Ezz Steel Competition Law Compliance Policy

Ezz Steel, through its business units, has established itself as a leader in the manufacture of a
comprehensive range of steel products in Egypt and an emerging seller of steel products on
international markets. The scale of production is such that Ezz Steel is a significant buyer of raw
materials, particularly within Egypt. This position of success and leadership is built on a sound
foundation of the pursuit of excellence in all aspects of our business from technical expertise,
exacting quality control, product innovation, meeting customer needs, competitive pricing, to world
class standards of corporate governance.
Responsibilities of Success and Leadership
With the rewards of success and leadership go responsibilities, for Ezz Steel, for each of its business
units, and for each individual manager. We accept those responsibilities. Our quest for excellence
starts and finishes with our commitment to lawful, ethical conduct. As we are becoming an
increasingly international business we must follow a set of internationally acceptable standards.
Application of Competition Laws to Ezz Steel
Ezz Steel recognises that competition law is an essential component of modern commercial law
which contributes directly to improved economic development by preventing the erection of nongovernment
barriers to trade and encouraging efficiency and innovation.
Ezz Steel recognises that its operations and the conduct of its employees are subject to domestic and
foreign competition laws
Ezz Steel’s Decision to Comply
Ezz Steel has chosen to implement a comprehensive competition law compliance policy for three
principal reasons:
1. Compliance with all relevant laws, whether domestic or international, is consistent with Ezz
Steel management’s general commitment to excellence in every area of business.
2. Competition Law compliance simply makes good business sense. Put simply there is an
unacceptable risk that the long term costs of non-compliance will be greater than the costs of
compliance.
3. Competition law compliance is an essential component of a contemporary ethical trading and
consistent with the personal ethics of the Chairman of Ezz Steel, each member of Ezz Steel’s
boards and senior managers.
Total Corporate Commitment
Our Competition Law Compliance Policy is not simply a set of aspirations; it is a clear unambiguous
statement of policy supported by appropriate practices and procedures to ensure that the risk of non
compliant conduct is minimised and where it does occur it is quickly detected and appropriate
remedial action taken.
A Culture of Compliance
To ensure preventative measures are appropriately targeted we regularly assess our operations to
identify areas of potential competition law compliance risk.
Management will investigate any potential contraventions of this policy or any relevant competition
law and take appropriate remedial action.
To facilitate efficient and effective application and auditing all competition law compliance policy
practices and procedures are fully documented and accessible.
Recognising that competition law compliance is a component of wider corporate governance, the
competition law compliance practices and procedures are integrated with other compliance programs
wherever possible.
Accountability
To ensure accountability we assign appropriate personal responsibility for compliance to identified
positions.
All employees who have decision making responsibilities that are relevant in a competition law
context are provided with appropriate education and their understanding of their responsibilities
regularly tested.
No senior manager, managing director or employee has any authority to give any order or direction
which would result in a conflict with this policy or a contravention of any applicable competition
law.
Total Personal Commitment
Acceptance and implementation of our Competition Law Compliance Policy is not discretionary; it
is mandatory and applies to every employee of Ezz Steel and its business units including each
member of Ezz Steel’s boards and each senior manager.
Ezz Steel’s employees must comply with both the letter and the spirit of this policy. Each manager
understands and is personally committed to the implementation and promotion of competition law
compliance within Ezz Steel and its business units. Each formally attests to acceptance of personal
responsibility for compliance with the Competition Law Compliance Policy and relevant competition
laws in respect of their responsibilities and conduct.
Each manager undertakes regular competition law compliance training and is required to
demonstrate an understanding of corporate and personal responsibilities.
Compliance with the Competition Law Compliance Policy is a requirement of all senior managers
and managing directors as is the reporting of any conduct that may raise competition law compliance
risks.
Ezz Steel resolves to take uncompromising action in respect of any senior manager, managing
director or employee whose conduct conflicts with this policy or contravenes any applicable
competition law.
Record Keeping, Reporting and Auditing
To ensure that the Competition Law Compliance Policy is effectively managed we monitor our
performance through regular and ad hoc internal reporting and both internal and external audit
inspections.
Continuous Improvement
Ezz Steel is successful in the production and marketing of a wide range of steel products because it
maintains an organisation-wide commitment to continuous improvement. We apply this
organisational attribute by actively seeking to continuously improve our Competition Law
Compliance Program and its supporting practices and procedures.
To ensure the viability of our competition law compliance efforts we allocate adequate financial and
human resources for sustained implementation.
External Expectations
Ezz Steel bases its relationships with suppliers, customers and competitors on lawful, efficient and
fair practices. We expect our suppliers, customers and competitors to respect our commitment to
competition law compliance and support this commitment by also complying with applicable
competition laws.
Ezz Steel will only do business by lawful and ethical means and will actively cooperate with
domestic and relevant foreign competition law authorities.
The Objective
Our goal is to ensure comprehensive, sustainable compliance with each relevant competition law and
in so doing demonstrate leadership in good corporate governance to the benefit of Ezz Steel’s
shareholders, its employees and the Egyptian people.
The stakes are high in both the Egyptian and international business environments and we can
reasonably expect scepticism of business intentions and conduct. Ezz Steel undertakes to meet and
surpass requirements and expectations.
Our commitment to our customers, suppliers, employees, competitors, the Egyptian government and
to the Egyptian people is that we will maintain a corporate culture of compliance that shall be second
to none.