Code of Conducts
Prepared for:
Gulf Cement Company
Date: 05.02.2026
Version: 1.0
1. Introduction
1.1 Sustainability, Integrity and correct Corporate Governance are key components of our ethical culture and guide our conduct towards customers, suppliers, employees, shareholders and stakeholders in general.
1.2 Gulf Cement Company PSC (“GCC”) considers ethics to be an essential part of business management and full compliance with laws is an asset that adds value to the company. Both our strategic and operational decisions are performed according to the ethical values that guide our conduct and applicable standards.
1.3 For this reason this Code of Conduct (hereinafter, the “Code”) was prepared, with the aim of defining integrity and fairness standards that GCC has voluntarily chosen to implement, as a commitment towards its stakeholders.
1.4 The Code applies to GCC and its subsidiary companies in the United Arab Emirates (“UAE”).
1.5 In the event of a discrepancy between the principles of the Code and the local laws or regulations of the UAE, the strictest rules always apply.
1.6 Additional rules may be adopted by each subsidiary, or group of subsidiaries, in order to address the specific needs of their organisations. In no case shall any additional rule contravene or lower the standards set by this Code. In the case of conflict, the norms herein shall prevail.
1.7 The principles contained in the Code apply to all directors, members of corporate bodies, employees, suppliers and any person acting in the name and/or on behalf of GCC including but not limited to representatives, agents, partners, external consultants, entities appointed by the company, etc.
1.8 All addressees must follow the guidelines set by the Code when facing and overcoming the ethical and legal challenges that they may encounter in their day-to-day work.
1.9 The Code is part of GCC’s overall Corporate Governance system, which manages the firm’s bodies, principles and processes to ensure that the company is efficiently managed to the highest corporate standards.
1.10 GCC encourages its stakeholders to adopt principles and policies consistent with the present Code.
2. Vision and Values
2.1 Our dedicated management has a long-term view of the business and commitment towards sustainable development, supported by high quality production facilities.
2.2 We pursue value creation through lasting, experienced know-how and operating efficiency of our industrial operations.
2.3 For over four decades we have been producing, with great passion, essential materials for the prosperity of communities. These materials allow the building of crucial infrastructure such as roads, bridges, tunnels, airports, dams, and of course, residential and industrial buildings.
2.4 Our day-to-day activities are governed by the following inseparable, interlocking and overlapping values:
Reliability and Soundness
We keep our promises. We respect our stakeholders. For over 100 years, we have been grounding our actions in experience, pragmatism, and competence, while looking to the future with a long-term vision.
Caring for our People
Our people are the cornerstone of our organization. We support them with attention and care and provide merit-based equal opportunities for personal and professional development.
Respect and Openness
We build a welcoming working environment and encourage people to express ideas without prejudice or restraint.
Continuous Evolution
We strive for excellence, develop technological innovation with passion, and aim to achieve lasting and sustainable economic, environmental and social performance.
Safety
Our commitment: Zero Accidents. We promote a work safety culture through concrete and proactive actions.
3. General Principles of Behaviour
3.1 Business Integrity
GCC undertakes to perform its activities in compliance with all laws and regulations in force in the UAE.
All persons subject to this Code must respect applicable laws and carry out their duties with loyalty and professionalism.
3.2 Fair Competition
GCC supports free enterprise and seeks to compete fairly and ethically within the framework of applicable competition laws.
All persons subject to this Code shall comply with applicable competition laws and shall not enter into agreements that may be considered anti-competitive.
3.3 Market Abuse
GCC ensures adequate management and protection of insider information.
Persons aware of insider information must keep it confidential and manage it according to internal procedures.
False information or fraudulent transactions that impact GCC securities are strictly prohibited.
3.4 Money Laundering
GCC takes all reasonable steps to prevent money laundering and financing of criminal activities such as terrorism.
GCC conducts business only with reputable entities involved in legitimate activities and whose funds come from legitimate sources.
3.5 Conflict of Interests
Employees may participate in activities outside their jobs provided they do not conflict with their responsibilities at GCC.
Any potential conflicts of interest must be communicated to the Compliance Committee.
Email: ComplianceCommittee@gulfcement.ae
3.6 Anti-Corruption
GCC prohibits any form of corruption.
No person subject to this Code may give, offer, request or accept money or anything of value to obtain an unfair advantage.
3.7 Gifts, Presents and Entertainment Expenses
Employees must not offer or accept gifts that may influence independent judgment.
Customary modest gifts and reasonable entertainment expenses may be allowed if compliant with UAE laws and company regulations.
3.8 Transparency and Accuracy of Information
GCC is committed to transparency and accuracy in financial statements, reports and communications.
All operations must be properly recorded and supported by documentation.
3.9 Confidential Information
Strategic, financial, technical or commercial information not in the public domain must be protected.
All persons subject to the Code must maintain strict confidentiality.
3.10 Privacy and Personal Data
GCC protects personal information and avoids unauthorized use.
Employees process only the personal data necessary for business activities.
3.11 Company Assets
Company resources must be used responsibly and protected against damage, loss or unauthorized use.
3.12 Intellectual Property
GCC invests in research and innovation.
Employees must safeguard company intellectual property and respect the intellectual property of others.
3.13 Corporate Image
All persons subject to this Code must act responsibly to protect GCC’s reputation and corporate image.
3.14 Respect for Human Rights
GCC respects dignity and equality and does not tolerate discrimination or harassment.
The company protects employees’ physical and moral integrity and promotes safe working environments.
GCC condemns exploitation of labour and promotes employee rights and freedoms.
3.15 Caring for Our People
GCC recognises that success depends on the commitment of employees.
The company supports professional development and equal opportunities based on merit.
3.16 Environment
GCC operates in full compliance with UAE environmental laws and regulations.
The company promotes technologies and processes that reduce energy consumption, emissions and environmental impact.
3.17 Health and Safety
GCC aims to achieve the highest safety standards and prevent injuries and occupational diseases.
All employees must comply with safety policies and use appropriate personal protective equipment.
4. External Relations
4.1 Community Relations
GCC builds trusted relationships with communities through transparency and long-term collaboration.
4.2 Supplier Relations
Suppliers must follow lawful and ethical practices and be selected based on competitiveness, credibility and stability.
4.3 Customer Relations
GCC collaborates with customers to provide innovative solutions and maintain honest, transparent relationships.
4.4 Government Relations
Relations with public administrations must comply with all laws and the highest ethical standards.
4.5 Shareholder Relations
GCC maintains transparent communication with shareholders and provides accurate information to the market.
4.6 Other Associations
GCC supports community initiatives through charitable and educational activities.
5. Implementation Monitoring of the Code
5.1 This Code was approved by the Board of Directors and distributed to all applicable persons.
5.2 The Compliance Committee ensures that the Code is applied and followed within the company.
Email: ComplianceCommittee@gulfcement.ae
5.3 Compliance with the Code is an essential condition for maintaining relationships with GCC.
5.4 Violations may result in disciplinary measures according to applicable laws and employment contracts.
5.5 Non-compliance by third parties may lead to termination of business relationships.
5.6 GCC provides confidential reporting channels for illegal conduct or violations.
5.7 Reports should be sent to the Compliance Committee.
5.8 GCC protects the anonymity of reporting parties and prohibits retaliation against individuals reporting in good faith.