Code of Conduct

Creative Marketing Solution

CODE OF CONDUCT

1. Introduction

Creative Marketing Solution (CMS) is committed to conducting its business with integrity, transparency, and respect for all individuals. This Code of Conduct establishes the ethical standards and behavioral expectations for all employees, contractors, and subcontractors working on behalf of CMS.

All personnel are required to read, understand, and comply with this Code. Violations may result in disciplinary action up to and including termination of employment or contract.

2. Scope

This Code applies to:

• All full-time and part-time employees

• Temporary and contract workers

• Subcontractors and third-party service providers

• Any individual acting on behalf of CMS

3. Ethical Business Practices

3.1 Integrity & Honesty

All employees must act with honesty and integrity in all business dealings. We do not tolerate fraud, deception, or misrepresentation of any kind.

• Be truthful in all communications with clients, partners, and colleagues

• Do not falsify records, documents, or reports

• Report any suspected fraud or unethical conduct immediately

3.2 Anti-Corruption & Anti-Bribery

CMS has a zero-tolerance policy for bribery and corruption in all its forms.

• Never offer, give, or accept bribes, kickbacks, or improper payments

• Avoid situations where personal interests conflict with company interests

• All gifts and hospitality must be reasonable and transparent

3.3 Conflict of Interest

Employees must avoid situations where personal interests conflict or appear to conflict with the interests of CMS.

• Disclose any potential conflicts of interest to management immediately

• Do not use company resources or relationships for personal gain

4. Labour Rights

4.1 Fair Employment

CMS is committed to providing fair and legal employment conditions for all workers.

• All employees receive written employment contracts in a language they understand

• Wages are paid on time and meet or exceed legal minimum requirements

• Working hours comply with applicable labour laws

• All legally mandated benefits are provided

4.2 No Forced or Child Labour

CMS strictly prohibits forced labour, bonded labour, and child labour in all its operations.

• Workers are free to terminate employment with reasonable notice

• No worker under the legal minimum age is employed

• No worker's identity documents are held or withheld

4.3 Freedom of Association

CMS respects the right of employees to freedom of expression and association, including the right to join organizations of their choice.

5. Human Rights & Non-Discrimination

5.1 Equal Opportunity

CMS is an equal opportunity employer. We do not discriminate on the basis of:

• Gender, age, nationality, or ethnicity

• Religion or political beliefs

• Disability or health condition

• Any other protected characteristic

5.2 Harassment & Abuse

CMS maintains a workplace free from harassment, bullying, and abuse.

• Physical, verbal, or psychological abuse is strictly prohibited

• All complaints of harassment will be investigated promptly and fairly

• No retaliation will be taken against anyone who reports a concern in good faith

5.3 Inclusion & Accessibility

CMS is committed to creating an inclusive workplace and plans to employ People with Disabilities (PwDs) as part of its workforce development strategy. Physical facilities are maintained to be accessible for all employees and visitors.

6. Environmental Responsibility

CMS is committed to minimizing its environmental impact and operating in an environmentally responsible manner.

• Reduce energy consumption and waste wherever possible

• Follow all applicable environmental laws and regulations

• Promote recycling and sustainable practices in our offices

• Work toward developing formal environmental policies by Q4 2026

7. Confidentiality & Information Security

All employees must protect confidential and sensitive information belonging to CMS and its clients, including Zain and other partners.

• Do not share confidential information with unauthorized parties

• Use company systems and data only for authorized purposes

• Report any suspected data breach or security incident immediately

• Comply with all information security guidelines communicated by management

8. Health & Safety

CMS is committed to providing a safe and healthy working environment for all employees.

• Follow all health and safety guidelines and procedures

• Report unsafe conditions or accidents immediately

• Basic health and safety awareness is provided to all employees during onboarding

9. Grievance & Whistleblowing

CMS encourages all employees to speak up about concerns without fear of retaliation.

• Employees may report concerns anonymously through direct communication with senior management

• All grievances are reviewed by senior management and addressed within a defined timeframe

• Retaliation against anyone who reports a genuine concern in good faith is strictly prohibited

• A formal whistleblowing policy is being documented and will be in place by Q3 2026

10. Supplier & Subcontractor Obligations

All suppliers and subcontractors working with CMS are required to:

• Acknowledge and comply with the principles of this Code of Conduct

• Comply with all applicable national laws and regulations

• Not engage in forced labour, child labour, or any form of discrimination

• Maintain confidentiality of CMS and client information

11. Violations & Disciplinary Action

Violations of this Code of Conduct will be taken seriously and may result in:

• Verbal or written warning

• Suspension or demotion

• Termination of employment or contract

• Legal action where applicable

All employees are encouraged to report violations through the grievance mechanism described in Section 9.

Acknowledgement & Approval

This Code of Conduct has been reviewed and approved by CMS senior management. All employees and contractors are required to acknowledge receipt and understanding of this document.