. C.A.T. GROUP CODE OF CONDUCT
Monitoring and Compliance/Reporting
oC.A.T., its Suppliers and Subcontractors obligation to comply with C.A.T. and
Customer Codes of Conduct.
oC.A.T. Compliance internal Reviews / Records.
oCompliance Records should be available upon request.
oDetection of suspected or actual Non Compliance instances, Prompt and
Confidential reporting to C.A.T. Customer and Management is a MUST.
oC.A.T. Prompt and Confidential reporting to Customer’s Management
including Corrective and Remedial Actions.
oFor Reporting Procedure, please refer to Clause 3: MONITORING AND
COMPLIANCE of this Code.

18. C.A.T. GROUP CODE OF CONDUCT
Non Compliance Consequences
oEmployee: Disciplinary Action including immediate dismissal and Legal Action
if required.
oSupplier/Subcontractor: shall be considered as a breach of Purchase Order or
Subcontract agreement Terms and Conditions and shall be dealt with
accordingly.

19. SAUDI ARAMCO
SUPPLIER CODE OF
CONDUCT.

20. 3. SAUDI ARAMCO SUPPLIER CODE OF
CONDUCT
Scope
oScope includes C.A.T. Company and all employees on SA Projects.
Intent
oConfirmation of commitment to conduct business in an ethical, legal, safe,
environmentally and socially responsible manner.
oRequirement to SA Suppliers to share and demonstrate this commitment.

21. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT
Supplier Code of Conduct Requirements
oCompliance with laws, codes and regulations as set in agreements.
oEnvironmental, Health and Safety Practices.
 Compliance of facilities with established governmental and industry
environmental protection policies.
 Maintenance of healthy residential camp and living environments for all their
employees (as per page 2 of Code of Conduct).

22. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT
Supplier Code of Conduct Requirements
oEthical Business practices: fair trade and Ethical sourcing.
oRelationship and Communications:
 All transactions to be made fairly, honestly and with integrity to the highest
ethical standards.
 Conflict of interest and improper business practice: for current or former SA
employee to use any confidential or proprietary business, technical or other
information obtained while in the service of SA.
 Hiring, employing or engaging as a consultant a former SA employee needs prior
permission from SA (as per page 3 of Code of Conduct).

23. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT.
Supplier Code of Conduct Requirements
oBribery and fraud: to influence or compromise the judgment or conduct of SA
or its representatives strictly prohibited.
oGifts, Gratuities and Hospitality :
 Nominal value gifts and reasonable hospitality may be offered to SA employees
e.g logo inscribed pens, shirts, coffee mugs, reasonably business entertainment
and meals.
 Excess of nominal value and reasonable hospitality shall be reported to SA.

24. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT.
Monitoring and Compliance / Reporting
oC.A.T. Company and all employees are responsible for complying with this
Code and monitoring its implementation.
oC.A.T. shall carry out internal reviews, inspections and audits to verify and
ensure compliance with the requirements of this Code.
oC.A.T. is responsible to ensure that these code requirements are
communicated and understood by all employees working on SA projects, jobs,
agreements and orders.

25. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT
Monitoring and Compliance / Reporting
oC.A.T. Management and all employees are to promptly and confidentially
disclose, directly to SA General Auditor ,all current or potential incidents
which give rise to conflicts of interest and unethical or fraudulent behavior by
any party including their or SA employees.
oFor SA General Auditor Coordinates, please refer to Code of Conduct page 4
Monitoring and Compliance clause.
oC.A.T. shall maintain records to substantiate compliance with this Code (Audit
reports, reviews, employee feedback, HSE reports, training Attendance
sheets, etc…).
oA Supplier Performance Assessment Report will be issued by SA following
inspections, review of publicly available information, filled questionnaire,
etc…

26. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT
Non Compliance Consequences
oSupplier
 SA Supplier Performance Assessment report shall be used by SA as a factor in the
selection of bidders, the administration of contracts and procurement and to
possibly restrict Supplier access to new SA business opportunities.
 In case of an unsatisfactory SA Supplier Performance Assessment report, SA
reserves the right, in addition to all other legal and contractual rights to
disqualify any potential supplier or terminate any relationship with a current
Supplier which SA has found to be in violation of this Code, without liability.
oEmployee:
 Disciplinary Action shall be applied including immediate dismissal and legal
action if required.

27. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT
Confidentiality and Application
oC.A.T. and all employees, in all instances, shall comply with the obligations of
confidentiality which are set in the applicable requests for proposal, invitation
to bid, other solicitation document or agreement with SA.
oSame Non Compliance Consequences apply for the Supplier and Employee in
case of violation of the confidentiality obligations.
oAdvertising, press release or printed matter that reference SA requires SA
Public Relations Department approval prior to publication or other use.

28. SAUDI ARAMCO SUPPLIER CODE OF CONDUCT
Confidentiality and Application
oThis Code of Conduct is an addition to any Supplier Obligations set in requests
for proposal, invitation to bid, other solicitation document or agreement with
SA.
oIn case of a conflict between this Code and any other SA solicitation
documents and applicable agreements the terms of the latter prevail.
oThe requirements of this Code are not subject to waiver i.e neither SA, its
Suppliers nor their personnel or representatives are authorized to propose or
approve conduct inconsistent with this Code.

29. QUESTIONS AND ANSWERS (Q/A)