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Ethics

President's Statement

Since the foundation of the CCC Group over 65 years ago, Honesty, Integrity and Family Values have always been the backbone of our Code of Practice and the basis of our successful operations that led us to where we are today.

Living in this troubled world where human values and simple good principles are no longer the beliefs of many people around us, one must remember that neither short-term benefits nor following others can justify us from deviating from our main principles and beliefs. I want every single one of you to hold on to these three pillars while carrying out the responsibilities that you are entrusted to perform: Honesty, Integrity and Family Values.

Since we issued the first version of the Ethics and Anti-Corruption Program a few years ago, the world around us has changed and, in the spirit of continuous improvement, we have revised our procedures.

The Company’s Revised Ethics and Anti-Corruption Program is your guide for holding on to these Three Pillars in our operations. Your full commitment and compliance to this Ethics and Anti-Corruption Program are required to maintain our sustainability and development in this challenging world.

Samer S. Khoury

President

Ethics and Anti-Corruption Program

Given that we are in the construction business on a global scale and operate in many countries around the world, it is essential for us to have a program in place to define anti-corruption and anti-bribery components of our compliance program. Our approved quality management procedure "Ethics and Anti-Corruption Program QMP-MOA-029" describes the main elements of the corporate anti-bribery and anti-corruption compliance program.

Consolidated Contractors Company CCC is committed to comply with the "FCPA: The US Foreign Corrupt Practices Act 1977", "The Bribery Act: The UK's Bribery Act 2010, which came into effect on 1 July 2011" and "The OECD Convention: The Organization for Economic Cooperation and Development's Convention on Combating Bribery of Foreign Public Officials in International Business Transactions Convention, which came into effect in February 1999" in all business relationships.

CCC employees are forbidden from engaging in any corrupt activity in the performance of their duties and must maintain a complete and clear accounting of books and records.

Ethics and Anti-Corruption International Organizations

CCC is a member of all of the important Ethics and Anti-Corruption International Organizations such as:

Audits

Over and above regular internal audits and self-assessments, we also carry out regular audits by an International Independent Agent who regularly conduct detailed assessments of CCC's areas of operations, ongoing projects and facilities, personnel and records, and investigate noncompliance with management procedures and report on our Ethics and Anti-Corruption Program.

The Compliance Team

A Compliance Team is established in all Areas of Operations including the UAE, Saudi Arabia, Qatar, Palestine, Oman, Lebanon, Kuwait, Jordan, Italy, Iraq, the CIS, North Africa and Africa proper.

The Compliance Team ensures adherence of all Areas of Operations and Projects to the corporate anti-bribery and anti-corruption compliance program.

Training

“Ethics & Anti-Corruption” training courses are part of CCC Technical & Project Management Training program. CCC project management programs are approved by the Project Management Institute (PMI) and, upon completion, attendees earn Professional Development Units (PDUs) as CCC is a registered Global Registered Education Provider (REP) by PMI and an authentic certificate is issued.

CCC's policy is to maximize online EACP training to reach the maximum number of employees in a relatively short period of time and this is due to; (1) the large number of employees (thousands) and (2) to having the employees spread around the world in many different countries and many different sites in any one country.

In 2015 “CCC’s Ethics Compliance Online Training Program” was launched to raise our staff’s EACP awareness in which more than 90% of CCC staff participated and successfully completed the course. CCC developed this program in coordination with an International specialist company in this field. The online course is a 60 minute online training session that provides an overview of the most important aspects of CCC’s Ethics & Anti-Corruption Program (EACP). Staff receive an individual e-mail providing a personalized link that takes the individual to an interactive Online Training Program. Participation is mandatory to all recipients and, upon successfully completing the program, a personalized authentic Certificate of Completion is issued. In early 2018, the online course was given again.

Reporting Violations - Whistleblowing Channels

CCC's employees can and are encouraged to report any violation of our corporate policies, code of conduct or any observed bribery or corrupt activity. Fully confidential and anonymous whistleblowing channels are provided for reporting any suspected breach of our policies, and retaliation for reports of misconduct made in good faith is prohibited.

Ethics