Al Farees, subsidiaris and affiliated companies have implemented a corporate compliance   program   (Compliance   Program)   to   provide   guidance   for   anyone associated with Al Farees, including its employees, officers and directors (each referred to collectively or individually in this Code depending on the context as “you”). The Code prohibits unlawful or unethical activity and directs you to avoid actions that, even if not unlawful or unethical, might create an appearance of illegality or impropriety. Al Farees depends upon maintaining its reputation in the business and financial community for the highest standards of legal and ethical behavior.   Any action that might diminish this reputation can adversely impact the Al FareesP and you.

Our  Corporate  Code  of  Conduct  (Code)  is  the  core  of  the Al Farees Compliance Program and is an integral part of the Al Farees’s employment policies and procedures.  The employees are responsible for becoming familiar with and complying with our Code.   A  current  copy of  the  Code,  which  will  be  updated  periodically,  is  always available to you from the Human Resources representative.

Reporting violations of the Code, as you may discover them, is an essential element of the Compliance Program.  If you ever have a question or are uncertain concerning the applicability of the Code, you should contact the Chief Compliance Officer or the Al Farees at the information given in the contact page. It is  an  impartial,  independent  service  that  provides  an  anonymous  and confidential method for our employees to report perceived misconduct or wrong doing or make inquiries of the Al Farees.  In any circumstance where you feel it uncomfortable or inappropriate to contact the Chief Compliance Officer directly, the hotline can relay your concerns to the Chairman of the Audit Committee.   Specific mandatory reporting procedures are outlined in Section IV below.  You should follow these procedures if you become aware of any information, facts or circumstances that constitute, or might constitute, a violation of the Code.