Code of conduct

CODE OF CONDUCT

November 2025

1. INTRODUCTION

Rozarya and all its subsidiaries (collectively, "Rozarya") are committed to fair and honest business practices. This Supplier Code of Conduct (“Code of Conduct'') outlines the main principles Rozarya adheres to and expects all its suppliers providing goods or services to Rozarya to comply with. We also believe that it is the responsibility of our direct suppliers to ensure that their subcontractors and suppliers conduct business with the highest ethical and business standards.

Rozarya reserves the right to immediately terminate any and all agreements with any supplier that fails to comply with any of the provisions of this Code of Conduct.

 

2. HUMAN PRINCIPLES

a. Human Rights

Rozarya is committed to upholding universal human rights. Rozarya prohibits the following practices and will not knowingly do business with any individual or company that participates in the following practices:

  • Exploitation of children, including child labour;

  • Physical punishment and all forms of human abuse;

  • Forced or compulsory labour;

  • Unlawful discrimination in employment and occupation.

Rozarya encourages its suppliers to adhere to the principles above.

b. Modern Slavery

Rozarya has a zero-tolerance approach to any form of slavery. We expect our suppliers to comply with the requirements set out in this Code of Conduct related to human and labour rights.

c. Anti-Harassment and Anti-Discrimination

Rozarya strives for its workplace to be inclusive and free of discrimination and harassment based on sex, race, ethnicity, religion or belief, disability, age, gender, ancestry, sexual orientation, disability, veteran status, marriage and civil partnership, pregnancy and maternity, or any other basis prohibited by applicable law. Rozarya suppliers must not discriminate against any of the above.

3. LABOUR PRINCIPLES

a. Child Labour

Rozarya prohibits employment of children in any form. Suppliers shall not employ anyone under the local legal age limit or the age of 15, whichever is greater, to produce goods or perform services for Rozarya. Any employment of minors must be in strict compliance with all applicable laws and regulations.

b. Forced Labour

Rozarya prohibits any form of forced or prison labour. Under no circumstances may Rozarya partners use forced labour or work with any individual or a company that uses forced labour.

c. Working Conditions

Rozarya suppliers must provide and maintain healthy working conditions, in particular ensuring that:

  • Workplaces are kept in clean and safe conditions;

  • Work equipment is provided and maintained in safe conditions;

  • Working places are safe.

d. Wages and Hours

Rozarya suppliers must ensure that their employees are paid in a timely manner in accordance with applicable laws and regulations. Working hours and overtime payment must be set up in full accordance with applicable laws and regulations. Rozarya encourages its suppliers to limit overtime as much as possible.

e. Freedom of Association

Rozarya suppliers shall respect and recognise the right of each employee to bargain collectively in order to create or join a trade union of their choice without incurring any sanctions, discrimination or harassment.

 

4. ENVIRONMENTAL PRINCIPLES

Rozarya suppliers must conduct their business in accordance with applicable laws and regulations related to environment protection. The supplier must ensure to obtain and keep valid the required environmental permits and registrations at all times.

The supplier must recognise that environmental responsibility is important and shall, wherever possible, undertake initiatives to promote greater environmental responsibility and encourage the diffusion of environmentally friendly technologies, implementing sound life-cycle practices and avoiding adverse effects on the community.

We encourage all suppliers to adopt an environmental policy and/or environmental management system, to underpin their work to reduce the environmental impacts of their operations including natural resource consumption, materials sourcing, waste generation, wastewater discharges and air emissions.

 

5. COMPLIANCE PRINCIPLES

a. Laws and Regulations

Rozarya suppliers must always act in compliance with all applicable laws and regulations as well as applicable industry standards.

b. Anti-Bribery, Anti-Corruption and Conflict of Interest

Rozarya suppliers must act in accordance with applicable anti-bribery and anti-corruption laws and regulations, including relevant provisions of the UAE Penal Code (Federal Law No. 31 of 2021) and other anti-corruption laws applicable in the UAE and its free zones. Under no circumstances may suppliers engage in any kind of corrupt practices, whether public or commercial bribery. All suppliers' corporate records must be transparent and accurate.

Rozarya suppliers are expected to disclose to Rozarya any situation that may appear as a conflict of interest, and disclose to Rozarya if any Rozarya representative under contract with Rozarya may have an interest of any kind in the supplier's business or any kind of economic ties with the supplier.

c. Data Privacy and Security

Rozarya requires its suppliers to protect the privacy of individuals and the security of confidential assets and information.

  • Suppliers must protect Rozarya’s confidential assets and information. Suppliers must design and maintain processes to provide appropriate protections for this information.

  • Rozarya requires suppliers to protect personal information in compliance with all applicable local laws, including UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. Personal information provided by or on behalf of Rozarya should only be used, accessed, and disclosed as permitted by the agreement between Rozarya and supplier.

d. Trade Controls

Rozarya suppliers must comply with all applicable laws, statutes, regulations, binding conventions and codes relating to customs, export controls, anti-boycott, and economic and financial sanctions laws and regulations, including economic and financial sanctions and trade embargoes imposed, administered, or enforced from time to time by any United Nations Body, the European Union, any European Union member state, the Ministry of Economy of the UAE, or other competent UAE government authorities.

 

6. OUTSOURCED SERVICE PROVIDERS

Should the supplier act as an outsourced service provider, it must comply with this clause. Suppliers shall establish a reasonable and effective internal controls system. Suppliers must provide services to Rozarya in accordance with the contract(s) concluded with Rozarya, including this Code of Conduct, and applicable regulations.

 

7. COMPLIANCE WITH THE CODE OF CONDUCT

a. Reporting Violations

Should the supplier become aware of any actual or potential violation of this Code of Conduct or any other unethical situation, they are encouraged to report to Rozarya at compliance@rozarya.com (Remember to update this with your final compliance email).

b. Rozarya’s Rights

During the supplier selection and/or certification process, suppliers may be required to complete a self-assessment questionnaire on compliance with the Code of Conduct. Suppliers may be asked to re-affirm compliance with the Code of Conduct periodically. Supplier shall ensure that its subcontractors, if any, comply with the Code of Conduct, and acknowledge that it is responsible for its subcontractors’ violations. In the event of non-compliance with, or violation of, the Code of Conduct, Rozarya may give the Supplier a reasonable opportunity to respond with proposed corrective actions, unless the violation is severe or incurable, or there is a violation of law. Rozarya may suspend or terminate its relationship with the Supplier and/or disclose the matter to the appropriate authorities if there is a violation of law.

c. Changes to the Code of Conduct

Rozarya reserves the right to update or change the Code of Conduct requirements upon notice.