INTEGRITY COMPLIANCE

Ndiema Group is committed to the highest standards of business conduct in our relationships with each of our stakeholders, including our customers, business partners and shareholders. This commitment requires that we conduct our business in accordance with all applicable laws and regulations and in accordance with the Ndiema Group Code of Business Conduct.

We mandate that our employees conduct all business with outside parties in a manner that reflects our value of integrity. We will not tolerate any form of unethical or unlawful conduct. Our stakeholders’ concerns are important to us and anyone is welcome to contact our Integrity Compliance Office with questions or for guidance regarding a business practice or compliance issue or to report any questionable or allegedly unethical or illegal behavior.

Anyone submitting a complaint or question is encouraged to provide his or her name, contact information and appropriate details of the questionable or allegedly unethical or illegal behavior so that we may contact him or her directly, if necessary. We will handle all inquiries discreetly and make every effort to maintain, within the limits allowable by the applicable laws and regulations, the confidentiality of any inquiry or report. We will conduct all investigations in accordance with applicable laws and regulations.

Ndiema Group will not tolerate any retribution or retaliation taken against any person who has, in good faith, provided information or otherwise assisted in an investigation or proceeding regarding any questionable or allegedly unethical or illegal behavior.