FOREWORD
in carrying out its business activities thereby
Emirates National Oil Company Ltd. (ENOC) LLC is
an organization with varied businesses joined together
by the shared vision of many talented individuals. Our
successes and image is reflected by the people that
work for ENOC and our organization demands and
maintains the highest ethical standards
4 5
All ENOC entities, its employees and suppliers are ultimately responsible for conducting themselves in
providing a solid foundation for future growth.
As we move forward, to effectively meet industry
challenges and collectively understand the
responsibilities in driving towards an ever growing
successful organization, a key component is an
understanding of ethical practices. For this
purpose, a Code of Business Conduct (herein
after ‘the Code’) handbook has been developed as
a guide for ENOC employees. The Code is a
management tool for establishing the corporate
values, responsibilities, obligations, ethical
ambitions of ENOC and the way it functions.
The Code is not intended to be exhaustive but to
provide direction, which will assist us in taking
responsible actions in a complex business
environment. Having the Code is not enough, as the
Code can only be effective and useful with committed
dissemination, implementation, monitoring and
embedding at all levels, which, will positively influence
employee behavior and contribution to the organization.
an ethical and integral manner in compliance with applicable laws i.e. everyone working for or with
ENOC must uphold the highest standards of business integrity and ethics in the conduct of all ENOC
related activities. The Code signifies ENOC’s long-standing commitment to conduct our business in
compliance with all applicable laws and regulations, in accordance with the continuous integrity and
highest ethical principles.
Compliance with our legal and ethical obligations is the responsibility of every employee and entity of ENOC,
as is the responsibility to acknowledge and report potential non-compliances of these obligations. Reporting
can be done directly through your supervisor / line manager or the Business Ethics Committee (BEC).
A commitment to integrity is about creating a climate for sustainable success. It is about creating an
environment where good people can make good decisions. Let us, as a team, ensure that ENOC’s
commitment to maintain the highest standards of business conduct is reflected in every activity that is
undertaken. I am certain that ENOC is and will continue to be known as an organization that upholds the
highest ethical standards.
Saeed Khoory
Chief Executive Officer
CONTENTS

ENOC VISION 8 ENVIRONMENT, HEALTH AND STAKEHOLDERS 24 TRUST & COMPLIANCE 30

ENOC MISSION 8 SAFETY (EHS) 15
ALCOHOL AND DRUGS 16 RECORDS MANAGEMENT 24 INTERNATIONAL BUSINESS 30
ENOC VALUES 8 WORKPLACE VIOLENCE PREVENTION 17 COMPANY PROPERTY 24 ANTI-CORRUPTION COMPLIANCE 30
INTEGRITY INTELLECTUAL PROPERTY 25 GOVERNMENT INVESTIGATIONS 30
INTRODUCTION TO THE CODE 10 18 TRADEMARKS 26 AUDITS (EXTERNAL, INTERNAL
INFORMATION USE AND SECURITY 26 & GOVERNMENT) 31
BUSINESS ETHICS COMMITTEE 12 CONFLICT OF INTEREST 18 CONFIDENTIAL & PROPRIETARY WHISTLEBLOWING 32
BUSINESS COURTESIES, GIFTS AND FRAUD & THEFT 33
BUSINESS ETHICS & ENTERTAINMENT 19 INFORMATION 28 COBC ACKNOWLEDGEMENT
COMPLIANCE FUNCTION 12 EMPLOYMENT OF IMMEDIATE 34
ETHICS HOTLINE 12 RELATIVES 20 CONFIDENTIAL INFORMATION 28 HOW TO CONTACT BE&C
RETALIATION 12 OUTSIDE EMPLOYMENT 21 PROPRIETARY INFORMATION 28 35
PEOPLE 14 CUSTOMERS 22 PUBLIC STATEMENTS 29

FAIR TREATMENT 14 THIRD PARTY RELATIONS 22

TOLERANCE 14 VENDOR SELECTION 22

6 7
ENOC VISION, MISSION AND VALUES
ENOC VISION
To be a leading regional integrated oil & gas group
highly profitable and socially responsible towards
employees, community and environment.
ENOC MISSION
•Achieving sustainable development and highly
profitable growth
•Serving growing energy needs of Dubai
•Attracting, developing and retaining top talent to
become the employer of choice
•Adopting latest technologies and implementing
best practices thus achieving world – class
performance
•Meeting and exceeding customer expectations
in terms of quality and service
•Maintaining high industry standards in
Environment, Health and Safety
8 9
ENOC VALUES
ENOC values have been imbibed in word and
spirit of the Code. As stated by the Chief
Executive Officer, “It is extremely important and
imperative to realize that we need to focus on and
live those values in all our actions and decisions.
Going forward, these values should be our guiding
principles in our journey to excellence”.
We want our decisions and actions to
demonstrate these ‘Values’. We believe that
putting our ‘Values’ into practice creates long-term
benefits for shareholders, customers, employees,
suppliers, and the communities we serve.
TEAM WORK – working together by sharing
ownership, responsibilities and outcome.
INTEGRITY – being honest, truthful, reliable and
fair, while dealing with all stakeholders.
TRANSPARENCY – being open, straightforward
and consistent in all we do, by communicating with
clarity, simplicity and precision.
RESPECT – acknowledge, recognize, and value
all stakeholders.
CUSTOMER FOCUS – position customer first in
all that we do.
 INTRODUCTION TO THE CODE

Emirates National Oil Company (ENOC) Code of
Business Conduct has been launched to effectively
meet industry challenges and ensure highest ethical
practices in carrying out its business activities thereby
providing a solid foundation for future growth.
This Code is a baseline while the business policies
and practices may require more compliance than
required by the Code. In those instances, entities
must follow the stricter policy, practice or law. The
Code is not a compilation of ENOC policies.
In extraordinary conditions, an entity may seek approval
of actions that otherwise would not be compliant with
the Code. Approval of any such actions must be sought
in advance and may be granted only by the Business
Ethics Committee (BEC).

ENOC places the highest value of integrity on its
directors, officers, employees and its entities. These
stakeholders are responsible for complying with all
applicable laws and regulations in each country
where ENOC does business and for knowing and
complying with this Code and other ENOC policies.
Violations of the Code are subject to disciplinary
actions including termination. Business units are
responsible for ensuring that their policies and
practices are consistent with this Code. The policies
in this Code apply across ENOC businesses in all
countries. If a local law conflicts with a policy in this
Code, the local law shall take precedence.
The Code and its terms may be modified or For any suggestions, feedback or complaints,
eliminated at any time by ENOC. ENOC entities contact the Business Ethics & Compliance
and employees are responsible for being familiar Function through COBC Portal.
with its contents. The most current version of the
Code is available on ENOC employee portal.
The rights of an employee and ENOC’s rights as an
employer are governed by the laws of the country of
employment, the policies of the employing entities
and the individual’s written employment contract.
This Code is not intended to clarify ENOC’s rights
and expectations as an employer. In case of any
doubts, employees should approach the Business
Ethics & Compliance (BE&C) function.

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 INTRODUCTION TO THE CODE
BUSINESS ETHICS COMMITTEE
The Business Ethics Committee (BEC) has been
established to oversee various aspects related to
ENOC Code of Business Conduct. The purpose of
the committee is to review and recommend to
managment the objectives, policies and
procedures that best serves ENOC’s interests in
maintaining a business environment committed to
high standards of ethics and integrity, corporate
responsibility and legal compliance. The
Committee’s authority and responsibility is defined
by the Business Ethics Committee Charter.
The BEC is comprised of the Chief Executive
Officer, Chief Ethics & Compliance Officer and
heads of HR and legal departments.
BUSINESS ETHICS & COMPLIANCE FUNCTION
The Business Ethics & Compliance function (BE&C) ENOC Ethics Hotline is an independent and confidential
has been established at ENOC by ENOC Audit multi-lingual platform available through phone, fax
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Committee. The function, headed by the Chief Ethics
& Compliance Officer, functionally reports to the
established Audit Committee and administratively
to the Chief Executive Officer.
BE&C has formally adapted an Ethics & Compliance
Program with activities related to establishment of
Code of Business Conduct for ENOC and its
stakeholders, related policies, management of Ethics
Hotline, case investigations, resolution, and its
reporting, awareness and trainings to reinforce the
Code as well as to ensure greater transparency in its
implementation. The function is also supported by an
independent Business Ethics Committee.
ETHICS HOTLINE
and email to report conduct that may be in violation with
ENOC Code of Business Conduct. This has been
designed to enable employees and other stakeholders
to easily and confidentially report any issue or instance
of misconduct. The service is manned by professional
and experienced consultants, able to attend to
employees effectively and take the initiative in dealing
with sensitive disclosures appropriately
RETALIATION
ENOC’s commitment to integrity includes a
responsibility to foster an environment that allows
people to report violations without the fear of retaliation
or retribution. No one should be discouraged from using
any available channels within ENOC.
Anyone who retaliates against another employee
for reporting known or suspected violations of
ENOC’s legal or ethical obligations is in violation of
the Code and subject to disciplinary action.
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 PEOPLE
FAIR TREATMENT
ENOC treats each individual fairly and recruits,
selects, trains, promotes and compensates based
on merit, experience and other work-related
criteria. ENOC complies with all UAEl laws
governing employment and labour practices.
Freedom from discrimination includes freedom from
any form of discriminatory harassment. Harassment
includes conduct that is intended to interfere or that
has the effect of interfering with a fellow employee’s
work performance or creating an environment that is
intimidating, hostile, or offensive to the individual.
Reference Documents: Human Resources Policy Manual (Code
of Business Conduct and Corrective and Guidance Policy)
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TOLERANCE
ENOC strongly supports each employee’s right to his or
her personal beliefs and values. However, personal
beliefs aside from those covered by the Code, should
not be forced on others in the workplace.
Employees should not use ENOC communication
tools (letters, e-mail, bulletin boards etc.) or
facilities to advocate religious, ethnic, political or
other potentially sensitive personal preferences.
Employees should not create, disseminate or circulate
malicious rumors and gossip, which effect fellow
colleagues, thus creating an atmosphere of stress, un-
productivity and employee disengagement.
Reference Document: Human Resources Policy
Manual (Code of Business Conduct)
ENVIRONMENT, HEALTH AND SAFETY (EHS)
EHS plays a fundamental role in the businesses
within ENOC. The overall strategy for managing
EHS risks is embodied in ENOC EHSQ Policy.
This Policy commits management and staff to
operate ENOC facilities in a manner, which
protects and preserves the natural environment,
and promotes the health, safety and security of its
employees, customers, suppliers, contractors and
the general public. ENOC firmly believes that
implementation of EHS guidelines is important to
ensure sustainability of its operations and directs
the way it runs its businesses.
As a minimum, ENOC will abide by local and
national EHS laws as well as comply with
internationally accepted standards and practices.
ENOC shall as an organization, apply the best
practice standards where applicable.
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 PEOPLE
To support the goals outlined in the ENOC EHSQ
Policy, ENOC has developed guidelines to ensure that:
•There is consistent implementation of EHS rules
and regulations across ENOC Group
•EHS policies, plans and programs are aligned
with corporate business plans
•Management is constantly made aware of the
EHS performance of ENOC Group
•Duties, responsibilities and expectations are
properly identified
•ENOC Group is provided with sufficient logistical
resources to handle all credible emergency scenarios
•Compliance review frameworks and mechanisms
are defined
•Approved codes of practice exist to guide
operating companies/affiliates on effective
implementation of EHS practices
Reference Document: EHSQ Policy
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ALCOHOL AND DRUGS
ENOC conducts its business with high standards of
safety, concern for the environment and the health of
its employees. ENOC policy is to maintain an alcohol
and drugs-free work environment.
Apart from being a serious violation to the local
regulations, the abuse of alcohol, drugs (illegal or
legal) or other substances in and outside of the
workplace can impair performance and be a
serious threat to both the health and safety of the
individual and their fellow workers. As a socially
responsible organization, ENOC is fully committed
to ensure that all its work places are completely
“Alcohol and Drugs Free”.
ENOC has a “zero tolerance” policy on drugs,
alcohol or other substances for employees on duty.
All employees must be aware of and abide by its
Alcohol and Drugs Policy Statement. ENOC strives
to maintain working conditions which are safe and
compliant with all applicable laws for its
employees and visitors to its premises.
Reference Documents: Human Resources Policy Manual (Alcohol
and Drugs Policy Statement and Corrective and Guidance Policy)
WORKPLACE VIOLENCE PREVENTION
ENOC is committed to a safe working
environment, free of threats, intimidation and
physical harm. Everyone has the right to work in a
safe environment and shares the responsibility for
assuring each other’s safety.
ENOC adopts a zero tolerance workplace violence
policy. This means that ENOC will investigate and
take appropriate action against any threat to a
safe workplace.
ENOC prohibits violent behavior including, but not
limited to, physical assaults, fights, threatening
comments, intimidation, and the intentional or
reckless destruction of property belonging to
ENOC, its employees or customers.
Any comments or behavior that could reasonably
be interpreted as intent to do harm to people or
property should be considered a threat and must
be reported to BEC.
ENOC also prohibits the unauthorized possession
and/or use of weapons by any individual on ENOC
premises.
Reference Documents: Human Resources Policy
Manual (Corrective and Guidance Policy)
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 INTEGRITY
CONFLICT OF INTEREST
Employees are expected to give their undivided loyalty to
ENOC when conducting job-related duties. ENOC requires
that its employees do not engage in, or give the
appearance of engaging in, any activity involving any
conflict, or reasonably foreseeable conflict, between their
personal interests and the interests of ENOC.
A conflict of interest occurs when personal interests
interfere with an employee’s ability to exercise his
judgment objectively in the best interests of ENOC.
Very often, a conflict of interest occurs when
employees make decisions on behalf of ENOC, while
also having a controlling or financial interest in, or
receive financial benefits from, an organization that
wants to do business with ENOC.
Conflict of interest can arise in many common areas,
despite our best efforts to avoid them. However, such
conflicts can generally be resolved by promptly notifying
the line manager or designated authority of any actual,
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perceived, or potential conflict of interest situation.
The manager can then provide guidance on how
best to resolve the conflict. If needed, an
employee may also contact BE&C for guidance.
Conflict of interest must also be disclosed in the
annual “Conflict of Interest Disclosure Form”. If,
during the year, any event or circumstance results in
development of conflict of interest by the employee,
the line manager / supervisor should be informed
immediately and the “Conflict of Interest Disclosure
Form” should then be resubmitted.
All ENOC employees are prohibited from using
ENOC property, information or position for
personal gain or to compete with ENOC.
Reference Document: Conflict of Interest Code
BUSINESS COURTESIES, GIFTS AND
ENTERTAINMENT
A business courtesy is a gift or service (whether in
money or in kind) provided to or received from a
business associate.
ENOC neither seeks to improperly influence the
decisions of its contractors or vendors by offering
extravagant business courtesies nor accepting
such courtesies from contractors or vendors.
All employees and representatives of ENOC
should understand the ethical issues associated
with gifts and entertainment and how these can
affect its relationship and reputation with the
customers and suppliers.
The issue of gifts and gratuities may have legal
implications when the Government or a Government
entity is involved and serious consequences can
result from mishandling these relationships. Offering
or accepting bribes and pay-offs is strictly prohibited.
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 INTEGRITY
Business gifts that compromise, or even appear to
compromise, our ability to make objective and fair
business decisions are inappropriate. Any doubt
should be resolved in favor of not giving or
receiving the gift.
ENOC employees and their immediate relatives
are generally not permitted to accept any business
courtesy or other benefit of any type offered in
connection with ENOC business transactions.
However, employees may accept:
•Limited refreshments and meals, when these
items are provided during a business meeting
•Reasonable and infrequent meals and entertainment
when offered by a business associate for a legitimate
business reason and when local custom or practice
would make it inappropriate to decline the offer
•Promotional business items with only token value as
per the limit provided in Conflict of Interest Code
Reference Document: Conflict of Interest Code
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EMPLOYMENT OF IMMEDIATE RELATIVES OUTSIDE EMPLOYMENT
ENOC wants to make sure that its workplace is fair and ENOC employment contracts prohibit employment of
untainted by any possible perception of favoritism. its employees at any other organization while
working at ENOC. Accordingly, ENOC will strictly
To ensure that all employees are hired, rewarded and enforce this provision and any employee who
promoted fairly, ENOC has a policy of not employing violates this prohibition will be subject to disciplinary
immediate relatives of the existing employees without action, including termination of employment.
requisite approvals. Immediate relatives include father,
mother, sister, brother, wife, husband, son or daughter. Reference Documents: Conflict of Interest Code and
Human Resources Policy Manual (Employment Contract)
Immediate relatives cannot be employed in jobs
where an ENOC employee has effective control over
any aspect of the related employee’s job.
In circumstances where immediate relatives are, or may
become involved in business activity / employment
related to ENOC, the employee should disclose the
nature of the relationship to ENOC and remove himself/
herself from any related decision-making process.
Reference Document: Human Resources Policy Manual (Recruitment)
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 CUSTOMERS
THIRD PARTY RELATIONS
ENOC competes fairly and in accordance with the
highest ethical and professional standards in its
third party relationships. ENOC entities shall
ensure that business is generated based on the
superior services and products with competitive
prices, and not through improper, unethical, or
questionable business practices.
Moreover, the entities shall strive for:
Honesty, integrity, fairness and compliance with
established tendering, procurement and
contracting policies, procedures and practices
Championing social responsibility and
sustainability practices in procurement
Avoiding the dealings that might prevent or
obstruct the effective operation of fair competition
Encouraging and supporting reliable contractors
and suppliers, locally and internationally
Long-lasting business relationships built on trust
and mutual benefit giving preference to
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competitive and quality goods and services,
promoting positive supplier and customer
relationships Avoiding behaviors or actions that
may negatively influence, or appear to influence,
procurement decisions
Reference Document: Quality Management System Manual
VENDOR SELECTION
ENOC entities will ensure that the all vendors are
selected based on appropriate criteria, such as
qualifications, competitive price and reputation.
Anyone responsible for buying or leasing goods or
services on behalf of ENOC must conscientiously
guard their objectivity and avoid any improper
reciprocal agreements.
Terms of ENOC’s business relationships, including
all external procurement commitments, i.e. Purchase
Orders, Contracts, Agreements, Performance
Criteria, Schedules, Prices and responsibilities are
established as per Procurement Policy in force
and full confidentiality is maintained to protect
mutual information.
The Vendors or any other third party goods/services
providers who do business with and/or represent ENOC
to conduct their business, are required to be in
compliance with all applicable local and international
laws, trade agreements and regulations as well as
follow the highest ethical and professional standards.
Reference Documents: ENOC Group Procurement Procedures
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 STAKEHOLDERS
RECORDS MANAGEMENT
ENOC adheres to the highest standards of honesty and
integrity. It is essential that the internal and external
reports and documents that ENOC creates, makes
public, or provides to its stakeholders, constitute full,
fair, accurate, timely and understandable disclosures.
The information that entities create, such as financial
reports, accounting records, business plans,
environmental reports etc. are required to be accurate,
truthful, and properly maintained. The users of this
information may be employees, government
representatives, auditors and legal bodies.
ENOC and its employees must ensure the retention
of records for requisite periods and that such records
are subject to timely destruction when the specified
retention period expires. “Record” for this purpose
includes hard copies of documents, records on
computers and electronic systems.
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Employees who contribute to the creation /
preparation of records are responsible for reading
and understanding ENOC policies, directives and
other procedures as they apply to their organization.
Reference Documents: Statuary and Financial Record
Retention Policy and Guidance Note (Refer Legal
Department for additional guidance)
COMPANY PROPERTY
ENOC employees should protect company property
to ensure its efficient use. Theft, carelessness, and
waste have a direct impact on ENOC’s profitability.
All ENOC assets are to be used for legitimate
company purposes. Any suspected incident of
fraud or theft should be immediately reported for
investigation through provided means of
communications like the hotline.
The obligation of employees to protect ENOC’s
assets also includes the company’s proprietary
information (refer Intellectual Property clause also)
Reference Document: Human Resources Policy Manual
(Corrective and Guidance Policy)
INTELLECTUAL PROPERTY
Patents, trademarks and copyrights prohibit the
unlicensed use of a protected invention, identifier (such
as a name or logo) or work (such as a photograph,
printed materials, or software).Violating such rights,
even inadvertently, can result in severe consequences.
Therefore, steps should be taken to avoid infringement
of non-ENOC patents and/or trademarks, and
employees should never make use of technology
patented by another company without permission.
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 STAKEHOLDERS
Further, utilization of ENOC’s intellectual property
(if not adequately protected) may affect ENOC’s
competitive advantage. Such intellectual property
includes confidential business information, trade
secrets, patented inventions, processes,
trademarks and copyrighted works.
The entities should ensure that ENOC interests are
protected from any intellectual property infringements.
Reference Document: Guidance Note (Refer Legal
Department for additional guidance)
TRADEMARKS
To pursue its business interests and create a
positive image, ENOC uses a number of brands,
logos and trademarks for its businesses.
Employees should ensure that these are correctly
utilized and depict ENOC brand in a good light.
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Permission in advance should be obtained from
the Brand and Corporate Communications
Management (BCCM) to ensure correct usage in
line with ENOC policies.
Further, the entities should ensure that brands,
logos and trademarks have been registered with
appropriate authorities.
Reference Documents: Brand and Corporate
Communications Management Policies related to Corporate
Communications, Public Relations and Sponsorship
INFORMATION USE AND SECURITY
All entities should use ENOC information
resources for responsible and authorized business
purposes. The information should be shared only
on a “need to know basis”.
Entities should follow “clean desk” policy and all
the confidential information should be kept in a
secured environment. Entities should also be
familiar with and follow pertinent IT policies.
IT users must keep all passwords confidential and are
responsible to report any suspected security violations
to their immediate supervisor / line manager,
Information Technology Department or BE&C.
E-mail systems are not entirely secure and may be
susceptible to interception and caution should be
exercised while sending or receiving mails to / from
unknown sources.
Reference Document: IT Users Code of Conduct
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 CONFIDENTIAL & PROPRIETARY
INFORMATION
CONFIDENTIAL INFORMATION
ENOC’s confidential information refers to
information that is not officially available in public
domain. Information is a valuable corporate asset
and its appropriate dissemination is critical to the
organization’s success.
ENOC’s confidential information is to be used
solely in pursuits of the company’s business
interests and must not be disclosed by any
employee during or subsequent to termination of
the employment relationship.
All requests for any information from a government
body should be brought to the attention of the
immediate supervisor / line manager and no
information should be furnished until appropriate
authorizations have been obtained.
Reference Document: Human Recousres Policy Manual
(Employment Contract-Confidentiality Statement)
PROPRIETARY INFORMATION
Entities are responsible for maintaining the
confidentiality of trade secrets and all other information,
whether intellectual property or otherwise, that is of
technical or commercial value to the company.
Disclosure of confidential or proprietary information
could seriously damage ENOC image and
safeguarding this information is the responsibility of
all employees and representatives.
Employees should be careful not to share information
with others, including other employees, unless they
need to know it for a legitimate business reason that
will not violate any law, regulation, or ENOC policy.
Employees need to guard against unintentionally
disclosing proprietary or confidential information in
situations such as discussions in public or usage
of other insecure communication means for
transmittal of information.
Reference Document: Human Recousres Policy Manual (Employment
PUBLIC STATEMENTS
It is important that ENOC provides the public with Any exception will be decided upon by CEO or the
accurate and consistent information regarding its Brand and Corprorate Communications Manager
operations, when required. according to the best interest of ENOC.
Unless otherwise authorized, employees must not Reference Documents: Brand and Corporate Communications Management
make public statements regarding issues or matters Policies related to Corporate Communications, Public Relations,
about which they are not authorized spokespersons. Spondorships, Donations and Corporate Social Responsibility
All enquiries made by the media and / or similar
parties should be channeled through the Brand
and Corporate Communications Manager who will
then discuss the appropriate response with the
departments or individuals concerned.
The Brand and Corporate Communications
Manager will prepare the release, or the
statement, according to established corporate
rules and policies and liaise directly with the media
organizations involved. Quotes on all aspects of
the business will be attributed directly to the Chief
Executive Officer (CEO) or in some cases to the
Brand and Corprorate Communications Manager.
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Contract-Confidentiality Statement) 29
 TRUST & COMPLIANCE
INTERNATIONAL BUSINESS
ENOC has a global reach. The laws that need to
be adhered to by ENOC or its vendors may differ
by country. All employees involved in ENOC’s
transnational businesses should be familiar with
and adhere to these requirements.
Employees must know and comply with the letter
and spirit of the laws of all countries wherever and
whenever ENOC’s business needs are affected.
Reference Document: Guidance Note (Refer Legal
Department for additional guidance)
ANTI-CORRUPTION COMPLIANCE
ENOC prohibits entities / employees from bribing,
providing facilitation payments or offering, promising, or
authorizing anything of value directly or indirectly in
order to obtain or retain business. Entities / individual
employees can be held liable for such payments.
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Reference Document: Guidance Note (Refer Legal
Department for additional guidance)
GOVERNMENT INVESTIGATIONS
All employees of ENOC are required to fully cooperate
with any appropriate government investigation,
provided ENOC is adequately represented in such
investigation by its own legal counsel.
Any time an employee receives information about
any new non-routine government investigation or
inquiry, this information should be communicated
immediately to BE&C.
Most routine government dealings can be handled
by the employee responsible for such matters.
However, if the employee believes that a routine
audit may evolve into a more formal government
investigation, the BE&C should be contacted.
Employees who fail to cooperate or who obstruct
these investigations are subject to disciplinary
action, up to and including dismissal.
Any government investigation related to EHS
issues should also involve EHSQ department.
Reference Document: Business Ethics Committee Charter
AUDITS (EXTERNAL, INTERNAL
& GOVERNMENT)
Consistent with ENOC internal controls and audit
requirements, its auditors will conduct objective,
independent examinations, taking into account
high level of business ethics, integrity and honest
dealings required of ENOC and its employees.
A strong audit effort helps assure compliance with
established policies, procedures and controls as
well as assists in identifying potential deficiencies
so that they may be promptly corrected.
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 TRUST & COMPLIANCE
False or misleading statements to auditors,
whether internal or external, are totally
unacceptable since full cooperation with auditors
is the responsibility of all employees.
No member of management or any other employee
may interfere with or hinder the audit process.
Reference Document:Internal Audit Charter
(Internal Audit roles and responsibilities)
WHISTLEBLOWING
Whistleblowing is relevant to all organizations as
every corporate entity faces the risk of things going
wrong internally. Where such a risk arises, usually
the first people to realize or suspect the wrongdoing
will be those who work in or with the organization.
ENOC expects its employees to raise the matter
when it is just a concern. The Whistleblowing Policy
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(herein after ‘the policy’) provides a procedure for
recording and addressing whistleblower complaints.
The objective of the policy is to:
Encourage employees to bring ethical and legal
violations they are aware of, to an internal
authority so that action can be taken immediately
to resolve the problem
Minimize the organization’s exposure to the
damage that can occur when employees
circumvent internal mechanisms and controls
Enable staff to raise genuine concerns about
such malpractice at an early stage
Let employees know the organization is serious
about adherence to the Code
Reference Documents: Fraud Management Policy, Business
Ethics Committee Charter and Whistleblowing Policy
FRAUD & THEFT
ENOC employees work hard to utilize and maintain
the assets made available to them. Assets include
money, equipment, technology and information.
These are all highly valuable and are to be
safeguarded and used only to pursue ENOC’s
business objectives. All assets must be protected
against theft, loss or abuse. Protection of ENOC’s
assets is the responsibility of each employee.
All reported incidents to BEC of fraud, theft or other
improper acts will be promptly investigated, and where
appropriate, those responsible will be prosecuted.
Reference Documents: Fraud Management Policy, Business
Ethics Committee Charter and Whistleblowing Policy
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COBC ACKNOWLEDGEMENT HOW TO CONTACT BE&C
To help ensure compliance with this Code of Business Conduct (“the Code”), ENOC requires all its For any suggestions, feedback or complaints,
employees to read the Code and the related polices and periodically acknowledge their understanding please contact the Business Ethics & Compliance
and adherence to the Code. function through an appropriate medium from
those provided below:
EMPLOYEE COMMITMENT TO ENOC CODE OF BUSINESS CONDUCT
ETHICS HOTLINE
I acknowledge that I have received a copy of the Code. I have read and understood the Code and the
related policies and will comply with the same. The Ethics Hotline facility is available for reporting
offenses, complaints, unethical/illegal practices,
If I observe or suspect any non-compliance to the Code, I will contact my supervisor / line manager or any violation of the Code or professional
the Business Ethics & Compliance function immediately. standards etc. The Ethics Hotline number is 800
ENOC ETHIC (800 3662 38442). Details of other
means of communication including fax, email and
Dated: _________________ _______________________________ post are available on COBC Portal.
Signature
(Refer to Introduction To The Code Section for an overview)
ETHICS ENQUIRY
Employees who wish to seek clarity or have any
ethics related questions may forward their enquiry
by email to ethicsenquiry@enoc.com direct.
The process covering the guidelines is available
on COBC Portal.
EMPLOYEE FEEDBACK
Employees may provide their feedback directly to
Business Ethics & Compliance function by email
to businessethics@enoc.com or through the form
available on COBC Portal.

_______________________________ BUSINESS ETHICS COMMITTEE YOUR FEEDBACK IS VALUABLE TO US.

Employee’s Name (Please Print)
The BEC has been established to oversee various
“COBC Acknowledgement Form” is available at the COBC portal and should be submitted electronically. aspects related to the Code. The Committee is
contactable by email at bec@enoc.com.

(Refer to Introduction To The Code Section for an overview)

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Emirates National Oil Company Limited (ENOC) LLC
ENOC House I, P.O. Box: 6442
Dubai, United Arab Emirates
www.enoc.com