We ensure concerns can be reported in a manner that is legitimate, fair, and equitable. This includes employee engagement surveys, ad hoc workers’ committees, a Compliance Hotline and Compliance mailbox, which is a direct line to the Group Compliance team, and a confidential ethics helpline, Takallam, which is run by an independent third party on our behalf. Any concerns received are handled in strict confidence. We strictly prohibit retaliation of any kind against anyone who reports a business ethics concern in good faith or cooperates with an investigation. We have policies and processes in place to resolve issues identified through Takallam or other methods. We are committed to ensuring concerns or grievances are investigated impartially and free from attempts by interested parties to influence the outcomes. Any preventative or remedial measures are based on fairness, equality, and procedural transparency. Operating with integrity We have adopted and implemented corporate compliance policies and procedures and continue to review and update as required for a company of our size and structure, operating in the industries we do. In 2023, the strength of the ADNOC Group Compliance Program was recognized by the award of ISO 37001 (Anti-bribery management systems) and ISO 37301 (Compliance management systems) certification. Our Code of Conduct sets out our commitment to conducting business ethically and responsibly, and guides our employees and contract employees of the company, and its controlled subsidiaries. The Code of Conduct focuses on important topics such as acting with integrity, competition and antitrust, confidentiality, anti-bribery and anti- corruption as well as international trade controls, insider trading, and adherence to applicable laws and regulations. Our Compliance framework also includes the following policies: Ethics and Compliance; Anti-Bribery and Anti-Corruption; Anti-Money Laundering; Conflict of Interests; Gifts and Entertainment; Compliance Investigations; Whistleblowing and Non-retaliation; Competition Compliance; an Inside Information and Insider Dealing Policy; Sanctions and International Trade Controls; and an Integrity Due Diligence Policy and related procedures. Our Supplier and Partner Code of Ethics applies to third parties we do business with, including suppliers, customers and strategic partners. It sets out the basic rules and standards that are necessary to conduct our business in an ethical and compliant manner and in accordance with our values. We work collaboratively with our partners, suppliers, customers, and government entities to elevate the collective fight against corruption, demonstrating how integrity and transparency are integral to how We recognize the integral role that ethics and compliance play in our sustainability journey. Our robust compliance framework ensures adherence to local and international regulations, fostering a culture of responsible conduct across our operations. we operate. Addressing corruption, internally and collectively, aligns with our company values. In addition, all suppliers, customers and other third parties who work with us are subject to anti-bribery and corruption exposure risk assessments, as part of our integrity due diligence process. We work collaboratively with our suppliers, customers, and strategic partners to mitigate and manage any actual or potential adverse integrity, corruption, and environmental, social and governance related impacts, which we identify in our supply chain. ADNOC has a robust process for governing conflicts of interest, which is set out in the Conflict of Interests standard and applies to all our employees. Employees have a duty to report potential conflicts of interest to their line manager and the Group Ethics and Compliance function. Once reported, individualized controls to manage any potential conflict risks are applied, as appropriate. Approximately 380 Takallam matters were raised in 2023. These matters were reviewed internally and, where required, process improvements and identified gaps were shared with the respective functions. In these cases, appropriate actions were taken, including comprehensive follow-ups to ensure the implementation of corrective actions. Training programs and awareness sessions are important to ensure all our employees are aware of the systems in place around ethics and compliance. It is mandatory for all our employees to complete annual training on the ADNOC Group Code of Conduct, anti- bribery and corruption policies and standards, and related Group policies and procedures. 100% of the Group’s in-scope employees completed the training in 2023, supported by a comprehensive and dedicated engagement plan. In addition, we conduct targeted training in competition law and sanctions. We regularly conduct conflicts of interest and speak up/non-retaliation awareness sessions for all employees. We also conduct ‘Compliance Minute’ sessions throughout the year for our business lines. Compliance inductions are conducted for new joiners. 100 101 Energy for Life
