Code of Conduct and Business Ethics

Boursa Kuwait adopted a code of conduct that includes best practices and professional conduct in this field in order to achieve the interests of the company and its shareholders and stakeholders, in addition to providing the opportunity for members of the Board of Directors, Executive Management and employees to achieve the objectives of the company to the fullest.

Boursa Kuwait has prepared a set of policies and procedures to ensure that its assets and resources are not exploited to achieve personal interests as well as limit the exploitation of internal information and promote the principle of avoiding conflicts of interest, which are summarized as follows:

Related Parties Transactions

The related party transactions policy provides guidelines on how to conduct and manage transactions with related parties, whether those transactions are between the company and its Board of Directors or Executive Management and employees. A record of the related parties has been prepared and circulated to the concerned departments.

Any new business relationship within the company is initiated only after verification that it is not related to that list, and in the event of any association with those parties, it is recorded in the transaction log with the related parties, reviewed by the Risk Management Committee and presented to the Board of Directors for discussion and approval.

Whistleblowing Policy

The whistleblowing policy provides a collaborative and transparent working environment for all employees, as the company has created an e-mail on Boursa Kuwait’s website in which any stakeholder can convey their concerns or suspicions about any violations, malpractice or misconduct to the Board of Directors. Such procedures shall be carried out within a framework that ensures protection of the informant, provision of the necessary investigation and supervision of such procedures.

Trading in Securities

In order to eliminate any potential conflicts of interest, a conflict of interest policy that sets guidelines for identification, notification, reporting, disclosure, prevention, or strict restraints of potential conflicts of interest has been developed. Moreover, it has established appropriate procedures to identify and effectively deal with cases of conflict of substantive interests, and to make sure that the Board of Directors deals with existing, potential and expected conflicts of interest and that all decisions are taken to achieve the company’s best interest.

The serious practical steps taken by the company to limit any conflict of interest cases include preventing employees and their minor children from trading in securities either listed on Boursa Kuwait or even ones that have applied for listing. During the onboarding period, the company makes the employee sign a disclosure form for the listed securities that either they or their minor children possess. In addition, the employees sign statements not to trade, whether for themselves or for their minor children, in securities listed or applied for listing on the stock exchange, except in exceptional cases specified by the executive bylaws of the Capital Markets Authority. Moreover, an annual report is to be submitted to the Capital Markets Authority that includes details of disclosure of ownership of listed securities and any related changes.