This set of guidelines originates from K&T JV LTD’s corporate policy and has been formulated to establish universal benchmarks for the behavior expected from every K&T JV LTD staff member. While these principles are not new to us and have been ingrained in our collective ethos, this Code of Conduct serves the explicit purpose of formally documenting these essential conduct regulations.

 PICTURE C1

Our approach to business ethics is defined by accountability and the highest ethical principles. These serve as the foundation upon which we bolster our market position and competitive capabilities in a sustainable manner. Additionally, our aspiration is for K&T JV LTD to stand as an organization that instills pride in its employees.

The Code of Conduct serves as a comprehensive outline, articulating the principles and directives for responsible and ethical behavior. Many of the subjects covered in the Code of Conduct are further expounded through employment contracts, standard operating procedures, and internal guidelines. Our aim is to transform the K&T JV LTD Code of Conduct from mere words on paper into a tangible benchmark, diligently practiced by every employee in their day-to-day dealings, regardless of their location or background. We therefore urge you to embody our values.

 We extend our gratitude for your dedication and rely on your continued support.

 Digital Signature  

CEO                                       COO         

Every employee at K&T JV LTD must adhere to the guidelines outlined in the Code of Conduct and should let these principles direct their daily tasks.

Scope and Applicability

This Code of Conduct is relevant to all personnel (including both white-collar and blue-collar employees, as well as contracted labor) affiliated with K&T JV LTD, and extends to individuals representing or working on behalf of the company. K&T JV LTD will strive to inform external parties about the specific sections of this Code of Conduct that pertain to them, emphasizing their anticipated adherence to these provisions while engaging in business interactions with K&T JV LTD

In instances where K&T JV LTD becomes cognizant of a violation of these stipulations by a business partner, the implicated partner will be requested to cease such conduct. K&T JV LTD’s management retains the authority to undertake appropriate actions, such as discontinuing the business relationship or notifying pertinent authorities, if the concerned business partner fails to comply within a reasonable timeframe.

Responsibility of all employees of K&T JV LTD

Embracing Corporate Responsibility involves every individual employee assuming accountability for their own actions. This extends to K&T JV LTD’s workforce understanding and adhering to the legal regulations pertinent to their specific roles, encompassing international, national, and local laws, as well as guidelines like commercial, tax, and competition laws. Additionally, strict adherence to internal policies and directives, including the Code of Conduct, is expected.

The responsibility of disseminating these guidelines and rules to employees lies with K&T JV LTD’s management. It is imperative that all employees promptly report any proven or suspected breaches of law, the Code of Conduct, or other internal regulations (refer to the "Reported Misconduct" section).

K&T JV LT retains the prerogative to take disciplinary measures should an employee fail to comply with laws, the Code of Conduct, or other internal regulations. Employees need to recognize that such transgressions can bear significant consequences for both the company and themselves, thereby holding them accountable.

Compliance isn't solely K&T JV LTD’s obligation; it is equally incumbent upon each individual employee. Ultimately, violations of compliance standards could lead to personal repercussions for employees under both civil and criminal law.

K&T JV LTD maintains a strict stance against any form of workplace insult or harassment. It is imperative that all employees experience just and unbiased treatment.

Core Principles

The equitable and respectful treatment of every employee is a paramount concern at K&T JV LTD. Our commitment lies in fostering an environment of mutual trust, where each individual is treated with honor and courtesy. We hold in high esteem the diversity stemming from varying cultural and personal backgrounds, valuing perspectives from different origins, cultures, languages, and ideas. To circumvent misunderstandings and conflicts, we interact with one another conscientiously and with deference.

At K&T JV LTD, all employees enjoy equal employment prospects. Our human resource decisions are rooted in merit, performance, integrity, qualifications, and similar benchmarks. This principle extends across all aspects of recruitment, training, compensation, and advancement.

Sexual Harassment

Sexual harassment can manifest in diverse ways, including explicit advances, demeaning comments, jests, offensive language, or suggestive gestures. Even if unintended, such behavior can be perceived as harassment.

K&T JV LTD strictly prohibits all forms of sexual harassment. Employees who feel subjected to such harassment have the option to approach the designated authorities at any time (refer to the "Reporting Misconduct" section). Their reports will be diligently and confidentially investigated. Rejection of advances or reporting of harassment will not adversely affect an employee's employment status, performance assessment, or income, unless the report is made with malicious intent. If any form of retaliation or reprisal occurs due to such a report, the relevant authorities must be promptly notified to curtail such inappropriate behavior.

Non-Discrimination

Within K&T JV LTD, human rights are fundamental values upheld by all. Our corporate culture recognizes the uniqueness and worth of each individual, emphasizing respect for their individual skills. Each employee is regarded as a valued team member, and their rights and dignity are upheld.

K&T JV LTD commits to the equitable and unbiased treatment of all prospective and existing employees. Discrimination based on nationality, ethnicity, gender, sexual orientation, culture, religion, age, marital status, social affiliation, health, union membership, political beliefs, or any other grounds is strictly prohibited.

Individuals possessing comparable hard and soft skills must receive equal treatment concerning hiring, terms of employment, compensation, training initiatives, and professional development within the local context. This principle extends to all interactions with external parties, including suppliers, customers, consultants, dealers, and other business associates of K&T JV LTD, even competitors.

We place the highest priority on maintaining safe and healthy working conditions. Every individual is responsible for the prudent and efficient utilization of our resources.

Working Conditions

K&T JV LTD steadfastly upholds working conditions in alignment with international laws and regulations, and we expect the same standard from our business partners.

Child and forced labor are categorically prohibited at all our facilities, and we actively seek to encourage our partners and suppliers to adopt similar principles.

Across all K&T JV LTD facilities, we ensure equitable and just compensation levels. We acknowledge our employees' right to engage in collective bargaining agreements as permitted by the laws and customs of their respective operating countries.

Alcohol and Substance Use

Alcohol and substances can significantly impair employees' cognitive abilities and their capacity to perform duties efficiently and effectively. Such substances not only hinder productivity but also jeopardize the safety of K&T JV LTD’s employees and their work environment.

Henceforth, the consumption of narcotics, alcohol, and other intoxicating substances during work hours is strictly prohibited for all K&T JV LTD employees, except for medical drugs prescribed by a licensed physician.

Environmental Conservation and Social Responsibility

Responsible environmental stewardship is of paramount importance to us. K&T JV LTD is fully committed to the intelligent and sustainable management of resources, energy, and waste. In pursuit of this goal, comprehensive environmental, health, and safety guidelines have been formulated. These guidelines either meet or exceed international and national legal requirements.

 Each employee is obligated to adhere to these guidelines, both for their personal safety and the protection of the environment. Sustainability is deeply ingrained in our corporate culture, embraced by every employee.

 K&T JV LTD’s dedication to society is an integral facet of our philosophy. We voluntarily engage in numerous projects for the betterment of the public, reflecting our responsibility to the larger community.

Core Principles

All personnel within K&T JV LTD bear the responsibility of safeguarding corporate resources and utilizing the available assets appropriately. Corporate resources encompass all operational elements (including but not limited to information) owned by K&T JV LTD constituting vital components of the company's pursued business activities. Each employee is thus accountable for preventing resource harm or loss, theft, IT security vulnerabilities, unauthorized or fraudulent modifications, unauthorized entry, improper usage, and unauthorized disclosure. Transporting corporate assets off company premises necessitates explicit authorization. Similarly, utilizing corporate resources for personal purposes requires explicit consent.

 Corporate Information

 K&T JV LTD endorses open information exchange and promotes data sharing. Nonetheless, mishandling, misuse, or destruction of corporate information can inflict substantial harm on K&T JV LTD. Hence, maintaining respect for and protecting confidential information takes precedence. Every K&T JV LTD employee is obligated to treat corporate information accessed during their service with meticulous care. The term "corporate information" encompasses all financial records, contracts, correspondence, technical details, etc., belonging to K&T JV LTD, irrespective of the medium employed for processing, transmitting, or storing the information.

 Notably, confidential information can involve:

• Trade secrets and proprietary knowledge,
• Existing or potential patents, copyrights, and trademarks,
• Business concepts, methods, plans, and proposals,
• Production and capacity information,
• Marketing strategies and sales projections,
• Client data,
• Internal pricing lists,
• Business strategies,
• Construction blueprints,
• Supplier particulars,
• Business principles,
• Technology and research and development data,
• Employee details, including recruitment, health, education, and training records,
• Financial data.

 Generally, K&T JV LTD staff are accountable for:

• Ensuring corporate information is managed consistently with pertinent laws and internal policies,
• Using corporate information solely for intended internal purposes and acquiring pre-approval from relevant supervisors for other uses (e.g., publication),
• Abstaining from making false or misleading entries in financial, accounting, technical records, etc.,
• Preventing destruction of corporate information before prescribed retention periods expire or while legal actions or investigations are ongoing.

 Classification of Corporate Information

All non-public information, except that explicitly designated "public," must be treated as internal and confidential. Such information is solely for internal K&T JV LTD use and must not be disclosed to external parties without specific authorization. The originator of corporate information or their superior is tasked with assigning the required level of protection (via labels, stamps, notes, email system's confidentiality criteria, etc.). Information marked as "confidential" mandates particularly cautious handling, prohibiting others' access at the workplace. When confidential corporate information must be shared externally, a confidentiality agreement is mandatory, with approval from the originator and/or owner before the information leaves K&T JV LTD

Email, Intranet, and Internet Usage

 Active utilization of email, internet, and intranet is crucial for swift, efficient communication. However, improper use of external data connections (email, internet) poses substantial risks to K&T JV LTD To mitigate these risks, strict adherence to internal guidelines, rules for email, internet, intranet systems, and social media must be maintained. Vigilance is essential in avoiding downloading, copying, or transmitting unlawful, defamatory, discriminatory, politically biased, or explicit content.

Secrecy

For security, using private IT devices or unofficially acquired IT equipment to process or store corporate data/documents is strictly prohibited. Compliance with data protection laws or relevant statutory regulations in respective countries is obligatory. Unless instructed otherwise by the employer, employees cannot forward entrusted data related to their duties, maintaining data confidentiality during and after employment. Confidentiality In executing their duties, employees access confidential corporate know-how stored within various IT tools and databases, encompassing commercial, organizational, and technical information K&T JV LTD’s intellectual property. Strict confidentiality must be observed, and this information should only be used for official responsibilities. Disclosing corporate know-how to third parties, making it available externally, or misusing it is strictly forbidden and may entail legal repercussions. K&T JV LTD retains the right, in compliance with country-specific laws, to document access to sensitive programs and data for data security purposes. Data

Removal and Safekeeping

Removing corporate data on data carriers (CDs, memory cards, portable hard drives, etc.) or IT devices (e.g., laptops) from company premises, as well as copying data to external networks (e.g., internet), requires supervisor consent. It is imperative for employees to securely manage data carriers and IT devices, and the "IT Usage" standard operating procedure should be noted.

K&T JV LTD anticipates its workforce to uphold the integrity of its own intellectual property rights while also demonstrating respect for the intellectual property held by external entities. The intellectual assets of K&T JV LTD encompass various forms including innovations, scientific or technical research outcomes, product advancements, novel technology creations, in-house software developments, and more. Depending on the context, these intellectual assets are fortified through processes such as registration, application for trade name or patent registration, design protection, and the issuance of either exclusive or non-exclusive licenses.

Every employee within K&T JV LTD is required to proactively shield the company's intellectual assets and counteract any unauthorized transfer of sensitive expertise to rivals or other unsanctioned third parties.

 In particular, employees must ensure that:

• Information pertaining to nascent products is not disseminated prior to the registration of patents or other intellectual property rights, or a conscious decision to relinquish such rights.
• Proprietary data remains confidential and is not exchanged with clients, suppliers, or industry competitors.
• Prior to embarking on discussions with potential collaborative partners, confidentiality agreements are executed.

Beyond safeguarding its own intellectual property, K&T JV LTD maintains a strong commitment to the intellectual property of external entities. Illicit utilization of a third party's intellectual property has the potential to result in significant repercussions for both K&T JV LTD and its workforce, including potential legal entanglements under civil law and financial penalties, among others. Such actions will be strictly prohibited under any circumstances."

The effectiveness of our external communication plays a pivotal role in shaping the reputation of our robust brands and upholding K&T JV LTD’s esteemed image in both international and regional markets. Our capability to communicate coherently, professionally, and ethically with external stakeholders and the media significantly contributes to this positioning.

We maintain a transparent, clear, and goal-oriented approach when communicating with a diverse array of parties, including our valued customers, the wider public, neighbors, and trusted suppliers. This approach facilitates a swift and well-regulated exchange of information, catering to the unique needs of each audience. It is imperative that our employees take pride in serving as the enthusiastic "ambassadors" of K&T JV LTD and its formidable brands, reflecting our shared values.

To ensure precision and accuracy, external third parties are furnished exclusively with information that has undergone explicit authorization for publication. The decision-making authority for communication methods and channels rests with the senior management, and when necessary, the Executive Board. This orchestrated approach guarantees our communication efforts are aligned with our overarching strategic vision.

In essence, our commitment to coherent, professional, and ethically sound external communication is pivotal in influencing how our strong brands are perceived in international and regional markets. The transparency, clarity, and purposeful nature of our interactions resonate throughout the organization, solidifying the reputation of K&T JV LTD and its esteemed offerings.

Customer Communication

At the heart of our interactions with customers lies our dedication as a capable and trustworthy partner, dedicated to fostering lasting business connections. We firmly believe that transparent and sincere engagement with our customers is a fundamental obligation. K&T JV LTD distinguishes itself not only through its offerings but also through an unwavering commitment to treating customers with directness, impartiality, and candor.

Our primary goal is to provide customers with solutions that impeccably align with their expectations. We leverage the strengths of our products and services while ensuring that our sales materials, advertisements, and other communications accurately represent them. This implies that every member of the K&T JV LTD team refrains from purposefully misguiding customers, be it regarding product quality, attributes, or availability.

Supplier Communication

Our interactions with proficient and high-achieving suppliers are oriented towards establishing enduring and trustworthy alliances.

K&T JV LTD is an integral part of a tightly-knit network encompassing business partners and suppliers. The foundation of these business relationships lies in the assurance that both parties' interests are consistently and equitably prioritized, in alignment with the principles of fairness. All procurement determinations are exclusively guided by transparent factors including quality, timelines, cost, service, and dependability, and remain uninfluenced by the personal motivations of individual staff members.

K&T JV LTD communicates its expectations and the benchmarks to be met by suppliers in a candid, equitable, and straightforward manner. The suppliers' capacity to uphold these elevated standards hinges on active collaboration. Whenever this cooperation involves the exchange of confidential information (such as product specifications, production processes, quality considerations, etc.), a confidentiality agreement is obligatory.

Engagement with Public Authorities

Our communication, both internally and externally, embodies values of transparency, integrity, and fairness.

K&T JV LTD engages with public authorities in a forthright, candid, and proactive manner. Our goal is to foster a relationship of trust, professionalism, and honesty with these entities.

As a general protocol, local management and/or duly authorized employees are responsible for liaising with public authorities (for routine queries, adherence to safety regulations, inquiries about ongoing projects, etc.).

Inquiries originating from public authorities that could impact the entirety of K&T JV LTD or pertain to more than one country or region should be escalated to the appropriate management level for evaluation and subsequent actions. During the handling of such inquiries, management collaborates with relevant divisions and, particularly in cases of public interest, seeks guidance from the Corporate Legal & Public Affairs department.

Engaging with public authorities might present challenges based on specific situations. In uncertain situations, it's advisable to seek guidance from your immediate supervisor.

Intra-Organizational Communication

The employees at K&T JV LTD  are obligated to uphold principles of candor, integrity, transparency, and fairness not just in external interactions, but also in their communications within the Group.

Internal communication transpires among various divisions within the Group as well as across individual corporate tiers.

Effectively conveying information in a clear and targeted manner through our information networks forms the cornerstone for swift information exchange, prompt consensus-building, well-informed decision-making, and consistent execution of agreed-upon actions. This foundation proves indispensable when introducing corporate changes and plays a role in fostering employees' sense of affiliation with the company. Sound decision-making and accurate implementation of resolutions can only be achieved by employees who have received ample information.

We anticipate our employees to take the initiative in sharing pertinent and valuable information with their colleagues.

Fundamental Tenets

Corruption involves the improper utilization of entrusted authority. This encompasses bribery, bestowal of advantages, receipt of benefits, unauthorized interferences, and other manifestations of corruption, which can inflict widespread harm across legal, economic, and political spheres. Consequently, K&T JV LTD firmly stands against all manifestations of corruption.

The following guidelines are pertinent to scenarios that may emerge during transactions or situations involving K&T JV LTD employees or external third parties acting on behalf of the company.

Bribery

Bribery represents a manifestation of corruption. Within the context of this Code of Conduct, K&T JV LTD defines bribery as any act involving the offer, promise, grant, request, or acceptance of financial or non-financial advantages, directed towards:

Public officials, civil servants, or other individuals employed within public authorities,

Politicians, political parties, and/or their representatives, or Other external third parties,

with the intent of facilitating or securing business transactions or gaining illicit advantages in business dealings. K&T JV LTDC explicitly prohibits any involvement of its employees in bribery, irrespective of the nature or worth of the offered inducements (monetary, non-monetary benefits, etc.). Employees found contravening this prohibition may be subjected to severe disciplinary actions and/or legal measures, including civil and criminal proceedings.

Should an employee of K&T JV LTD confront a bribery attempt or suspect an external third party of attempting to exert undue influence, it is mandatory to promptly inform their immediate supervisor.

Gifts and Hospitality

K&T JV LTD strictly prohibits the presentation or acceptance of gifts, hospitality, or other favors when such actions constitute an inappropriate and unethical attempt to influence business transactions or might give rise to the perception of improper influence.

As part of K&T JV LTD’s commitment to nurturing positive relationships with its business associates, employees may occasionally engage in the exchange of gifts or hospitality of modest value (such as invitations to business meals or customary promotional items like pens, calendars, etc.). This is permissible as long as the intent is not to exert undue influence on business decisions and such actions do not create such an impression.

However, the offering or receipt of cash or cash-equivalent items (like checks, bank transfers, etc.) is strictly prohibited, regardless of the monetary value involved.

The fundamental principles outlined in this section also extend to the initiation of business interactions.

Money Laundering

Individuals or entities involved in criminal enterprises (such as drug trafficking, bribery, fraud, blackmail, etc.) frequently seek to "cleanse" ill-gotten gains, disguising their origins to evade public scrutiny or create a facade of legitimate income. The majority of countries worldwide have laws prohibiting money laundering.

K&T JV LTD  is resolutely committed to unwavering adherence to all relevant anti-money laundering regulations. To this end, K&T JV LTD establishes business partnerships exclusively with trustworthy customers and/or other associates who are engaged solely in lawful business pursuits and derive their financial resources from legal channels.

Every segment of K&T JV LTD is therefore responsible for ensuring that they do not accept funds associated with money laundering. In cases of uncertainty, a comprehensive inquiry should be conducted to gather as much information as possible about the business partner. If there is any suspicion or indication of money laundering or other illicit activities involving a business partner, the pertinent supervisor must be promptly informed.

Engagement with Public Authorities

The majority of nations globally enforce stringent legal regulations concerning the acceptance of gifts and/or bribes in interactions with public authorities.

As highlighted in the preceding section, K&T JV LTD employees are prohibited from presenting, promising, or bestowing cash payments or similar benefits to civil servants and other individuals employed by public authorities. This prohibition applies especially to cases where the intent is to secure preferential treatment or influence decisions to be undertaken by these public authorities.

Political Contributions and Engagement

 Donations and any other forms of payments to political parties, whether direct or indirect, are impermissible. As an apolitical entity, K&T JV LTD refrains from making contributions, whether monetary or non-monetary, to political candidates, political parties, or organizations dedicated to furthering the interests of political parties or ideologies.

 Employees are at liberty to participate in personal political endeavors, provided that:

• Such personal political actions adhere to the bounds of legality.
• All personal political engagements occur outside of working hours.
• No resources belonging to K&T JV LTD are employed to support these personal political activities.
• The personal political involvements do not exert any adverse influence on K&T JV LTD in any manner whatsoever.

Competition Laws and Ethical Practices

The fundamental objective of competition laws, including antitrust laws, is to safeguard the principles of unfettered competition. K&T JV LTD is firmly dedicated to robust, transparent, and morally sound competition, carried out in strict accordance with the prevailing legal regulations. Regardless of our operational scope, we ensure that all our business conduct aligns impeccably with the laws governing equitable competition.

Transgressions against international and national competition regulations could yield profound ramifications for both K&T JV LTD and the implicated employees. These repercussions may encompass substantial penalties, civil litigation, and claims for damages from stakeholders such as customers, rivals, and more.

Due to the intricate nature of the topic and the potentially detrimental outcomes associated with transgressions or misconduct, this section cannot encompass the comprehensive array of competition rules governing interactions with customers, suppliers, and competitors within the market. Consequently, when uncertain, employees are strongly encouraged to reach out to their superiors at the earliest opportunity. This proactive communication helps to ensure clarity and compliance.

 Prohibition of Unfair Competition

In adherence to valid legislation, we prohibit all competitive actions achieved through unfair means. This prohibition specifically pertains to:

Misleading Information: The dissemination of deceptive data regarding business aspects such as product quality, origin, manufacturing methods, pricing, and other factors.

Misuse of Signs: Unauthorized usage of symbols like the CE marking on untested products, or the appropriation of third-party proprietary trademarks.

Unfair or Unethical Actions: This includes practices like boycotts, discrimination, breaches of contract, and betrayals of trust.

Interaction with Customers

Our interactions with external parties are consistently fair. We rely on the merits of our products and services for competition. We ensure that our sales materials, advertisements, and other communications accurately and honestly represent our offerings. We treat all customers with integrity, fairness, and respect for their independence. Any agreements or arrangements that hinder competition, especially those involving resellers, are considered unlawful. Additionally, in the event of a dominant market position, K&T JV LTD commits to responsible conduct.

Relations with Suppliers

K&T JV LTD’s procurement decisions are grounded solely in product/service quality, deadlines, pricing, and supplier support. Fair treatment is extended to customers or suppliers that are also competitors, eliminating any bias. We refrain from securing supplier agreements that mandate their purchase of our products/services as a prerequisite for conducting business.

Engagement with Competitors

Collaboration with competitors is avoided. K&T JV LTD refrains from engaging in arrangements that limit competition, whether explicit or implicit, covering aspects like prices, terms, quantities, customer allocation, and sales territories. Agreements barring competitors from transacting with specific customers or suppliers (boycotts or refusals) are also prohibited. Acquisition of market information adheres to lawful methods.

Discussions with customers involve avoiding the disclosure of internal matters, including:

• Pricing and sales terms
• Cost structures
• Inventory details
• Production plans
• Market assessments
• Confidential or proprietary data

Joint ventures, collaborations, and mergers can potentially stifle competition if entered into with (potential) competitors. Their feasibility must align with the legal frameworks of relevant jurisdictions. Therefore, all planned ventures, collaborations, and mergers must be vetted by the Corporate Legal & Public Affairs department and are generally subject to the Executive Board's approval.

Considering the conditions for permissible comparative advertising, K&T JV LTD generally refrains from such practices. Comparisons with competitors' products or services are required to be objective, comprehensive, fair, and accurate. Data and information supporting these comparisons undergo thorough validation.

Lastly, derogatory remarks or negative comments about competitors are strictly prohibited.

Foundational Principles

Numerous governments worldwide have enacted regulations to impose constraints on the export of goods and the dissemination of technology. These regulations serve multiple objectives:

• To curtail global conflicts and prevent their initiation.
• To safeguard countries' security by preventing terror groups and hostile regimes from accessing military equipment and technology.
• To protect the reputation of countries and governments by avoiding associations with weapon and military equipment provision or support for specific regimes.

K&T JV LTD aligns with these objectives. Additionally, violating export control regulations could lead to severe consequences, including substantial penalties (like goods seizure, sales forfeiture, denial of future export permits, or simplified customs procedures), as well as a significant reputational setback.

We adhere to all regulations applicable in the countries where we operate, specifically those related to goods export restrictions, embargoes, and sanctions on particular countries and individuals.

Controlled Goods and Products

Products subject to export limitations generally fall into these categories:

• Military goods: Items designed for military purposes.
• Dual-use goods: Civilian-oriented items that could be exploited for military or prohibited purposes with moderate effort.
• Sanctioned goods: Items banned from export to specific countries due to embargoes or sanctions. These usually encompass goods used for internal repression or vital to industries in sanctioned countries.
• Whether a product is subject to export restrictions hinges on its features and technical attributes.

Controlled End-Uses

Even if a product isn't inherently restricted for export, its use for specific prohibited purposes could still lead to export limitations or bans. These purposes are particularly linked to weapons of mass destruction, carrier rockets for such weapons, and military use in countries under weapons embargoes.

Moreover, we consider the following facets:

Listed Individuals

Many countries have regulations within their sanctions and embargoes framework that prohibit transactions involving certain individuals or entities (termed "listed persons").

Risk of Diversion

Instances may arise where individuals or entities unable to access specific products through conventional channels-due to denied export permits, for instance-might attempt to deceive by involving third parties or providing inaccurate export transaction details.

Export and Technology Transfer

Similar to physical goods, technology (including information, drawings, component lists, and instructions aiding product manufacturing) and software can also fall under categories of military goods, dual-use goods, or sanctioned goods. Transferring such technology or software to foreign nations may necessitate permits.

Prior to any technology or software transfer, we ensure compliance with permits and permissions.

Conflicts of Interest

K&T JV LTD upholds the privacy of its employees and, under normal circumstances, does not involve itself in their personal matters beyond the workplace. However, all K&T JV LTD employees are required to steer clear of situations that may create or have the potential to create conflicts between their personal or familial interests and the interests of the company. It is strictly forbidden for personal interests to influence the professional judgment of our employees.

In the realm of business, conflicts of interest typically arise when the personal endeavors of employees or their immediate family members (spouse, parents, children, or other cohabitants) clash with the company's operations, raising concerns about the decisions made and the integrity of the decision-maker.

Illustrative Instances of Possible Conflicts of Interest include:

• Engaging in activities external to K&T JV LTD that hinder or have the potential to hinder performance within the company.
• Undertaking business transactions with companies or individuals where a close family member holds ownership or serves as a direct negotiating party.
• Accepting gifts, favors, or similar gestures.

Numerous actual or potential conflicts of interest can often be sidestepped in a manner that suits both the employee and the company's interests. Invariably, any existing or potential conflicts of interest should be disclosed through a written report submitted to the immediate supervisor, with a corresponding entry documented in the personnel records.

Core Principles

Every employee at K&T JV LTD bears the responsibility of upholding this Code of Conduct, alongside adherence to laws, internal guidelines, and regulations. This commitment is pivotal for K&T JV LTD’s enduring success, even when faced with challenging compliance scenarios.

 When confronted with questions or situations residing within ambiguous territory, and neither the Code of Conduct nor internal guidelines offer explicit direction, consider the following queries:

• Does the intended activity comply with the law? Are you being asked to engage in something that might be ethically questionable?
• Is the situation clear and understandable?
• Would your actions remain consistent if observed by your superiors, K&T JV LTD’s senior management, or colleagues?
• Would you feel at ease with your actions being publicized in the media?

Points of Contact

Should uncertainty persist even after carefully pondering these questions, please reach out to any of the following individuals:

• Your immediate supervisor
• Other managers within K&T JV LTD
• Human Resources Executive
• Human Resources Executive Role

 The Human Resources Executive at K&T JV LTD carries the following responsibilities:

• Overseeing the implementation of the Code of Conduct
• Addressing queries about interpreting the Code of Conduct that arise during routine business operations
• Reporting to the K&T JV LTD Executive Board concerning company-wide adherence to the Code of Conduct

Please contact the Human Resources Executive if:

• You're unsure how to act in specific business scenarios
• You suspect that the Code of Conduct contradicts local laws and/or internal guidelines and rules
• You have suggestions for enhancing the Code of Conduct

Contact details for the Human Resources Executive can be found in K&T JV LTD’s internal communications, local bulletins, notice boards, and similar channels.

Sometimes, workers at K&T JV might find or think that someone is not following the rules in the Code of Conduct, other company rules, or even laws. Doing something wrong like this can really hurt the company's business and its reputation. So, the company doesn't allow it.

If K&T JV workers see or think something is wrong, they should tell someone right away. Ignoring it is like helping bad behavior.

If they're not sure what to do, they can talk to their boss first. They can also talk to other managers, the Human Resources team, the works councils, or the Compliance Officer.

K&T JV will also have a special outside service that workers can call to report bad behavior. This service is called “Whistle Blow “The goal is to record reports of bad behavior that is proven or suspected.

All the reports made to the K&T JV Line will be kept secret and looked into carefully using a specific process.

 It's better if workers give their names when they report something, but they can also report things without saying who they are. You can find more about the “Whistle Blow “in the company's messages or from the Human Resources team.

To make sure workers feel safe talking about these things, K&T JV promises that people who report bad behavior won't get in trouble for speaking up. This also goes for anyone who gives important information to help check into the bad behavior.

 But, the company also says that if someone makes up a story on purpose, they might get into trouble.