Raising concerns Training and awareness Conflicts of interest Gifts and entertainment ADNOC Group is committed to an open and transparent culture where everyone is empowered to speak up whenever our values and integrity are at risk. We ensure concerns can be reported in a manner that is legitimate, fair and equitable. This includes employee engagement surveys, ad hoc workers’ committees, targeted contractor helplines, a direct line to the Group Compliance team via a compliance phone contact number and mailbox and an anonymous whistleblowing helpline Takallam (which means ‘to speak’ in Arabic) run by an independent third party on our behalf. The whistleblowing line is available to employees, contractors, other third parties and the general public 24/7 in both English and Arabic languages. Any concerns received are handled in strict confidence. In accordance with the ADNOC Group Whistleblowing and Non-Retaliation Standard, 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 via other channels. We are committed to ensuring concerns or grievances are investigated impartially and free from attempts by interested parties to influence the outcomes. Any remedial measures are based on fairness, equality and procedural transparency. Approximately 640 Takallam matters were raised in 2024. These matters were internally reviewed and, where necessary, appropriate action was taken. Identified gaps or areas for improvement were shared with the respective functions for implementation. It is mandatory for all our employees to complete annual training on the ADNOC Group Code of Conduct, including antibribery and corruption policies and standards and other related Group policies and procedures. Employees also complete an annual compliance declaration confirming their understanding of, and compliance with, the ADNOC Group Code of Conduct and other compliance policies. We regularly hold employee training and awareness sessions on conflicts of interest, gifts and entertainment and the importance of speaking up without fear of retaliation for all employees. Additionally, we provide compliance updates throughout the year for our business lines, provide compliance inductions for new joiners and conduct targeted compliance training on specific topics, including competition law and antitrust and sanctions and international trade controls. To strengthen awareness across the value chain, we extended Code of Ethics training to our contractors, reinforcing our expectations of ethical conduct beyond ADNOC’s direct workforce. In 2024, 99.5% of all employees assigned to complete the online annual Code of Conduct training and declaration did so successfully. 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 disclose a potential, actual or perceived conflict of interest, including any internal or external relationships or interests that could impair objectivity or lead to perceived bias. Once reported, individualized controls to manage any potential risks are applied, as appropriate. As part of the annual compliance declaration, employees confirm the status of any conflicts they may have. ADNOC has a Gifts and Entertainment standard in place to ensure all gifts and entertainment offered or received by employees is modest, legal and appropriate. Employees are required to disclose and seek approval for gifts or entertainment above certain thresholds or involving government officials. 135 ADNOC Sustainability Report 2024 HOW WE OPERATE KEEPING OUR PEOPLE SAFE ADVANCING NET ZERO EMPOWERING LIVES SUSTAINABILITY AT ADNOC ABOUT ADNOC PROTECTING NATURE AND BIODIVERSITY
ADNOC Sustainability Report 2024: Driving Progress & Prosperity Page 134 Page 136