Code of Ethics – Kalken Security Group

Must know

Any Code of Conduct dictates how personnel must work. The aims of this Code are to set out specific principles in compliance with the International Code of Conduct for Private Security Providers, allowing the operation of the company and any associated companies, to bear scrutiny at an international level. It is expected that adherence to this Code will allow personnel to operate in a humane way within local, national and international laws and promote the business ideals of the company.

The kalken security group ltd code of ethics and business conduct provides guidelines to ensure that our behavior on the job is ethical and supports the reputation Kalken has earned as one of the most admired security company in the country. Kalken is consistently recognized as being among the best companies to work with across the country. While the Code provides guidance for a range of workplace situations, the high standards that characterize our work environment can be summarized in a few simple principles.

Our Vision

Our vision is to continue to grow as an industry leader, creating value by upholding our tradition of excellent service. This commitment to our clients creates a passion within our workforce to provide exceptional customer experience through collaboration, responsiveness and candid communication.

Mission

Our mission is to provide tailored services that exceed our clients’ quality standards using industry best practices, competitive pricing and thought leadership. To always strive to employ the best people and provide the most efficient, cost-effective service and equipment, as well as offer the best warranties available to our customers

Our Goals

We want to become the best security services provider and Customer Satisfaction to always be our priority.

Our Commitment to Ethics and Compliance

At kalken security group ltd, ethical behavior is inseparable from integrity and good judgment. Ethical behavior is more than just compliance with the law. We all have a responsibility to honor not just the letter of existing laws, but the spirit that underlies them by basing our decisions on legal and internal and external regulatory rules and our Values.

To help us understand our responsibilities and make good decisions, we have developed this Code of Ethics and Business Conduct (“Code”) that defines kalkens security standards and expectations as they relate to ethical business and personal conduct. The Code is applicable to kalken security group and its affiliates.

We operate in many counties around the country and the complexity of local laws and customs may require additional guidance that is more specific than what is provided in our Code. Whenever there is a difference between local requirements and this Code, apply the strictest standard, and do not follow customs or apply practices that would violate this Code or our Values.

Using our code

Our code addresses many of the complex legal and ethical decisions you may face in your day-to-day life at kalken security. Regardless of whether or not an issue is specifically addressed in our code, we expect you to use good judgement and common sense when making decisions. When faced with a difficult decision, your best judgement should either guide you to an answer or to the need to seek advice from a manager. Consider the following questions which will help guide you to the right response:

<> Is the decision or action legal?

<> Is the decision or action a violation of our code?

<> Do you have all of the information you need to make an informed decision?

<> Can you confidently defend your decision to your colleagues, manager, regulators or a government agency?

<> Would you want the decision, action or repercussions of the action to be reported in the press?

<> Would you want your friends, family or colleagues to learn about the decision or action?

Leading by example is one of the most effective ways that we can build partnerships and create a respectful and ethical workplace. Leading by example means not only demonstrating the highest standards of personal integrity, but also making yourself available to colleagues who have questions or concerns.

Integrity

We deliver on our verbal and written promises. We are open and honest in our dealings with others much focusing on accountability for how our actions reflect on the company’s reputation and for the prudent use of company resources. Personnel will be required to uphold the corporate integrity of their employer. The Code of Conduct will be observed at all times and the ethics and relevant training and skills will be utilized effectively in supporting the work of the company. Personnel will maintain a responsibility to the company and preserve its integrity through observing the following responsibilities:

-Personnel will not engage in, benefit from, or enable competitors or other inappropriate persons, to acquire confidential information about the company or its personnel.

-Personnel will avoid potential conflicts of interest which could impair their performance for the company. These include (but are not restricted to): business dealings, investments, family relationships, outside employments, improper personal benefits, gratuities and inappropriate relationships with clients, suppliers, or competitors.

-Personnel will not accept or offer gifts, gratuities, kick‐backs or bribes to persons or organizations seeking to engage in business with the company.

-Personnel will consult with management in the event of an action arising which is not clearly defined above, but which may be construed as a bribe, gratuity or solicitation of the same.

-Personnel will take reasonable steps to protect kalken Security and/ or clients of kalken Security’s property, equipment, materials, resources, documentation and business assets.

Entrepreneurship

We are a nimble company in a dynamic industry. Our ideas are big and bold.

Partnership

We work closely with our clients and colleagues; the best decisions come from sharp minds engaged in challenging and constructive debate that develop highly motivated and effective team members.

Communication

Communication is vital to our organization; we all benefit from the effective sharing of knowledge.

Innovation

The old way is not always the best way. We are creative and imaginative in everything we do.

Inclusiveness

Each one of us has the ability and is given the opportunity to have an impact on Kalken security success. Our opinions are sought, our values and cultures are respected by fostering a safe workplace that values diversity, teamwork and human dignity.

Respect

We respect and listen to our customers and strive for workplace excellence that enables us to meet their needs and exceed their expectations.

Our business principles

Our code is based on our shared values and business principles and must be followed by all of our employees, officers and each member of our board of directors. Our code represents our commitment to doing the right

thing, personally and professionally, and respecting the rights of others.

Much of what we do at Kalken Security is based on the partnerships we build with our colleagues, customers, suppliers and other stakeholders. You are expected to demonstrate a high degree of professionalism and ethical conduct at all times.

This involves accepting certain responsibilities, respecting the rights and feelings of others and refraining from behavior that might be harmful to you, your fellow colleagues or Kalken Security Group.

We shall always;

Conduct our business with integrity.
Treat each other and our community with respect.
Provide each other a safe and secure work environment for growth and development.
Communicate clearly and honestly act lawfully and ethically.
Report misconduct and support others who report misconduct.
Abide by our code.

Ethical Business Practices.

We are committed to conducting business with integrity. Our obligation to act ethically starts with open and honest communication with our colleagues, customers and all others with whom we interact.

In addition, we have an obligation to act in the best interest of Kalken security by protecting the information and assets of kalken security, our colleagues, customers, and by avoiding situations that could compromise the ability to act objectively on behalf of kalken group.

Member: Kenya Security Industry Association

Kalken Security Group Ltd is a member to Kenya security Industry Association (KSIA) a trade association for the professional security industry in Kenya based in Nairobi city. It has helped shape standards in the private security industry.

The association applies strict membership criteria, providing assurance that member companies are financially sound and run by directors of good repute, as well as possessing mandatory certification accredited by a Kenya private security authority and other related government institutions. By ensuring that the views of its members are taken into account in the development of legislation and subsequent amendments, the KSIA helps influence government policy by lobbying efforts provided and impetus for regulation of the security industry through the Private Security Industry Act 2016.

Where the industry lacks standards, the association’s members develop their own codes of practice, which at times other government Institution could use in providing benchmarks for the wider private security industry requirements.

Understanding our code

By being part of kalken security, you are agreeing to uphold our commitment to our code. You are responsible for reading and understanding our code together with our supplemental policies, including any additional policies that might apply to your business specifically. Many of the policies discussed in our code are available for your reference via other links. If you feel there is a conflict between our code and any supplemental policies, you should comply with the most restrictive requirement or seek clarification from our manager on duty.

Our code applies in all counties where we conduct business. Violations of our code or any of the supplemental policies described in our code by any of our employees could result in disciplinary action and even dismissal.

As an employee…

Seek guidance from your Manager and any other Company reporting resource whenever you have questions about this Code, the Company’s policies or any of the laws and regulations which apply to your responsibilities.

Discuss any concerns you might have about possible violations of the Code, the company’s policies or any other laws and regulations with your Manager or another Company reporting resource listed under “Raising Concerns. “Understand the standards that apply to your job and take responsibility jointly with your manager to identify training needs. Take responsibility for your own conduct. No one has the authority to make anyone violate our Code. Any attempt to direct or

otherwise influence any employee to commit a violation is itself a violation of our Code.

As a manager…

Emphasize the importance of the Code to all employees and consistently encourage open communication. Play a proactive role in training employees on the Code and related topics, specifically by encouraging employee participation in training initiatives and identifying potential training opportunities.

Understand when to escalate business concerns and when to seek support from additional resources. Communicate the Company’s commitment to conducting business ethically and in compliance with all laws and regulations to all third parties whom you oversee and review and confirm that their actions and behaviors are consistent with our values and with this Code.

Accountability

We are all accountable for complying with the Code, as well as all company policies and applicable laws, rules, and regulations that apply to us. Likewise, we are all accountable for our decisions and actions, especially managing the risks inherent in our roles and appropriately escalating issues and violations of which we become aware. If mistakes are made, we acknowledge them and act to correct them.

Violation of the provisions of this Code or the referenced policies and guidelines is grounds for corrective action, which may include termination of your employment. Certain actions may also result in legal proceedings, including prosecution for criminal violations.

Dealing with our customers and others

We must be honest and fair in our dealings and communications with our customers, as well as with third- party service providers, competitors and each other. We provide our customers, prospective customers with advice, service, and products, and we are committed to making other security products and services available to them on a fair, transparent, and consistent basis, and to conducting business in a responsible manner.

Legal Obligations.

Kalken security group ltd must comply with all statutory and regulatory requirements, including national and local requirements governing such activities, including registration, reporting and disclosure requirements. We are committed to following all applicable laws, rules and regulations that apply to our businesses and as specified by the regulatory body private security regulatory authority. More information about our responsibilities under certain laws, rules and regulations applicable to our industry is therefore well available and has to be followed to the latter.

Member: Mombasa Security Firms Forum

Was formed to improve working relationship between private security companies in coast region by sharing information among members bringing both national and local security intelligence and other security administrations on board.

The forum (MSFF) also undertakes an education role, which it delivers, in part, through accredited training academy with specific Skills for Security. The training academy works with employers to improve security skills and professional standards by providing access to training courses and qualifications for people employed in private security roles across the country.

Support our communities

We want to be known as a trusted neighbor in our communities where we live and operate. Our commitment therefore remains to help local civic organizations and be sure that our participation does not interfere with our work or create a potential conflict of interest.

Soliciting or pressuring customers, third party service providers, or other team members to support our favorite charities or causes is not allowed at all.

CODE OF ETHICAL PRACTICE

The company is committed to the maintenance and development of a culture where integrity and ethical standards are given the highest priority. Our ability to function effectively relies on the implicit trust of the public and clients, and their belief that we can carry out our duties in a fair and impartial manner. The Statement of Ethical Principles and Code of Ethical Practice relate to every member of the Company. The Statement of Ethical Practice and Code of Ethical Practice are not intended to cater for all eventualities. Instead, they are designed to provide guidance in respect of issues and decisions, which may arise in the course of our duties and everyday lives. All staff must report any conduct considered to be unethical. Where there is suspected wrongdoing, confidentiality will be given the highest priority and will be maintained as far as possible and supported by management. The focus is, however, about preventing situations where employees may be compromised. This statement and Code are intended to be living documents, which will continue to evolve. What may have been acceptable or unacceptable conduct many years ago may now no longer be so. Equally conduct, which may be considered entirely appropriate or inappropriate today, may, in years to come, become less so. It is in the context that we all have a duty to examine our own conduct and be willing to expose ourselves to scrutiny in all spheres of our employment and off duty time.

Business Ethics.

We’re committed to the highest standards of integrity, transparency, and principled performance. We do the right thing, in the right way, and hold ourselves accountable in every way possible.

We have a responsibility to always act with honesty and integrity. When we do so, we earn the trust of our customers. We have to earn that trust every day by behaving ethically; rewarding openly, honest communication; and holding ourselves accountable for the decisions we make and the actions we take in our daily business.

Anti-bribery and anti-corruption

We do not tolerate bribery and corruption, which, in all forms, go against our Vision, Values & Goals and our company policies, and violate the law. We do not offer or accept bribes or any other kind of improper payment, including facilitation payments or anything of value, and we do not do anything through a third party that we are not allowed to do ourselves.

Protect the environment

We are committed to integrating environmental mindfulness into all we do and accelerating environmental sustainability. We recognize that our environmental impact goes beyond how we operate. We see the business value of taking a leadership position in addressing our own environmental footprint and in finding innovative solutions to help our communities and customers become more resilient.

We also know that our impacts extend beyond the walls of our operations to include our supply chain and customers. We focus on managing environmental risks in our approach to sensitizing all those we work with across the board with an aim to do better when we make decisions that care for and improve the environment. Remember that each of us can help support efforts to advance environmental sustainability in our operations and extending to our communities at large.

Discrimination, harassment and bullying

Whether conducting business in one of our offices or offsite, you should always treat others with respect and dignity, and contribute to a workplace that is characterized

by inclusiveness. Any form of discrimination or harassment based on a person’s race, color, religion, sexuality, gender identity or expression, national origin, disability, age, veteran status or any other characteristic protected by law, is strictly prohibited.

While it is not always easy to define harassing, discriminatory or bullying behaviour, some common examples include:

Using epithets or slurs, or making derogatory comments or similar types of remarks

Making jokes about a person, no matter how light-hearted the intention

Negative stereotyping

Threats, intimidation or hostile acts that create an uncomfortable or hostile work environment

Comments or written or graphic material that disparage or show hostility or aversion towards an individual or group

We also strictly prohibit any conduct that could be considered sexual harassment. Some common examples include:

Unwelcome sexual propositions, demands or advances of a sexual nature

Unwelcome physical contact such as touching, hugging, kissing, grabbing, patting or pinching

A pattern of disparaging comments or jokes that interfere with another’s work performance or that creates a hostile, offensive or threatening work environment.

Inappropriate remarks about a person’s appearance.

Vulgar or obscene gestures, even if said or made jokingly.

Keep confidential information safe and secure

Kalken security group personnel must not improperly disclose confidential business information, whether verbally, in writing or electronically and confidential business information should never be used for individual benefit.

Each of us has access to confidential information about kalken security, our customers, team members, and our third-party service providers. We are responsible for keeping confidential information safe and secure.

Do not use proprietary information that you acquired while working at another company, and do not pressure other team members to do so.

Do not attempt to access confidential information unless you have a legitimate Kalken security business reason to do so.

Be careful when accepting information from third parties. You should know and trust their sources and ensure that kalken security has appropriate rights to use the information.

Do not use or disclose proprietary information about kalken security or its team members, customers or third-party service providers to anyone except properly designated team members, unless required by law.

In some business units, there may be additional policies that restrict the flow of confidential information with other business units, including those that are engaged in other investment and trading activities.

Nothing in this Code prevents you from either discussing or disclosing the terms and conditions of your employment (including your pay) or from reporting any possible violation of law or regulation to the appropriate authority or investigative agency.

Use of our assets

Physical and financial assets are valuable and must be preserved, protected and managed properly. We are entrusted with protection of kalken security assets and using them appropriately.

Kalken security assets include physical, financial and intellectual property and always remember to use kalken security assets only for legitimate kalken security business purposes.

Always protect the assets under your control from theft of any kind, waste, misuse of any nature, loss, and or damage.

Limited personal use of company-owned vehicles, phones, computers, electronics, and company networks is allowed, but use good judgment and always ensure that personal use does not interfere with your work environment or in any way violate our policies or security requirements.

All intellectual property that is developed while working for kalken security must not be disclosed to any other person or entity other than kalken security and it cannot be used externally or published without written permission and do not sell, lend, or donate our assets without approval.

Regulators and government agencies or officials

All requests from regulatory authorities, government agencies or officials should be directed to the legal department.

Unless you are authorized by the communications department, you are discouraged from discussing kalken security as part of your personal use of social media. While business should only be conducted through approved channels, we understand that social media is used as a source of information and as a form of communicating with friends, family and workplace contacts.

When you are using social media and identify yourself as a kalken employee, officer or director or mention kalken incidentally, for instance on a Facebook page or professional networking site, please remember the following:

Intoxicating and Controlled Substances

The use of alcohol and drugs can impair your ability to work effectively and productively. Except at approved functions, or with appropriate authorization, you shall not drink alcohol on kalken security premises.

The use, possession, distribution or sale of controlled substances by any person while on kalken security premises, is therefore prohibited.

Any person under the influence of alcohol of controlled substances is prohibited from entering kalken security group and its affiliates’ premises, engaging in Company business or operating Company equipment. Any use of alcohol or any other substance that causes or contributes to unacceptable job performance or unusual job behaviour is prohibited.

You are prohibited from working while your performance is impaired by alcohol or any other drug whether legal or illegal. Additionally, you may not possess any non-pharmaceutical drugs on kalken security premises or at work-related functions.

Investigations and Inquiries

All personnel must fully cooperate with internal and external audits, investigations, and inquiries that are conducted by the Company. In addition, in the course of business you may receive inquiries or requests for information from government officials or regulatory agencies. If you learn of a potential government investigation or inquiry, immediately notify your area supervisor and or manager prior to taking or promising any action.

You are expected to fully cooperate and ensure that any information you provide is true, clear and complete. With respect to all audits, investigations, inquiries and remember that, you must NOT:

Destroy, alter, or conceal any document in anticipation of or in response to a request for these documents.
Provide or influence others to provide, false, or misleading statements to a company or government investigator.

Individuals who act contrary to our Code, our policies, laws or regulations may be subject to discipline which could include termination of services as well as possible legal proceedings and penalties.

Those involved in the wrongdoing may also be subjected to discipline this includes, those who fail to use reasonable care to detect violation of our code, persons who refuse to divulge information which may be material to an investigation, as well as supervisors who approve, condone, “look the other way,” or attempt to retaliate.

Remember Violation of this Code are analyzed on a case-by case basis and will be addressed in accordance with all applicable internal procedures, union or collective agreements and legal requirements.

EQUAL OPPORTUNITY

Diversity is a decisive factor for our competitiveness, attractiveness and ability to innovate and adapt. Kalken security must ensure

that employment-related decisions are based on relevant qualifications, merit, performance and other job-related factors.

Unlawful discrimination relating to employment must not be tolerated. Each employee of kalken security group and candidate must be considered on individual merit, without discrimination as to origin, gender, age, disability, sexual orientation, gender identity, affiliation with a political party, religious, or union organization or minority group and must ensure the highest standards of non-discrimination is enforced.

Respect for human rights

In Consistent with our Vision, Values & Goals, kalken security recognizes that governments have the duty to protect human rights, and our company has a responsibility to respect human rights. To that end, we strive to respect human rights throughout our operations and our products and services, including consistent treatment among people, employee well-being, economic and social freedom, and environmental stewardship. We seek tangible ways to apply these principles through our actions and relationships with our team members, customers, suppliers and communities in which we do business.

Reporting misconduct

Our obligation to observe the highest standards of personal integrity is more than just an individual responsibility. You also have an obligation to speak up when you see others failing to act with integrity or violating our code. This isn’t always easy or comfortable, but we expect that you will help us maintain an ethical culture by reporting any concerns using the procedures outlined in our code.

We adhere to a strict policy of non-retaliation for good faith reports of misconduct. You should never fear retaliation or dismissal for making good faith reports of misconduct or suspected violations of our code.

We encourage you to speak with someone – a manager, a member of our human resources department, the compliance department or our general counsel – if you are unsure about whether a particular situation constitutes a violation or breach of our code. In addition, our compliance hotline is available to you if you would like to report violations and breaches of our code or if you have questions or concerns about a situation not specifically addressed by our code.

Grievance procedure

We take the welfare of our employees, officers and directors very seriously and will investigate all claims of harassment. Our local human resources department has the responsibility of determining the appropriate course of action and will take the decisions and actions it deems necessary in each case. Investigations will be kept confidential to the extent possible.

The purpose of the grievance procedure outlined in our Employee Handbook is to ensure the fair and appropriate treatment of all employees, officers and directors. Procedures may vary across jurisdictions, but you are encouraged to use our grievance procedure to raise issues or concerns.

Health and Safety at Work

Kalken security is committed to providing a safe and healthy work environment for personnel and others who visit or work at our offices and or our customer’s premises. Fulfilling our commitment to health and safety is everyone’s job. When it comes to health and safety, as a Company and individually we must always demonstrate visible leadership, care, and concern for one another. In all of the Company’s processes and assets including those of our customers, safety should be the first aspect considered in any decision made and always ensure to:

Integrate health and safety in all activities and in all phases of the business in the execution of your job.
Understand your responsibilities to comply with the applicable standards of health and safety.
Always wear required safety equipment and never tamper with safety equipment or systems.
Participate in all required health and safety training.
Only undertake work that you are qualified to perform.
Stop work if you consider it unsafe and report it immediately to your direct supervisor.
Never work while impaired by, for example, lack of sleep, alcohol, or any drugs – including prescription or over-the-counter medication.
Report any accident, injury, illness, or unsafe condition immediately. Never assume that someone else has reported a risk or incident.
Know, understand and comply with the operational procedures that apply to your work, ensuring that risks are assessed and that the appropriated measures to prevent them are applied in advance.
Know the emergency procedures that apply where you work.
Report all concerns regarding health and safety immediately to your direct supervisor and your local HSE personnel

We all have a responsibility to assist in the maintenance of a safe and secure work environment. Always follow our safety and security procedures, including evacuation plans, and ensure records accurately reflect your emergency contact information. Always use caution and good judgement in all activities and notify your manager if you believe there is a safety issue that should be addressed.

Personal data

During your employment with kalken security group, you may come into contact with the personal data of your colleagues, our customers and or other third parties. Personal data must only be collected and used to the extent necessary for legitimate purposes with the management approval.

We as kalken security group ltd have an obligation to comply with and abide by the data protection and privacy laws of the jurisdictions in which we Operate.

This is a complex and rapidly changing area of law, and you should speak with someone in the legal department or the compliance department should you have questions about the proper use and dissemination of personal data.

Media, government and public enquiries

When members of the media, government officials or members of the public contact us to request information, our response can have far-reaching implications. When providing information about our products and services, operational strategies or financial results, we must ensure that the information is accurate and that we are ready to disclose the information publicly. Thus, if you receive an external request for information, even if it seems like a simple request, forward the request to the appropriate department listed.

Public speaking and interviews Before publishing, making a speech or giving an interview in your capacity as an employee, officer or director of kalken security group ltd – or if a publication, speech or interview might in any way be connected to your position or role – you should obtain approval from authorized communications department.

Media

All media enquiries should be directed to our corporate communications department.

Social media

Never disclose confidential information about kalken security or its business, customers or suppliers. Make clear that any views expressed are your own and not those of kalken security.

Remember that our policy on discrimination, harassment and bullying applies to social media sites. Be respectful of your colleagues and all persons associated with kalken security, including customers and suppliers. Promptly report to our communications department any social media content which

inaccurately or inappropriately discusses kalken security.

Never respond to any information, including information that may be inaccurate about kalken security.

Never post documents, parts of documents, images or video or audio recordings that have been made with kalken property or of kalken security products, services or people.

Professional networking, Online networking on professional or industry sites, such as face book, has

become an important and effective way for colleagues to stay in touch and exchange information. Employees, officers and directors should use good judgement when posting information about themselves or kalken on any of these services.

What you post about kalken security or yourself will reflect on all of us. When using professional networking sites, you should observe the same standards of professionalism and integrity described in our code and follow the social media guidelines outlined above.

Non-Retaliation

Each of us plays a critical role in safeguarding the integrity of kalken security. You are required to immediately report issues that could conflict with our Code, policies or laws and regulations. Personnel can report possible concerns in confidence and without fear of retaliation.

We will not tolerate any retaliation against anyone who in good faith asks questions, makes a report of actions that may be inconsistent with our Code, policies, laws or regulations, or who assists in an investigation of suspected wrongdoing.

Reporting “in good faith” means making a genuine attempt to provide honest, complete, and accurate information, even if it later proves to be unsubstantiated or mistaken. A report that is found to have been made in bad faith may, however, result in disciplinary consequences.

Violence-free workplace

We strictly prohibit acts of hostility, intimidation or violence towards others in the workplace and in places where our business is being conducted.

You shall not bring dangerous weapons, explosives or any other weapons onto kalken premises, or to any work-related setting, regardless of whether you are licensed to carry such weapons.

Our Code Of Ethics And Business Conduct