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This Code of Conduct describes the ethical commitments of MIDDLE EAST CLOUD AND DIGITAL TRANSFORMATION COMPANY LIMITED (“CNTXT”). In order to develop a company culture that meets our vision, mission and core values, the Code of Conduct sets out expectations to the personal conduct and business practice of our employees and partners. 


This Code of Conduct applies to all employees (including hired-in personnel), officers and directors in CNTXT (together referred to as “we”, as we are all on one team). Anyone (partners, agents, subcontractors) acting on behalf of CNTXT are expected to adhere to standards that are consistent with this Code of Conduct and applicable laws and regulations. The same applies to suppliers, subcontractors and other contracting parties, and CNTXT shall do its best to ensure such compliance.


We shall all comply with all applicable laws and regulations, and respect cultures and rights of individuals everywhere we operate. If there are differences between laws/regulations and the standards set out in this Code of Conduct, we shall follow the highest standards that are consistent with applicable local laws. This Code of Conduct is the main governing document in CNTXT. If you think someone is violating any of our governance policies or applicable laws or regulations, don’t be bashful - let your manager or other appropriate authority know about it. 


Personal responsibility

We shall all strive to exercise good judgment, care and consideration. Get familiar with, and perform your duties in line with the principles of this Code of Conduct. If you need advice in handling a specific or possible ethical dilemma, or have questions about the Code of Conduct, consult with your manager or other appropriate authority. 

Managers’ responsibility

Managers are responsible for communicating the requirements in the Code of Conduct to all their direct reports, and for promoting and monitoring compliance with the Code of Conduct within their respective area of responsibility. 

Board of Directors and CEO’s Responsibility

CNTXT’s Board of Directors is responsible for implementing the Code of Conduct. The CEO shall ensure that employees are aware of and comply with this Code of Conduct, that annual Code of Conduct training is conducted for employees, and that all employees sign off on that they have read and understood the Code of Conduct.


Act with integrity in the course of your work – follow your moral and ethical convictions, do the right thing even if no one is watching you, be true to yourself and the Code of Conduct, and don’t dishonor yourself or the Code of Conduct.

Conflict of Interest

Conflict of interest is when you have a personal or outside interest that conflicts with the best interest of CNTXT. 

A personal interest can be a financial interest in another company or a transaction, a relationship, including but not limited to immediate family, or any interest or relationship that may improperly affect our judgment and decision-making. 

We are all committed to: 

■ never take action or get involved in relationships that in fact or appearance can give rise to a conflict of interest, and ensure that transactions with related parties adhere to relevant principles for such transactions; 

■ if a conflict of interest arises or something appears to be a conflict of interest, notify your manager; 

■ seek pre-approval from your manager for directorships or assignments held/carried out in other companies; and 

■ never let engagement in duties or assignments outside CNTXT negatively impact our working relationship with CNTXT and always ensure that such activities do not conflict with CNTXT’ business interests.

Corruption and bribery

CNTXT has zero tolerance for all forms of corruption, and we make active efforts to ensure that it does not occur in our business activities. 

Corruption, as defined in CNTXT’s Anti-Corruption Policy, is when a person or organization offers, gives, receives, or solicits something of value for the purpose of influencing - directly or indirectly - officials or private parties for an improper purpose, including to obtain or retain business or any business advantage. 

When engaging with public officials, we must be extra cautious of the corruption risk and act in a transparent manner. We are all committed to: 

■ never, directly or indirectly, offer anything of value to influence the actions or decisions of, or otherwise obtain any improper advantage from: 

  • any official person, including any person in public or legal duty, 
  • any person acting on behalf of customers or subcontractors/suppliers, or 
  • any other third party; in selling goods and services, conducting financial transactions or representing the company’s interests; 

■ never give nor encourage facilitation payments unless an employee is a victim of extortion and his or her health and safety is in danger (such incidents shall immediately be reported to your manager and CNTXT’s CEO or Compliance Officer); and

■ ensure that all payments comply with CNTXT’s accounting and financial procedures for the approval and recording of payments, and that they are submitted to the appropriate level of management. 

■ if you or your colleague end up in a serious situation, report immediately to your manager and CNTXT’s CEO or Compliance Officer.

Gifts and hospitality

CNTXT does not accept the offer or acceptance of business courtesies where they could constitute, or appear to constitute, an undue influence. Hospitality, such as social events, meals or entertainment, may be acceptable for a clear business reason, provided that the cost is reasonable. Local laws may restrict or prohibit offering of gifts and entertainment to public officials. 

We are all committed to: 

■ never offer, promise, give or receive gifts, hospitality or other advantage to or from a public official without specific, written pre-approval from CNTXT’s Compliance Officer; 

■ never, directly or indirectly, accept gifts or other remuneration if there is reason to believe its purpose is to influence business decisions; and 

■ never solicit a gift or favor for personal benefit from any of CNTXT’s stakeholders.

Export Controls and Sanctions

Export controls and economic sanctions laws restrict the sale, shipment, electronic transfer, provision and disclosure of information, software, goods, assets, funds and services across national borders or involving parties subject to economic sanctions. Exports are not limited to traditional shipping methods and include electronically transfer, through discussions or visual inspections.

We are all committed to: 

■ carefully consider potential impact of export control laws and sanctions before transfer of goods, technology, software or services across national borders; and 

■ be cautious if dealing with parties from sanctioned countries or otherwise designated for financial sanctions. 

Fair Competition

CNTXT shall protect fair and open competition and comply with antitrust and competition laws and regulations.

We are all committed to: 

■ meet competition in a professional and transparent manner; 

■ never take part in or support illegal cooperation on pricing, illegal market sharing or any other activity that constitute breach of applicable competition laws; and 

■ consult the Compliance Officer in all matters involving risk of antitrust exposure for CNTXT, yourself, or any of your reports.

Money Laundering

Money laundering occurs when the criminal origin or nature of money or assets is hidden in legitimate business dealings or when legitimate funds are used to support criminal activities. CNTXT is firmly opposed to all forms of money laundering.  

We are all committed to: 

■ seek to prevent that CNTXT’s financial transactions and business activities are used to launder money; 

■ ensure that all business activities are legitimate and involve legitimate funds deriving from legitimate sources; 

■ consult the finance department or the Compliance Officer if there are irregularities relating to payments, such as offshore bank accounts or accounts not normally used by the party in question; and 

■ consult the finance department or the Compliance Officer if in doubt about the origin and destination of money and property.

Safeguarding of IP and Assets

Only authorized employees can use our property and assets, and only for legitimate business purposes. This goes for both tangible property (such as equipment), and intangible property (such as intellectual property and confidential information). Information produced and stored on our IT systems is the property of CNTXT. We shall never process or download information that may be illegal or inappropriate. 

Our intellectual property, such as logos, copyrights, trade secrets, “know-how” and patents are CNTXT’s most valuable assets. Unauthorized use can lead to loss of value. Inappropriate use of others’ intellectual property, including violation of license requirements under which open source software is distributed, may expose CNTXT and you to criminal and civil fines and penalties.  

We are all committed to: 

■ only use CNTXT’s logos and marks for necessary business purposes; 

■ prevent unauthorized use of CNTXT’s intellectual property; 

■ respect others’ intellectual property; 

■ report suspected misuse of trademarks, logos, or other CNTXT intellectual property to the legal department; 

■ consult with the legal department before • authorizing access to or use of CNTXT proprietary information, • soliciting, acceptance or use of proprietary information from outside CNTXT, and • incorporating open source code or other content not belonging to CNTXT into a product, service, or internal project; 

■ use IT systems and particularly internet services carefully, and only for business purposes, not personal interests.

Sensitive Information and Confidentiality

We shall protect sensitive or confidential information, and not misuse information belonging to CNTXT or a partner. 

We are all committed to: 

■ comply with statutory and contractual confidentiality obligations, which may apply as long as the information is considered sensitive or confidential, and after conclusion of the employment or contractual relationships with CNTXT; and 

■ always carefully consider how, where and with whom CNTXT-related matters are discussed.


We shall act responsibly and aim to reduce direct and indirect negative influences on the external environment. We shall follow relevant international and local laws and standards, and seek to minimize our environmental impact.


Accurate and Timely Information and Financial Reporting

CNTXT is committed to providing our stakeholders with quality information that enables them to maintain a correct picture of our financial standing. 

We are committed to: 

■ communicate relevant business information on a timely basis to our stakeholders; and 

■ accurately register and present accounting and financial information, and other disclosure information in accordance with laws, regulations and relevant accounting standards.

Relations to business partners

We are dependent on our partners and shall deal honestly, ethically, impartially and fairly with our stakeholders.


CNTXT may promote its business through sponsors that reflect CNTXT’s values, quality and profile. All sponsorships shall be structured as “win - win situations''. All sponsorships and charitable donations to organizations must be approved by the CEO.


Violation of the Code of Conduct will not be tolerated and may lead to internal disciplinary action, dismissal or criminal prosecution. 

If you have questions about the Code of Conduct, contact the CNTXT Compliance Officer or your manager (for employees). If you are aware or have suspicions concerning unprofessional conduct or breaches of this Code of Conduct, report this to your manager or our Compliance Officer immediately. There will be no retaliation nor any impact on your professional career for reporting violations in good faith. Failure to report is considered a breach of this Code of Conduct.