Code of Conduct

Code of Conduct for Directors and Senior Management pursuant to Clause 49 of the listing agreement

SM Energy Teknik & Electronics Ltd’s commitment to ethical and lawful business conduct fundamentally shares value of the Board of Directors, the senior management and all other employees of the Company.

Consistent with its Values and Beliefs, SM Energy Teknik & Electronics Ltd has formulated the following code of Conduct as a guide. The Code does not attempt to be comprehensive or cover all possible situations. It encourages the SM Energy Teknik & Electronics Ltd’s team to take positive actions, which not only commensurate with the Values and Beliefs, but also perceive to be so. SM Energy Teknik & Electronics Ltd expects all its employees to implement the Code in its true spirit and in case of any doubt or confusion, to consult his/her immediate superior, the head of HR or the Executive CMD as relevant.

For the purposes of this Code, the term “senior management” shall mean

(a) Executives who are in the grade of General Manager and above;
(b) All executives directly reporting to the Executive CMD and
(c) Company Secretary

In performing their functions, the directors and senior management of the Company shall:

Act honestly, diligently and in good faith with integrity in all their dealings with and for the Company.

Not use any confidential information obtained by them in the course of their official duty, whether from the Company, or otherwise, for personal gain, or use/allow the use of such information for the financial benefit for any other person.

Not engage in any business, relationship or activity, which might detrimentally conflict with the interest of the Company.