ETHICS AND COMPLIANCE

Our Code of Ethics is designed to hold SABIC accountable to the highest standards of integrity and to help us comply with the laws and regulations of all countries in which we operate. It is a continual evolving process and we strive to engage in an ongoing dialogue with our workforce, customers, suppliers, investors, community members, and other stakeholders to maintain a framework for conducting business in an ethical manner, addressing risk and mitigating issues and other concerns.

At SABIC, we provide employees regularly updated training manuals, and mandate that every employee is required to complete the in-person or online compliance training that covers specific topics related to their work duties, such as antitrust legislation, fair employment practices, and trade controls. Our employees are encouraged to report any compliance concerns, and to inquire and ask for guidance on any doubts they may have.

SABIC's Chief Compliance Counsel, responsible for managing the implementation of the compliance program, regularly reports to the Audit Committee of the Board on all progress at the program level, risks, and any other significant results. In addition, we keep our reporting channels available to external stakeholders such as customers, suppliers, and community members.

SABIC closely works with external organizations specializing in important compliance issues in order to keep our company up to date with the latest regulatory developments, learn best practices, adopt a broader perspective, and even act collectively to drive change. Since 2013, SABIC has participated in the annual G20/B20 policy process on anti-corruption. In 2022, we were part of the Indonesian B20 Integrity and Compliance Task Force. In the Middle East, we are part of an organization called the Pearl Initiative– a group for Gulf-based companies to share best practices on compliance and good governance. These partnerships enable us to learn about pioneering efforts undertaken at other companies and allow us to share our best practices with others.

Developing compliance capacity matters to our customers, suppliers, and other third parties. They wish to have visibility across the entire supply chain to ensure that it is free from corruption, forced labor, child labor, environmental violations, and other unsustainable practices. In 2021, SABIC launched a wide-ranging training program for third-party business partners including suppliers, distributors and contract/temporary workers. Through this online, local-language training, we are able to ensure that our third parties have a grounding in the compliance concepts that we adhere to.

COMPLIANCE INVESTIGATION DATA

In 2022, we investigated 136 Code of Ethics policy concerns, of which 42 were concluded to have violations. Accordingly, 73 associated corrective actions were taken.

* Assured by KPMG

COMPLIANCE TRAINING DATA (AS OF JANUARY 1, 2023)*

These internal and external efforts benefit us in many ways, including through independent recognition. SABIC retained Ethisphere’s Compliance Leader Verification™ status through 2024. The Compliance Leader Verification process examines in detail every aspect of a company’s program, including ethics and compliance program structure and oversight, training and communication, risk measurement, monitoring for misconduct, disciplinary measures, ethical corporate culture, and employee perceptions. The rigorous review process and verification indicates that our compliance efforts are widely recognized to assure our stakeholders.

SCREENING FOR SANCTIONS

SABIC’s International Trade Controls Policy ensures that all transactions are screened against restrictions on sanctioned countries, persons, and prohibited end uses. Transactions are prohibited with entities subject to sanctions administered by the United Nations, the European Commission, UK's HM Treasury, United States Department of Treasury Office of Foreign Assets Controls, Japan’s Ministry of Economy, Trade, and Industry, and others.

REPORTING CONCERNS

In-person, online, and telephone channels are available for employees, suppliers, customers, and other stakeholders, including community members and civil society to report any violations of regulations or ethics.

ANTI-BRIBERY TRAINING

Under our leadership of the Saudi B20 Integrity and Compliance Task Force, an anti-bribery training and mentorship program was initiated for entrepreneurs and those working in small and medium-sized enterprises. The program gained significant attention from numerous organizations that work against corruption, including the OECD, UN Development Program, and the World Bank Group. These organizations are taking this program forward amongst their constituencies.

OUR ESG AND SUSTAINABILITY GOVERNANCE