Compliance assessment and monitoring We conduct compliance risk assessments periodically to identify, measure, and update ethics and compliance risks in our business activities, assess current state of controls and develop risk mitigation plans as required. We also assess adherence to the compliance obligations and the compliance program across the ADNOC Group. Compliance program Code of Conduct our commitment to act with integrity in everything we do Ethics & Compliance the framework governing our Ethics & Compliance Program Supplier & Partner Code of Ethics the standard of behavior we require for third parties working for ADNOC Whistleblowing and Non-Retaliation our commitment to a speak-up culture and no retaliation Anti-Bribery and Anti Corruption no tolerance for fraud, bribery, or corruption Conflict of Interests conflicts between responsibilities to ADNOC and outside interests must be disclosed Gifts and Entertainment gifts & Entertainment (offered or received) must be appropriate Sanctions & International Trade Controls estrictions on the business we can do with certain entities end countries Integrity Due Diligence all companies ADNOC does business with must be reviewed for integrity Compliance Investigations compliance investigations are conducted fairly and rigorously Competition Compliance avoiding anti-competitive conduct when dealing with competitors or third parties Inside Information and Insider Trading requirements applying to sensitive information about ADNOC Distribution and ADCOP Anti-Money Laundering compliance with applicable anti-money laundering laws and regulations Ethical use of AI responsible and ethical development, deployment and use of AI Privacy and Data Protection requirements for appropriate protection and management of personal data 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 operate. Addressing corruption, internally and collectively, aligns with our company values. All our suppliers, customers and other third parties who work with us are subject to, amongst others, anti-bribery and corruption exposure risk assessments as part of our integrity due diligence process. 134
ADNOC Sustainability Report 2024: Driving Progress & Prosperity Page 133 Page 135