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Business Ethics

Each of us

Employees, officers, members of Blogger and Directors alike must commit to understanding this Code and abiding by its principles:
The principles support full compliance with applicable laws. They also represent the practical ways thatwe put our values to work every day.


Our Company’s foundation is built on our Values, which distinguish us and guide our actions. We conduct our business in a socially responsible and ethical manner. We respect the law, support universal human rights, protect the environment and benefit the communities where we work.


We are honest with others and ourselves. We meet the highest ethical standards in all business dealings. We do what we say we will do. We accept responsibility and hold ourselves accountable for our work and our actions.


We trust, respect and support each other, and we strive to earn the trust of our colleagues and partners.


We learn from and respect the cultures in which we work. We value and demonstrate respect for the uniqueness of individuals and the varied perspectives and talents they provide. We have an inclusive work environment and actively embrace a diversity of people, ideas, talents and experiences.


We seek new opportunities and out-of-the-ordinary solutions. We use our creativity to find unexpected and practical ways to solve problems. Our experience, technology and perseverance enable us to overcome challenges and deliver value.


We have an unwavering commitment to being a good partner focused on building productive, collaborative, trusting and beneficial relationships with governments, other companies, our customers, our communities and each other.

Protecting People and the Environment

We place the highest priority on the health and safety of our workforce and protection of our assets and the environment. We aim to be admired for world-class performance through disciplined application of our Operational Excellence Management System.

High Performance

We are committed to excellence in everything we do, and we strive to continually improve. We are passionate about achieving results that exceed expectations, our own and those of others. We drive for results with energy and a sense of urgency.

When each of us follows the Code, we communicate our commitment to the values that have made Blogger admired both as a business partner and as a valued citizen of the global community. It is important to note, however, that violations of the Code, or the policies referred to in the Code, could discipline, including termination of employment and/or criminal prosecution.

Blogger does not tolerate any form of retaliation for reports made in good faith. This includes blatant actions, such as firing, transferring, demoting, or publicly attacking someone, as well as more subtle retaliation, such as avoiding someone, leaving him or her out of professional or social activities, and so on. It includes actions taken by managers and employees alike.

We Respect Diversity

Diversity is also a fundamental value at Blogger. As stated in The Blogger Way, this means that “we learn from and respect the cultures in which we work.
” We also value “the uniqueness of individuals and the various perspectives and talents they provide.
” We promote diversity within our work force and have an inclusive environment that helps each of us to fully participate and contribute to Blogger's success.

We Provide Equal Opportunity

Our policy against discrimination aligns with our position on diversity. The Company follows the lawsthat prohibit discrimination in employment practices, wherever we do business. It is Blogger’s policy toprovide equal employment opportunities and to treat applicants and employees without illegal bias. It is ourpolicy that no one at Blogger should ever be subject to discrimination on the basis of:

  • race

  • religion

  • color

  • national origin

  • age

  • sex

  • gender identity

  • disability

  • veteran status

  • political preference

  • sexual orientation

  • genetic information

In Kurdistan region, discrimination is prohibited in hiring, rate of pay, promotion, demotion, transfer,layoff or termination.

Employee Compensation and Tenure

Our Company has a “pay-for-performance” philosophy. We administer wages, salaries and benefits to maintain our competitive position in the marketplace. It allows us to attract and retain topnotch personnel, provide incentives, and reward excellence. This approach to compensation supports our value of High Performance.

Controlled Substances and Drugs

Fortunately, the drug phenomenon here in Kurdistan is almost nonexistent, and severe penalties are imposed by law to even who hold it.
The Company prohibits the use, possession, distribution, purchase or sale of controlled substanceson its premises while conducting business for the Company or while operating Company equipment.Controlled substances include:

  • illegal drugs and narcotics

  • prescription drugs obtained or used without a legal

  • prescription or

  • other unlawful substances or materials.


The use, possession, distribution, purchase or sale of alcohol by any person while on Company premises,or while operating Company equipment, is prohibited . Any person under the influence of alcohol is prohibited from entering Company premises, engaging in Company business or operating Company equipment. Any use of alcohol that causes or contributes to unacceptable job performance or unusual jobbehavior is also prohibited.

Preventing Workplace Violence and Harassment

The Company prohibits actual or threatened violence against co-workers, visitors or anyone else who iseither on our premises or has contact with employees in the course of their duties. Every threat of violence is serious. We must report any such event immediately. Blogger is also committed to a workplace free of illegal harassment. If you are confronted with harassment, you should report your concern to your supervisor, or Blogger’s Hotline.

Human Rights

Human rights are generally defined as basic standards of treatment to which all people are entitled, regardless of nationality, gender, race, economic status or religion. Although governments have the primary duty to protect and ensure fulfillment of human rights, Blogger recognizes that companies have a responsibility to respect human rights, and can also play a positive role in the communities where we operate.

Avoid Accepting or Giving Gifts, Fees, Favors or Other Advantages

It is also a conflict of interest for a Blogger employee or director to give or receive gifts or entertainmentof more than nominal value, or cash in any amount to or from people or companies doing business with Blogger. Therefore, we must not:

  • Accept fees or honoraria in exchange for services provided on behalf of the Company.

  • Provide or accept gifts or entertainment from anyone doing or seeking business with Blogger or any of its affiliates. Generally, modest forms of gifts and entertainment received from vendors are acceptable and do not create conflicts of interest.

  • Give a gift or entertainment to anyone for the purpose of improperly influencing him or her to take action in favor of Blogger.


Bribery Is Always Prohibited

Bribery of any government official in any country is strictly against Blogger policy, even if the refusal tomake such a payment would result in the Company losing a business opportunity.

Management approval is required before any gift or payment can be made to a government or publicofficial. In some cases, the gift or payment must also be approved by your Compliance Coordinator or

Operational Excellence: Safety, Health, Environment, Reliability and Efficiency

Blogger’s policy is to maintain the safety and health of people and the quality of the environment where we operate. The Operational Excellence Management System (OEMS) defines the expectations regarding the systematic management of safety, health, environment, reliability and efficiency to achieve world-class performance in operational excellence.We are committed to working in a way that places the highest priority not only on our own safety and health but also on the safety and health of our co-workers and members of the community.

We are also committed to protecting the environment by minimizing and mitigating environmental impacts throughout the life cycle of our operations. Protecting People and the Environment is a key value at Blogger.

Our policy is to maintain the safety and health of everyone and the quality of the environment wherever we operate.

All of us are responsible for complying with applicable Company policy and government laws and regulations and for fully committing to the requirements of the OEMS in our work activities.

Blogger is to comply with the letter and spirit of all environmental, health and safety laws and regulations.

Each of us has the authority and responsibility to stop — or not start — any work activity if hazards or risks posema threat to safety or the environment.