CODE OF ETHICS & BUSINESS CONDUCT

Sapphire Fibres Limited (Sapphire Fibres) conducts its operations with honesty, integrity, openness and fair play, strong commitment to high standards of ethical, moral and lawfully. These are among the most important traditions of the company and critical to meet our commitment to our shareholders, customers, suppliers and employees. Ethical behavior is an individual responsibility. Behavior reflecting high ethical standards is expected of all executives and employees regardless of their position or location.

Our businesses and customs vary, and each individual who works for the Group is unique, however, we have certain standards and responsibilities to share wherever we do business. Similarly Sapphire Fibres respect the legitimate interest of those with whom we have relationships.

The Code sets forth the Company’s policies and practices relating to legal compliance and business ethics. It reflects the Company’s core values and high ethical standards. Every director, officer and employee is responsible for reading and understanding this Code and for conducting business on behalf of the Company in accordance with the policies and practices herein.

MANAGEMENT COMMITMENT FOR ETHICS

All the Company employees are accountable for their own actions as well as the conduct of employees who are within their span of control. The Company employees are responsible for seeing that the Code and other Company policies, including applicable laws are followed.
They must:

Make a personal commitment to operate in accordance with the highest standard of ethical business conduct, and communicate commitment to others.
Ensure that the employees reporting to them receive appropriate compliance and ethics training.
Maintain a work environment that is respectful and one that encourages open communication regarding ethical problems and concerns.
Periodically discuss ethical issues and review the Code with employees and third parties reporting to them.
Avoid hiring individuals who have the propensity to violate law or rules of the type embodied in the Code.
Avoid retaining employees who perpetually violate Company policy, applicable laws and /or engage in or promote moral turpitude.

MANAGERIAL RESPONSIBILITIES

Managers are expected to set the highest standards of ethical business conduct and encourage to discuss the ethical and legal implications of business decisions. It is their responsibility to create and sustain work environment in which employees, consultants and contract workers know that ethical and legal behavior is expected of them.
Managers must be diligent in looking for indications that unethical or illegal conduct has occurred, and take appropriate and consistent action to address any situations that seem to be in conflict with the law or the Code.

EMPLOYEE COMMITMENT TO ETHICS

The Code sets forth the Company’s policies and practices relating to legal compliance and business ethics. It reflects the Company’s core values and high ethical standards. Every director, officer and employee is responsible for reading and understanding this Code and for conducting business on behalf of the Company in accordance with the policies and practices herein.

OBEYING THE COMPANY CODE, POLICIES AND OTHER APPLICABLE LAWS

Sapphire Fibres will respect the rule of law of Pakistan and other countries in which we operate. Obeying the law, both in letter and in spirit, is the foundation on which the Company’s ethical standards are built. In conducting the business ethics of the Company, the covered parties shall comply with the Code, other Company policies and all applicable laws and regulations in Pakistan and outside Pakistan’s jurisdiction in which the Company does business. Although all covered parties are expected to know the details of these laws, it is important to know enough about the applicable laws to determine when to seek advice from supervisors, managers or other appropriate personnel.

CONFIDENTIALITY

We must protect this confidential information that is generally NOT known to the public and, if improperly disclosed may be harmful to the Company or its customers or suppliers, or helpful to its competitors.
Information is only protected if it is confidential and is not publicly available or if the public would have difficulty in acquiring the information except by unlawful means.

COFLICT OF INTEREST

Sapphire Fibres employees will avoid situations where loyalty to the company may come into conflict with personal interest or loyalties. They must not seek gain for themselves or others through misuse of their positions.
If such a conflict does arise, it should be declared in writing to senior management who must make sure that the individual is insulated from any decision making or operation in the area of conflict of interest

PROTECTING COMPANY ASSETS

We are personally responsible and accountable for the proper expenditure of Company funds, including money spent as travel expenses or for customer entertainment. We are also responsible for the proper use of Company assets over which we have control including assets that customers or others have entrusted in our custody. Company assets must be used for proper purposes. This includes both during and after working hours and by third parties involved with the Company. Company assets should not be used for personal benefit, sold, loaned, given away or otherwise disposed off regardless of condition or value, without proper authorization.
We must not provide the Company’s files or documents of any kind to anyone without any prior, specific authorization from a supervisor. It is our obligation to protect Company’s Proprietary information which includes intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, databases, records, salary information and any unpublished financial data and reports. Any act by Company’s employee that involves theft, fraud, embezzlement, or misappropriation of any property/asset is prohibited.

FAVORS AND BENEFITS

Employee should never allow himself to be in a position whereby he/she might be deemed by others to have been influenced in making business decisions as a consequence of accepting a gift or hospitality.
Employees shall not provide or offer to provide any favors or benefits to government departments or engage in any activities which could influence the business decisions and violate the law. Offering or providing bribes or kickbacks is prohibited in all circumstances.
An employee may not furnish or offer to furnish any gifts, entertainment, meals, compensation, credits or anything of value to a person who has business dealings with the Company (suppliers, purchasers and competitors) until authorized by the supervisor.

COMPETITIVE INFORMATION

Sapphire Fibres believes in fair competition. Sapphire Fibres must never use any illegal nor unethical methods to gather competitive information. Sapphire Fibres and its employees will conduct their operations in accordance with the principles of fair competition and all applicable regulations.

BUSINESS CONDUCT

CUSTOMERS

A primary objective of the Company is to become the customers most valued supplier. We provide products and services that aim to delight our customers and in doing so we aim to provide a lasting relationship of cooperation and trust.
Labeling of products will be complete, fair and honest. Only claims which can be substantiated and fulfilled are made by the company, its employees and its agent.

SHAREHOLDERS

Sapphire Fibres will conduct its operations in accordance with principles of good corporate governance. Sapphire Fibres will provide timely, regular and reliable information on its activities, structure, financial situation and performance to all the shareholders. Shareholders are informed about significant and material violations of corporate policies (including codes of conduct) and any adverse decisions by tribunals or courts.

EMPLOYEES

Sapphire Fibres is committed to create the working environment where there is mutual trust and where everyone feels responsible for the performance and reputation of the Company.
Sapphire Fibres will recruit, employ and promote employees on the sole basis of the qualifications and abilities needed for the work to be performed.
Sapphire Fibres is committed to safe and healthy working conditions for all employees.
Sapphire Fibres is committed to working with employees to develop and enhance each individual’s skills and capabilities.
Sapphire Fibres respects the dignity of the individual and the right of employees to freedom of association.
Sapphire Fibres will maintain good communications with employees through company based information and consultation procedures.
Sapphire Fibres recognizes the need for supporting and/or providing the essential social infrastructure and community services to its workers.

BUSINESS PARTNERS

Sapphire Fibres is committed to establishing mutually beneficial relations with its suppliers, customers and business partners.
In its business dealings it expect its partners to adhere to business principles consistent with its own.
The Company is careful in its negotiations and contractual arrangements with other companies. This includes fair dealing, prompt payment and the avoidance of corrupt practices, bribes and questionable payment.
The Company seeks out supplies who meet the same standards on environmental and social grounds as the group sets for its own products.

ACCURACY OF BUSINESS RECORDS

All reporting of information should be accurate, honest and timely and should be a fair representation of the facts. No false, artificial or misleading entries in the books and records of bank shall be made for any reason.
Employees throughout the group are responsible for properly, honestly and accurately recording any kinds of information. No information will be manipulated or deliberately withheld by any employee to show a falsified picture of the situation. All reporting will be based on regular compliance and policies of the Sapphire Fibres.

WAGES, BENEFITS AND WORKING HOURS

We ensure that wages and social benefits are in accordance with laws in force or prevailing wage practice in the country. The working hours are followed in accordance with local standards at all the Plants and offices of the Company.

COMMUNITY INVOLVEMENT

Sapphire Fibres strives to be a trusted corporate citizen and, as an integral part of society, to fulfill its responsibilities to the societies and communities in which it operates.

PUBLIC ACTIVITIES

Sapphire Fibres is encouraged to promote and defend its legitimate business interests.
It will co-operate with government and other organizations, both directly and through bodies such as trade associations, in the development of proposed legislation and other regulations, which may affect legitimate business interests.

HEALTH, SAFETY AND ENVIRONMENT

Sapphire Fibres is committed to making continuous improvements in the management of environmental impact and to the longer-term goal of developing a sustainable business. The Company is committed to ensuring the wellbeing of its workers, the people living and working in our communities near our facilities and the environment and will provide the human, physical and financial resources necessary to meet this commitment
It will work in partnership with others to promote environmental care, increase understanding of environmental issues and disseminate good practice.
Each employee is responsible for observing the safety and health rules and practices that apply to his or her job. Employees are also responsible for taking precautions necessary to protect themselves and their co-workers, including immediately reporting accidents, injuries, and unsafe practices or conditions. Appropriate and timely action will be taken to correct known unsafe conditions.

COMPLIANCE-MONITORING-REPORTING

Compliance with business principles is an essential element in business success. The Board of Directors of Sapphire Fibres is responsible for ensuring that these principles are communicated to, and understood and observed by, all employees.
Day-to-day responsibility is delegated to the senior management. They are responsible for implementing these principles.
Assurance of compliance is given and monitored each year. Compliance with the Code is subject to review by the Board supported by Audit Committee or the Board.
Any breach of the Code must be reported in accordance with the procedures specified by the management.
The Board of Sapphire Fibres expects employees to bring to their attention or to that of senior management, any breach or suspected breach of these principles.

CHILD LABOR

The Company discourages and prohibits the use of child labour. In this regard, we respect and follow all the prevailing labor laws relating to Child Labor in our country.
We encourage the development of workplace apprenticeship programmes for the educational benefit of young people.