Ethical practices, compliance with laws and regulations and transparency are essential to building trust with stakeholders, fostering a culture of accountability and ensuring long-term success. As a lawful, ethical and responsible organization, ADNOC upholds the highest standards of integrity. This approach supports broader sustainable development across our operations and responsible environmental, social and economic outcomes. Our ethics and compliance program sets out our approach to managing compliance obligations, mitigating compliance risks and upholding the highest levels of ethical standards. The Group Ethics and Compliance function is responsible for the development, implementation and review of the Group Ethics and Compliance program with oversight from the MD & GCEO, the ADNOC Board of Directors and the ADNOC Audit Committee. Our Group Ethics and Compliance program is certified under ISO 37001 (Anti- Bribery Management System) and ISO 37301 (Compliance Management System). Operating with Integrity Our Code of Conduct articulates our commitment to conducting business ethically, responsibly and in compliance with all applicable laws and regulations. It sets the requirements and expectations for our employees to act with integrity at all times. Our Supplier and Partner Code of Ethics applies to all third parties we engage with, including suppliers and strategic partners 26 . It sets out the rules and standards that allow us to conduct our business in an ethical and compliant manner and in accordance with our values. We have adopted and implemented corporate compliance policies, standards and procedures across all key compliance risk areas. We continue to review and update these as required for a company of our size and structure, operating in the industries we do. Compliance program Code of Conduct our commitment to act with integrity in everything we do Standards Ethics and Compliance Framework the framework governing our Ethics and Compliance Program Whistleblowing and Non-Retaliation our commitment to a speak-up culture and no retaliation Anti-Bribery and Anti-Corruption zero tolerance for fraud, bribery, corruption or money-laundering Conflict of Interests conflicts between responsibilities to ADNOC and outside interests must be disclosed Gifts and Hospitality gifts and hospitality (offered or received) must be appropriate Sanctions and International Trade Controls restrictions on the business we can do with certain entities and countries Supplier and Partner Code of Ethics the standard of behavior we require for third parties working for ADNOC Integrity Due Diligence all companies ADNOC does business with must be reviewed for integrity Compliance Incident Management compliance investigations are conducted fairly and rigorously Competition Compliance avoiding anti-competitive conduct when dealing with competitors or third parties Insider Management 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 26 For details, see the Responsible sourcing section of this chapter. HOW WE OPERATE KEEPING OUR PEOPLE SAFE ADVANCING NET ZERO EMPOWERING LIVES SUSTAINABILITY AT ADNOC ABOUT ADNOC PROTECTING NATURE AND BIODIVERSITY 117 ADNOC Sustainability Report 2025 116
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