values to which all employees are required to adhere

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We’re proud to act as a responsible corporate citizen in all of our activities. HOMA Group is committed to maintain high standards of ethics and business integrity.

HOMA has adopted a Code of Conduct policy highlighting the standards of anti-bribery principles and importance of operating with integrity.

This policy upholds the highest professional and ethical standards in everyday business activities, corporate culture and governance. It explains our commitments and expectations towards partners and provides guidance for employees and everyone who works on our behalf.

HOMA Group pursues a stringent and absolute zero-tolerance policy worldwide with regards to corrupt business practices in any and all business transactions. It does not permit any of its employees and/or directors to engage in acts of bribery or corruption.

We ensure transparency in our reporting internally and to all business partners. We aim to treat all commercial counter-parties and activities with fairness.

HOMA embraces innovation and have created a culture of compliance, teamwork and integration. HOMA Group’s management team is responsible for fostering and maintaining this culture throughout the company and works collectively and continually as a governing body to do this.

CODE OF CONDUCT

HOMA Group’s Code of Conduct ("The Code") re-affirms our commitment to uphold the highest ethical standards at all times. The Code clearly defines expected behaviors and provides guidance to employees as to HOMA’s principles and how and what employees should escalate to Compliance and or Management.

HOMA’s whistle blowing policy and procedures allow any individual within the organization to raise a concern about any situation that might represent a breach of our Code of Conduct or any other company policy and sets out clear expectations for them to do so.

Concerns can be brought to the person’s immediate supervisor or another appropriate manager or reported to the company’s C.E.O secretary (either by E-mail or phone).

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The company has in place a clear policy of no retaliation for any issues reported in good faith. HOMA Group’s Compliance and Management team are committed to ensuring that any issues reported are taken seriously and are followed through to resolution.

We expect all of our business partners to assist us to meet the responsibilities stated in our Code of Conduct and to actively support and respect our values and principles in their own business practices.

Also we expect all of our dear customers to conduct themselves and their activities ethically and in compliance with applicable law.

GOVERNANCE MANAGEMENT

HOMA Group has a clear framework in place for the manner in which it conducts its business. HOMA maintains an open-plan, office-free physical environment, and management endeavors to be open and approachable and encourages full communication between all individuals across the company.

HOMA Group’s management team comprises representation from across the company and is heavily represented by the control functions. This structure ensures that HOMA considers all factors and risks in making decisions and is not basing decisions exclusively on commercial terms.

The management team expects a rigorous approach to risk management and a strong ethical and compliance culture from all employees of the company.

To assist HOMA Group Board of Directors with its oversight responsibilities with respect to Compliance, HOMA has held numerous Compliance and Business Ethics meetings.

These meetings are composed of a local, cross-functional group of senior employees who meet quarterly to review HOMA’s in depth business activities with respect to Compliance and Ethics, and to provide ongoing reviews of the Company’s Compliance and Ethics programs, policies and procedures.

Those reviews that the committee conducts support senior management’s oversight of the Company’s business activities and ensure that they are in compliance with international laws and regulations and have conducted with integrity.