Code of Conduct

OBJECTIVE

1.To ensure that Chiniot Group of Companies (the Company) conducts its operations with the highest ethical standards, adhering to all statutory regulations and universally accepted principles of good corporate governance. The Company’s core values include Merit, Integrity, Teamwork, Safety, Dedication, and Innovation. This Code of Conduct (the Code) is established to foster these values within the corporate culture of the Company.

APPLICATION

2.This Code applies to all Directors and Employees of Chiniot Group of Companies and its subsidiaries, in compliance with corporate governance best practices.

IMPLEMENTATION

3.The Code includes the following provisions:

USE OF COMPANY ASSETS / RECORD KEEPING

3.1 Directors and employees shall protect the Company’s assets and ensure their legitimate use for business purposes only. The use of Company funds for political contributions to any organization or candidate is strictly prohibited.
3.2 The Company must maintain accurate financial records in compliance with Generally Accepted Accounting Principles (GAAP) and relevant laws.
3.3 Any significant deviations from GAAP, including off-balance-sheet transactions, must be disclosed to the Audit Committee, Board of Directors, and statutory auditors.

LEGAL COMPLIANCE & CONFLICT OF INTEREST

3.4 Directors and employees must adhere to all laws and corporate governance standards, avoiding conflicts of interest. Any actual or potential conflicts must be reported in writing to the Company.
3.5 Directors and employees must avoid any financial interest in competitors, suppliers, consultants, or customers that may compromise their loyalty to the Company.
3.6 The Company upholds transparency in contracts and business dealings, engaging only with reputable third parties based on commercial and arm’s-length transactions.

ANTI-CORRUPTION & ETHICAL BUSINESS PRACTICES

3.7 The Company rejects corruption in all forms and prohibits bribery, kickbacks, and unethical business practices. Employees shall not accept favors or preferential treatment that could influence business decisions.
3.8 Employees may accept reasonable business entertainment if it serves a legitimate business purpose and does not create a conflict of interest.
3.9 Employees may offer or accept customary tips or hospitality that promote goodwill, provided they do not influence business dealings.

CONFIDENTIALITY & DATA PRIVACY

3.10 The Company respects data privacy and confidentiality, ensuring that sensitive Company and customer information is protected.
3.11 Employees shall not exploit Company information or resources for personal gain.

GENERAL PRINCIPLES

3.12 The Company is an equal opportunity employer, ensuring a workplace free from discrimination based on gender, race, religion, or creed.
3.13 Employees must report any violations of this Code to the designated authorities within the Company.

RESPONSIBILITY FOR ENFORCEMENT & INTERPRETATION

4.1 All Directors and Employees are responsible for enforcing and complying with this Code. Questions regarding the Code should be directed to immediate supervisors or the Human Resources and Compliance Department.
4.2 Violations of the Code will be investigated thoroughly, and employees must cooperate in any inquiry.
4.3 The Company ensures confidentiality in reporting violations and protects whistleblowers from retaliation.
4.4 Retaliation against employees who report violations in good faith is strictly prohibited and will result in disciplinary action, including termination.

This Code reflects the Company’s commitment to ethical business practices across its sectors, including Industrial & Commercial Explosives, Chemicals, Mining & Blasting, Logistics, Real Estate, and IT.