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Sawary Energy has been providing innovative, comprehensive power solutions to businesses and residents across the Kingdom of Saudi Arabia since 1975. In the many years that we have been servicing our community, we have been the company that government, industries, businesses, and homes rely on to deliver an essential utility needed to forge a bright future and live a productive and enjoyable life – electric power!

However, Sawary Energy does not only stand for excellence and reliability in product and service quality. We are equally dedicated to maintaining the highest standards of integrity, and environmental and social responsibility wherever and whenever we perform our duties.

Being a good corporate citizen requires that we do what is right. Sawary and all of its directors, officers, and employees commit to exemplary handling of the principles in this Code of Conduct.

Our clients, business partners and stakeholders value us for the way we do business. By building on our strong legacy and always acting with integrity, we contribute to a successful future for our company, everyone we do business with and the society.

Place and date: Jeddah, April 22, 2019

Ayman Hegab

Director of Operation

Sawary Trading and Contracting Co. Ltd
Mohammed Al Sulaiman

Chairman of the Board




  • Communications
  • Respecting Privacy
  • Employment Practices
  • Health, Safety and Environment
  • Bribery and Corruption
  • Entertainment, Favors, and Gifts
  • Lobbying and political contributions
  • Conflicts of Interest Integrity
  • Money Laundering and Terrorist Financing
  • Competition and Markets
  • Use of Company Assets
  • Insider Information and Insider Trading
  • Observance of Our Code of Conduct
  • Reporting of Violations and Protection from Retaliation
  • Issuance of the Code of Conduct
  • Application of the Code of Conduct
  • Definitions
  • Applicable laws and regulations



This Code of Conduct is provided as a guidance document for every director, officer, employee, agent or representative of Sawary Trading and Contracting Co. Ltd (in this document referred to as ‘Sawary’).

Sawary and its employees are committed to respect and comply with the laws and regulations that are applicable to Sawary and its activities, as laid out in the chapter GENERAL INFORMATION.

In addition, fairness, honesty, respect and trust are inherent in our core values and are given in the Holy Qur’an (28,26; 22,23; 31.17-19).

Sawary requires candor and honesty from its directors, officers and employees to assure compliance with these rules. For all of us, as employees, the basic requirement is that we conduct ourselves in a responsible manner. One of our most important assets is our integrity. All employees, officers and directors of Sawary are to discharge their duties and responsibilities in a manner consistent with the principles laid out in this Code of Conduct, and consistent with all Applicable Laws of any country in which they perform work on behalf of Sawary (the “Applicable Laws).

It is the obligation of every employee who can be exposed to any of the areas covered by the Applicable Laws to understand the general requirements of this Code of Conduct. Our managers ensure that the rules are known and adhered to in the working environment. They inform their employees about the meaning of this Code, the importance of correct behavior and the consequences of in case of breach of the rules as formulated in this Code.

Our Code of Conduct has been adopted by Sawary’s Board of Directors and is binding for all employees. It incorporates our basic standards of ethical behavior. It makes employees aware of critical issues, which require consideration, caution or guidance from other colleagues.

The Code of Conduct is also designed as a guidance to help prevent and detect violations of Sawary policies and the Applicable Laws.

Ethical behavior is not always easy to define, and the Code of Conduct does not have answers for every situation that employees may face. Our goal is that the Code assists employees, particularly in dilemma situations, to always act ethically. Employees who have concerns or questions, or who are unsure how to respond in a particular situation, are invited to seek appropriate advice from Human Resources, their superiors, or the Chief Compliance Officer.



Sawary shall maintain the highest ethical standards in the conduct of its business; it shall fulfil its legal requirements and conduct business with strict regard for what is right and appropriate; it shall be honest and straightforward in all of its dealings; and it should avoid all situations that might give even the appearance of being unethical or illegal.

In reading this Code of Conduct, we keep in mind the following:

  1. Ethical behavior and compliance with the Applicable Laws are conditions of employment. Violations of the Code of Conduct, other Sawary Trading and Contracting Co. Ltd. Policies, or the Applicable Laws will result in appropriate disciplinary action, and if serious, termination in accordance with the provisions of the Saudi Labor Law.
  2. Violating the law or this Code of Conduct is never the right choice. If an employee suspects that an action is wrong but nevertheless pursues that action because he believes that the revenue, profit or any other intended benefit outweighs corporate policy or the Applicable Laws, then they will be subject to disciplinary measures.
  3. Please take the time to read and understand this Code of Conduct. In case you have any questions, please ask your supervisor. Existing and new employees are required to sign a statement that they have read, understood and will comply with the Code of Conduct
  4. We will not conduct business where we cannot do it in an ethical way. This applies to relationships with employees, customers, contractors, government representatives, partners and vendors.
  5. Sawary is committed to the principles expressed in this Code. We must all work together to maintain our reputation and corporate and personal integrity. All employees are expected to act in the best interests of Sawary and to promote our company’s good name and reputation.

The laws and regulations applicable to the matters addressed in this Code of Conduct can at times seem complex. Sawary encourages you to seek appropriate advice if you have any doubt concerning the lawfulness or appropriateness of any action.


Sawary is committed to conducting its business in an open, transparent and honest manner. All communications, whether internal or external, should be accurate and forthright. These communications may include, but are not limited to, general internal reports and memoranda, advertising, media broadcasts, marketing, sales brochures, e-mail and social media such as Twitter, Facebook and the like.

Sawary has rules with respect to the use of its electronic communications systems. Employees are expected to be familiar with these rules and shall observe all such Policies and Directives. When in doubt, seek clarification from your supervisor.

Sawary will provide accurate and consistent information when promoting its products and services, or any other corporate information disclosed to the outside. Misleading, false or exaggerated claims concerning our products and services, or those of our competitors, are unacceptable. These same principles must be adhered to when responding to inquiries from customers, fellow employees, the media, regulatory agencies, and stockholders.

Relations with the media and public institutions are the sole task of the communications departments and the responsible management.

We are all asked to think before communicating. A poorly thought-through communication may be misinterpreted and what is written or said cannot be taken back. Any statement, whether oral or written, that is false, derogatory, malicious or defamatory of any other person, and in particular, our competitors, will not be tolerated.


Respecting Privacy

Personnel information and records (for example relating to confidential customer data, employee’s health records, or social security information) are treated with respect and confidentially. We will only collect, use, and disclose employee information on a business need-to-know basis or if required to do so by a law, regulation or order of a court or any other entitled authority. We apply this policy of confidentiality to former employees as well. We familiarize ourselves and comply with applicable regulation. Due to the importance of international relationships in our business, this extends also to the new EU law on data protection and privacy (General Data Protection Regulation) and other applicable data privacy legislation in other countries where we do business.

Employment Practices

Our employees are our most important asset. The value of this asset is reflected in the ability, integrity, knowledge, and talent of our employees. We will:

  1. Provide an environment where employees are well informed and follow this Code of Conduct and act with fairness, honesty, integrity and professionalism in the performance of their functions and in all of their business relationships.
  2. Keep in mind that treating each other with respect and professionalism is not just good business – it’s the law.
  3. Provide equal opportunity for all in recruiting, hiring, developing, promoting and compensating in accordance with the law and the customs and traditions of the Kingdom of Saudi Arabia. Sawary will implement the Kingdom’s employment policies with respect to Saudization, the employment of women, and those other matters mentioned in the Saudi Labor Law or ministerial directives. When operating in other countries, Sawary will obey and respect applicable local employment laws and policies.
  4. Guided by our values and beliefs and in accordance with applicable law, assume responsibility for respecting human rights wherever and whenever we operate. We fully subscribe to the principle that every human being has the right to be treated with dignity, fairness and respect. In particular, Sawary does not tolerate directly or indirectly any form of child or forced labor.
  5. Maintain a professional, safe, and discrimination-free work environment. Mutual respect is the absolute minimum of behavior expected from everyone.
  6. Promote employees on the basis of their ability, achievements, experience and performance.
  7. Prohibit harassment. Sexual harassment of any kind, whether the harasser or the victim is a co-worker, supervisor, agent, customer, guest, or vendor is prohibited.
  8. Provide an environment that is conducive to productivity and personal growth and encourage employees to participate in civic engagement.
  9. Investigate complaints of violations of Sawary Code of Conduct, corporate policy or applicable laws. Retaliation against anyone who has made a complaint is prohibited. Ahmad N AlBinali Holding Co. will remedy a situation where a violation of Sawary policy or applicable law has occurred.

If an employee believes that he has experienced, learned, of or witnessed harassment, they must notify a Human Resources representative or supervisor as soon as possible. The laws affecting employment practices are complex and constantly evolving. Therefore, it is critical that each supervisor maintain awareness of Sawary’s employment policies by seeking appropriate advice from Human Resources or the Chief Compliance Officer.

Health, Safety and Environment

We will conduct our business in a manner that avoids harm to people and respects the environment. We ensure compliance with all applicable health, safety and environmental laws and regulations. This commitment extends to initiatives undertaken to reduce and eliminate injuries in the workplace and the prevention of pollution.

We will communicate our environmental commitment to the communities where we operate, to our customers, stakeholders and the general public. We will maintain a systematic



environmental management process, which implements pollution prevention measures to avoid the release of hazardous substances into the environment.

We also deliver products and services that help our customers achieve improved energy and process efficiency and thus contribute to their own sustainability ambitions.

Occupational safety and environmental protection is a condition of employment. Management ensures that employees are properly informed and trained to execute their duties in a responsible and safe manner. Sawary is responsible for providing a safe workplace, and all employees are responsible for following safety practices and procedures to ensure their own safety and the safety of those around them. No deviations from Sawary Trading and Contracting Co. Ltd. safety practices or procedures are permitted without the approval of the appropriate Sawary personnel or government regulatory agency. The disposal of waste in violation of law or the concealment, destruction, or falsification of records is strictly prohibited.



Bribery and Corruption

Sawary and its employees, officers, directors, and agents, are prohibited from promising, soliciting, offering, or accepting anything of value, either directly or indirectly to or from a government official or any other person with the intention to improperly obtain a business or any other advantage for Sawary or for oneself.

Prohibited acts include, but are not limited to, bribes, illegitimate favors, collusion, pressures, either directly or through third parties (e.g. intermediaries, agents, consultants), or the request of benefits for Sawary, oneself or others.

Sawary also prohibits facilitation payments. A facilitation payment is defined as a small payment to a low-level government employee to expedite or secure performance of a routine, nondiscretionary governmental action, such as obtaining utility services or clearing customs. Facilitation payments are never permitted for purposes of influencing a discretionary action or to obtain business.

The provisions of the Saudi Combating Bribery Law (CBL) prohibit a Public Official from accepting, receiving or soliciting bribes to:

  • Perform any of the duties associated with his position;
  • Violate any of the duties associated with his position;
  • Receive remuneration for his actions; or
  • Confer on the briber any act, matter, decision, obligation, contract, license, supply agreement, job service or any other benefit or advantage.

The prohibition applies regardless of the Public Official’s intention not to perform the act associated with the bribe.

The CBL defines a “Public Official” as:

  • A person employed by the government or any public administrative authority, regardless of whether permanent or temporary;
  • An arbitrator or expert appointed by the government or any judicial body;
  • A person assigned by a government authority to perform a specific assignment;
  • A person employed by a company that manages or operates a public facility or performs a public service, or employed by a joint-stock company or company in which the government has a holding, as well as a company carrying out banking operations; or
  • A chairman or director of a company provided for in the preceding bullet point.


Other applicable laws include in the definition of a public or government official also representatives and employees of sovereign wealth funds; public international organizations, such as the United Nations or World Bank; and foreign political parties as well as candidates for public office.

A “Bribe” is anything of value, e.g. a tangible benefit or privilege, promise or gift and may include, but is not limited to:

  • Money;
  • Property or investments;
  • Gifts
  • Travel, hospitality and entertainment;
  • A paid or unpaid internship;
  • Discounts on products and services;
  • Offer of employment for a Public Official or a relative of the Public Official;
  • A promise to pay;
  • Assumption or forgiveness of debt;
  • The payment or reimbursement of travel expenses; o
  • Personal favors.

If an employee of Sawary is confronted with a demand for a bribe from anyone, the demand must be reported immediately to Sawary’s Chief Compliance Officer.

Entertainment, Favors, and Gifts

We are committed to the development of durable and long-term relationships with customers, communities in which we operate, stakeholders, and vendors. Our integrity and good name is fundamental to the creation of such relationships.

Offering occasional gifts, entertainment, or hospitality occurs in the normal course of business. However, we never use these as ways to influence decisions or to obtain an improper advantage from a public official or other business partners. All gifts and hospitality must be related to a justifiable business purpose and be within the bounds of good taste. They must also be modest, appropriate in a given context, infrequent, and be accurately recorded as such.

Sawary employees are prohibited from accepting gifts from third parties beyond token gifts (e.g. small give-aways branded with the logo of the company). The exchange of occasional social amenities (i.e. business lunches, dinners or entertainment) between employees and third parties is acceptable when reasonable. In all cases, the appearance of impropriety must be avoided.

Lobbying and political contributions

While Sawary may occasionally represent its interests and promote an enhanced dialogue with stakeholders in a broader sense, it does and will not engage in lobbying activities or make any kind of political contributions.

Conflicts of Interest

Officers of Sawary are to set an example of the highest ethical conduct, both in appearance and in fact. Sawary requires that its officers, employees (including temporary and loaned employees), and directors avoid situations in which their personal interests might conflict with the interests of Sawary, its subsidiaries, or affiliates.

Such conflicts of interest could potentially arise if officers, employees or directors have direct or indirect economic or financial interest or influence in Sawary’s dealings with contractors, vendors and any other companies, organizations or individuals doing or seeking to do business with Sawary, or in competition with Sawary. In particular, employees and directors


shall avoid conflicts of interest between personal and family economic activities and their tasks within Sawary, including without limitation when selecting vendors and contractors.

For example, Sawary employees shall not:

  1. Participate in a business transaction involving Sawary without disclosing his own participation or the participation of a family member or relative to Sawary.
  2. Use confidential or proprietary information owned by Sawary including patents, trademarks, or unpublished information for personal gain.
  3. Supervise another family member, romantic interest, or relative where the supervisor has discretionary authority regarding assignments, compensation and promotions.
  4. Have a direct or indirect financial interest in any vendor or competitor whether the employee has the ability to influence a decision with respect to Sawary’s business, or where the vendor or competitor is owned, managed or controlled by a family member, relative, or close friend.
  5. Conduct personal business on Sawary time or using Sawary facilities and equipment without the explicit prior consent from the Board.
  6. Own an undisclosed 5% or more interest in a publicly traded company.

These examples are non-exclusive. Conflicts of interest usually can be avoided where there is full disclosure. Any employee having any doubts as to whether a particular set of circumstances constitutes an impermissible conflict of interest should seek appropriate advice and clearance from his supervisor.

To this end, employees and directors must not engage in or give the appearance of engaging in any activity involving a conflict or a reasonably foreseeable conflict between personal interests and those of Sawary. There must be no divided allegiances. Outside employment or outside business involvement by a Sawary employee must be made known by the employee to his supervisor.

Sometimes, perception is reality. We attach as much significance to our employees’ avoidance of the appearance of impropriety as we do to actual conflicts of interest as perceptions can be just as damaging to Sawary as a real conflict of interest. In all situations, including those where there are no clear legal constraints, Sawary business shall be conducted in such a manner that neither Sawary nor any of its directors, officers, or employees would be embarrassed or open to legal liability if the full facts were disclosed.

We may periodically ask employees to submit a formal declaration concerning possible conflicts of interest. Providing timely, candid responses in such declarations is a condition of employment.

Financial Integrity

Information transparency is an essential principle to which Sawary, its employees, officers and directors are firmly committed. Sawary and the public rely on the accuracy of our accounting records and financial reporting. The books and records of Sawary shall be kept in a complete and accurate manner, one that fairly reflects the activities of Sawary. This applies to all transactions, whether large or small. The preparation of expense reports and time sheets, the posting of sales and marketing data, logging expenses in connection with gifts, entertainment and hospitality, as well as the recording of significant capital improvements or investments all require the same degree of detail, accuracy and transparency. Any willful omission or falsification of Sawary records will be regarded as a serious violation of Sawary policy. The principle of transparent and accurate information shall also apply to internal communications. Under no circumstances shall the information that is provided internally be deliberately incorrect, inaccurate, or lead to confusion to those receiving such information.

Money Laundering and Terrorist Financing

Money laundering refers to financial or legal transactions in which money obtained or generated by unlawful activity is disguised by infiltrating the legal circuit of finance and business in order


to hide the money’s origin. Money laundering is a punishable offense in almost all countries, including Saudi Arabia that established its Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) regime with the issuance of the Anti-Money Laundering Statute in 2003 and its Implementing Regulations in 2005.

Sawary only accepts money from legal sources. Employees are to obtain detailed information about the background of the business partner and the purpose of the intended business before a business transaction will be confirmed. In case of doubt and if irregularities are suspected, employees shall contact their superiors or the Chief Compliance Officer of Sawary.

Competition and Markets

Competitive markets are important because they enable economic prosperity and contribute to social balance. To ensure markets operate in a fair and transparent way, many countries, including Saudi Arabia, have introduced laws prohibiting anti-competitive practices.

Sawary is committed to follow applicable Competition Regulation and does not engage in any activities that could reasonably be construed as being unlawful, anti-competitive, abusive or unfair (e.g. exchanging data and information with competitors, or dividing up or allocating customers).

Sawary is also aware of and follows applicable trade sanction or export laws and regulations that prohibit or restrict doing business with certain countries, entities or individuals.

Use of Company Assets

Employees shall protect and preserve Sawary’s company assets and resources and help to manage costs. Company assets include such things as electronic mail, computer systems, documents, equipment, facilities, information, Sawary’s logo and name as well as material and other supplies.

The use of Sawary assets and resources for personal, community or charitable endeavors requires express written authorization from your supervisor.

Any use of corporate assets for purposes other than Sawary’s business is prohibited. Sawary forbids the use or disclosure of any confidential, proprietary, or trade secret information which belongs to other individuals or entities, including that which comes to you or Sawary through legitimate channels, a previous employer, competitor or vendor, unless authorized to do so in writing by the owner of the information.

All employees are required to respect Sawary ‘s confidential information, proprietary information, intellectual assets and trade secrets. Such can include inventions, patents, copyrights, business, financial, technical or research information, software and computer programs, product designs, manufacturing expertise, customer information or information relating to Sawary strategy.

Some examples of misuse of company assets include, without limitation:

  1. Taking office supplies or equipment home for personal use; including using Sawary equipment to repair personal property;
  2. Personal use of Sawary vehicles without express authorization;
  3. Unauthorized copying of computer software programs; or
  4. Using Sawary -issued credit cards for personal purchases.

Insider Information and Insider Trading

Company policy, the Capital Markets Authority, and regulators in other jurisdictions establish strict guidelines for the use of Inside Information by employees, officers and directors. Inside Information is material knowledge of Sawary or other business information that is not generally available to the public and can have a significant impact should it be disclosed. Material information is information that a reasonable investor, business partner or other



external party would consider important when making a decision to trade with stocks or other securities.

Insider trading is the trading of a publicly listed company’s stock or securities by individuals who have access to insider information about a company. In most countries, trading based on insider information is illegal because it provides the insider with an unfair advantage.

Sawary confidential and proprietary business information shall be safeguarded and utilized only in keeping with the best interests of Sawary, its obligations to third parties, and the highest ethical and legal standards. Such information shall not be disclosed to third parties without prior approval of a duly authorized officer of Sawary. Employees, officers, and directors shall not make any inappropriate or fraudulent use of this information and must not benefit from any opportunity of obtaining any personal benefit based on the knowledge acquired in the performance of their professional duties. Likewise, employees, officers and directors will not disclose any personal data obtained from contractors, vendors, employees or public administration. The trust and confidentiality that these groups have placed in Sawary must be respected and guaranteed at all times.

Sawary requires all employees to strictly observe the following requirements:

  • All information about Sawary not generally available to the public must be treated as confidential.
  • Employees receiving or having access to inside information are prohibited from trading Sawary shares.
  • Employees must not disclose inside information to spouses, relatives, friends or business associates.
  • Employees who in the course of their employment may have obtained inside Information about other companies are prohibited from trading in shares of such companies.



Observance of Our Code of Conduct

We expect everyone to observe the letter and the spirit of the Code of Conduct. Any employee who violates our Code of Conduct, Sawary Trading and Contracting Co. Ltd. policies and procedures or the Applicable Laws, actively permits or passively tolerates a subordinate to do so, will be subject to disciplinary action up to and including termination. Disciplinary action for violations will be applied consistently and fairly throughout Sawary Trading and Contracting Co. Ltd.

Reporting of Violations and Protection from Retaliation

Any violation of this Code of Conduct could cause harm to Sawary and can lead to serious personal and corporate risks and liabilities. For these reasons, employees are encouraged to promptly report any concerns or problems or any actual or suspected violations of our Code of Conduct to Sawary ‘s Chief Compliance Officer.

The decision to report a concern or problem is not always an easy one. Nonetheless, Sawary encourages employees to discuss their concerns and seek assistance, irrespective of the nature of the problem or how insignificant the problem may appear.

Sawary wants to ensure that employees seeking advice will receive prompt guidance before the fact, i.e., prior to engaging in conduct that may be in violation of the law or this Code of Conduct.

No employee shall suffer retaliation in any form for reporting suspected violations of this Code of Conduct in good faith. Disciplinary action will be taken against anyone who retaliates directly or indirectly against any employee who reports an actual or suspected violation of Sawary’s


policies or Code of Conduct. This applies even in those instances where the allegation ultimately proves groundless, provided that the allegation was made in good faith.

Any employee who knowingly reports false or misleading information will however, be subject to disciplinary action.

Sawary will make every effort to safeguard the confidentiality of statements and other information reported by employees. Subject to legal requirements Sawary will maintain the anonymity of employees reporting suspected violations in good faith.

Issuance of the Code of Conduct

This Code of Conduct has been issued on April 22, 2019 and is supplemented by more detailed policies and procedures. A current version of this Code of Conduct is published on Sawary’s website:

Application of the Code of Conduct

Sawary Trading and Contracting Co. Ltd. expressly states that:

  • It reserves the right to unilaterally change at any time its policies, guidelines, and related procedures;
  • Nothing contained in Sawary Trading and Contracting Co. Ltd.’s policies or guidelines shall be construed or applied as binding interpretation or definition of the law or industry practice;
  • Nothing contained in the Code of Conduct or other publications of Sawary Trading and Contracting Co. Ltd. Is intended by Sawary Trading and Contracting Co. Ltd. to be, nor shall it be construed as, an employment agreement; and
  • Any act by Sawary Trading and Contracting Co. Ltd.’s employees or agents in violation of the Applicable Laws or Sawary Trading and Contracting Co. Ltd.’s policies is beyond the scope of such person’s authority and is not an act by or on behalf of Sawary Trading and Contracting Co. Ltd.


Throughout the Code of Conduct, the term “we” is used to refer to Sawary Trading and Contracting Co. Ltd, and its subsidiaries and affiliates. The use of such terms as “we” is for convenience only and is not intended as an accurate description of corporate or other legal relationships between or among Sawary Trading and Contracting Co. Ltd. and its affiliates. Throughout this document, the phrase, “Code of Conduct” refers solely to the Sawary Trading and Contracting Co. Ltd. Business.

Applicable laws and regulations

Some of the important laws and regulations that are applicable to Sawary are, including but not limited to:

The laws of the Kingdom of Saudi Arabia; specifically the Combating Bribery Law, Royal Decree No. M/36, dated 29/12/1412H corresponding to 30 June 1992 (the “CBL”); the Civil Service Law, Royal Decree No. M/49, dated 10/7/1397AH corresponding to 26 June 1977; the National Strategy for Protecting Honesty and Combating Corruption, Council of Ministers Resolution No. 43, dated 1/2/1428AH corresponding to 19 February 2007; the Organization for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public Officials In International Business Transactions and its local country enabling legislation; and any other law, such as the United States Foreign Corrupt Practices Act or the UK Bribery Act, that may govern  Sawary Trading and Contracting Co. Ltd.’s activities (collectively, the “Applicable Laws”).

You can download PDF copy from here