Compliance & Ethics Code

COMPLIANCE & ETHICS CODES

RCC undertakes to conduct its business activity to the highest standard of integrity and ethics and adopts a clear and unequivocal policy of zero tolerance for bribery and corruption. It is both our individual and collective responsibility to strictly comply with relevant laws and regulations, apply RCC’s anti-bribery and Anti-corruption policies, and uphold ethical principles to always earn trust. With our decades of experience and reputation for integrity across the globe, we take extensive measures to provide civil engineering solutions that clients can trust.

RCC’S Commitment to Compliance and Ethics

● We are familiar with and comply with local, national, and international regulations.

● We uphold all laws and standards.

● We created a comprehensive and up-to-date Anti-Bribery and Anti-Corruption Compliance Program. This is the compliance program presented to you.

Adherence to Compliance and Ethics laws

Our Code of Ethics is Consistently reviewed to adhere to the most current protocols, RCC mandates high ethical standards for all employees, specifically:

○ Operating in good faith and with integrity

○ Prohibiting corruption and bribery

○ Preventing conflicts of interest

To uphold this code, RCC provides extensive ethical training at each project site, as well as conflict resolution strategies for all new hires and frequent refresher sessions for existing employees.

Anti-bribery and enforcement program: As a member of the SBI International Holdings AG (SBI) RCC adheres to the TASE Securities Law’s and strict anti-fraud regulations. Our Anti-bribery ad Anti-Corruption Compliance Program is continually updated, and our rigorous framework includes:

■ Appointing Compliance officers to implement and assimilate the compliance program.

■ Informing all employees and relevant business associates of the Company’s Anti-Bribery and Anti-Corruption policies.

■ Adopting appropriate contractual clauses in all employment agreements and in all new and renewed agreements with business associates and relevant third parties.

■ Performing due diligence in accordance with the compliance program.

■ Holding annual training for the company’s employees to reinforce familiarity with compliance programs and policies; and

■ Ensuring proper documentation and bookkeeping comply with company procedures.

RCC’s high governance standards also include;

Health & Safety

●Protecting the health of workers and residents in the area in which we operate.

CSR & Environmental

● Preserving the biodiversity native to the countries in which we work.

● Putting in place ecological protections.

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RCC'S HIGH GOVERNANCE STANDARDS ALSO INCLUDE;

Health & Safety

●Protecting the health of workers and residents in the area in which we operate.

CSR & Environmental

● Preserving the biodiversity native to the countries in which we work.

● Putting in place ecological protections.