Code of Conduct

This Code of Conduct sets out the guidelines of behavior for all African Road Technology employees, officers and directors.  These standards are also expected from each of our business partners, agents, advisors and sub-contractors when they are working with us or on our behalf. These expectations should be visible at all times to our co-workers, host communities and governments, along with all other individuals and groups whose opinions influence our success. Collectively, these are our stakeholders.

The Code expresses our expectations in general terms. It cannot and does not address every situation that may arise. If you find yourself in a situation that presents a difficult ethical decision and you cannot find the guidance you need here, or in any of the policies that we have adopted from time to time, you should ask your immediate line manager or, alternatively, any of our Directors. This code of conduct is available on our intranet and also our website.

While we reserve the right to modify these documents from time to time, our commitment to the basic principles laid out here, including our policy against retaliation, will not waiver

Every employee and every contractor engaged on our behalf is, in practice, individually accountable for our reputation for integrity. We also expect that Directors and managers will lead by example to set a tone for ethical behaviour for all of their employees. It is expected that they will make themselves available to employees with any questions about ethics and compliance. Our intention is that questions can easily be raised and that employees get appropriate and clear answers.

Our Code is based on good common sense and sound judgment. If you step back from a situation and ask yourself, “what’s the right thing to do?” you will almost always arrive at the right solution. Apply the “Mirror Test” – ask yourself: “how would I feel if my decision and the consequences of my actions were featured on the front page of the newspaper?” or “would I be proud to explain my actions to my co-workers, family members and friends?”

Finally, in our operations here in Cameroon and elsewhere, local cultural norms sometimes conflict with our legal obligations, our Code, our policies and relevant standards. Whenever such a situation arises, please ask your line manager or any Director. If in any doubt, ask. In any case

of conflict, our legal obligations, our Code, our policies and relevant standards must govern and apply to your conduct.

Standards of Conduct

  1. We work safely.

We are committed to an accident and injury free workplace, and to protecting the health and wellbeing of our employees and visitors.

  1. We promote sustainability.

We must and will observe the prevailing relevant social, environmental, and economic principles of sustainable development wherever we operate.

Our commitment to sustainability includes the promotion of fundamental human rights, especially for those who live in the communities where we operate and those with whom we work.

  1. We value diversity and inclusion and work respectfully.

We welcome employees from a wide range of cultures and races and seek to maximize local employment opportunities so our workforce reflects the communities where we operate as much as possible.

  1. We make hiring and promotion decisions fairly.

African Road Technology is an equal opportunity employer. We recruit, select, place, promote and compensate employees on the basis of their qualifications for the job and do not discriminate against one another on the basis of national origin, race, religion, disability, age or any other attribute that is protected by local laws or generally accepted international practice.

  1. We support and protect those who speak-up.

We will not retaliate or take any action against any employee for asking questions or voicing concerns about our legal or ethical obligations when acting reasonably and in good faith.

  1. We protect the value of our assets, including our physical and intellectual assets, our information, data and our good reputation.

We follow applicable security and information technology standards to protect our physical assets and intellectual property from theft, loss, damage, or misuse. We safeguard our confidential information from unauthorized disclosure, changes or loss, and we conduct ourselves at all times in a manner that will uphold the value of our good name and reputation whenever we represent the company.

  1. We behave honestly and transparently in our dealings with others.

We do not tolerate bribery or corruption of any kind and will undertake our business in a transparent manner.

  1. We speak up when we see issues or have questions and we will cooperate candidly in any investigation.

We are encouraged to communicate with our line managers, our Site managers, or Directors if we have questions about or feel that we are being pressured to violate our ethical responsibilities, or see others doing so. We also candidly cooperate in investigations regarding ethics and compliance matters and other company-related investigations.

  1. We are accountable for upholding the Code.

Every Africa Road Technology employee, officer, director, and contractor engaged on behalf of our Company is accountable for complying with this Code, our policies as applicable to them and all local and national laws, and applicable regulations in all countries where we do business. Failure to live up to the responsibilities in our Code, and Company policies (as amended from time to time) or applicable laws and regulations may result in disciplinary action which could result in termination of employment.

  1. How our governance works.

This Code reflects our expectations of one another as we work to advance the interests of our Company and its stakeholders. It is the foundation of our internal governance, which consists of the Policies listed below and other supporting documents. Our employees and third-party colleagues can find an electronic version of this Code and the Policies referred to in it on the Company’s web-site.

  1. Health and Safety Policy
  2. Operations and Resource Development Policy
  3. Asset and Value Protection Policy
  4. Business Integrity Policy
  5. People Policy
  6. Sustainability and Stakeholder Engagement Policy

Neither this Code, nor any policy, or other similar statement (either written or verbal), are not and may not be interpreted as an employment contract or other legally binding agreement between this Company (or any of its holding companies or subsidiaries) and any person or entity unless incorporated as part of some written legally binding contract concluded between this Company and the relevant person.

Code Acknowledgement.

I understand and agree that the statements contained in this and in any other company materials (including Policies, guidelines, and other similar statements (both written or verbal) do not constitute a contractual commitment to continued employment or otherwise create any contractual obligation on the part of the Company on any account whatsoever.

I also understand and agree that this Code of Conduct and other company materials

do not constitute a promise of specific treatment in specific circumstances, but are expectations that may be revised by the Company or any manager whenever in their reasonable judgment a change is necessary or appropriate and I will abide by any such changes. Notwithstanding the foregoing, our against retaliation for speaking up in good faith, however, will not be modified.

Waiver.

This Code cannot be waived without appropriate approval. If you encounter a situation that you believe may require waiver of a provision of the Code, raise the issue promptly with your line managers, your site managers, or our Directors. Directors and executive officers who seek a waiver should address the Board of Directors or a designated committee of the Board. Waivers for Directors and executive officers will be disclosed to the extent and in the manner required by law.