I. Legal Basis and Purpose

This Code of Ethics is issued in accordance with the provisions of Qatar Labour Law No. (14) of 2004 and its amendments, as well as all applicable regulations, ministerial decisions, and internal company policies.

This Code constitutes an integral and binding part of the employment relationship between Memar International and its employees. Compliance with this Code is a mandatory contractual obligation, and any breach thereof shall be treated as a violation of employment duties in accordance with the applicable laws of the State of Qatar.

The purpose of this Code is to establish enforceable ethical and professional standards, ensure lawful and responsible conduct, protect the Company’s interests and reputation, and promote integrity, impartiality, and professionalism in all work-related activities.

II. Scope of Application

This Code applies to all employees of Memar International, including executive management, supervisory staff, administrative personnel, technical staff, and workers, whether employed on a permanent, temporary, or contractual basis, across all local and international operations, insofar as permitted by Qatari law.

All employees are legally obligated to comply with this Code, the Company’s internal regulations, and the applicable provisions of Qatari labour and civil laws.

III. Duties of Employees

In accordance with the Qatar Labour Law, employees shall:

• Perform their duties with honesty, integrity, and due care, and in a manner consistent with the Company’s legitimate interests.
• Comply with all lawful instructions issued by the Company, provided such instructions do not violate applicable laws or public order.
• Refrain from any act or omission that may cause material, moral, or reputational damage to Memar International.
• Maintain confidentiality of Company information during and after the termination of employment, in accordance with Qatari law.
• Avoid conflicts of interest and disclose any actual or potential conflict immediately to management or Human Resources.

IV. Mandatory Reporting and Whistleblowing

Employees are required to promptly report any actual, suspected, or potential violation of this Code, Company policies, or applicable laws, including fraud, corruption, theft, abuse of authority, or unethical conduct.

Reports shall be submitted to the Human Resources Department or any other authorized body designated by the Company. Failure to report known violations may constitute misconduct under the Qatar Labour Law and may result in disciplinary action.

Memar International strictly prohibits retaliation against any employee who reports a violation in good faith, in accordance with the principles of justice and fairness under Qatari legislation.

V. Investigations and Due Process

The Company reserves the right to conduct internal investigations into alleged violations of this Code, in compliance with the procedural safeguards stipulated under the Qatar Labour Law.

Employees are obligated to fully cooperate with investigations, provide accurate information, and comply with investigation procedures. Any obstruction, refusal to cooperate, or provision of false or misleading information shall be considered a serious breach of employment obligations.

Disciplinary measures shall be imposed only after proper investigation, documentation, and notification, in accordance with due process requirements under Qatari law.

VI. Disciplinary Measures

Any violation of this Code shall subject the employee to disciplinary actions consistent with Article (61) and related provisions the Qatar Labour Law, including but not limited to:

• Written warning
• Deduction from wages within legal limits
• Suspension from work with or without pay, as permitted by law
• Termination of employment with notice or summary dismissal where legally justified

The Company reserves the right to refer violations involving criminal or civil liability to the competent Qatari authorities, without prejudice to its right to claim compensation for damages.

VII. Termination and Legal Consequences

Serious violations of this Code, including gross misconduct, breach of trust, fraud, or acts causing substantial harm to the Company, may justify summary termination in accordance with the Qatar Labour Law.

Termination under this Code shall not prejudice the Company’s right to pursue legal remedies under civil or criminal law where applicable.

VIII. Interpretation and Governing Law

This Code shall be governed by and interpreted in accordance with the laws of the State of Qatar. In the event of any conflict between this Code and applicable Qatari law, the provisions of the law shall prevail.

Memar International reserves the right to amend or update this Code in compliance with Qatari legislation. Any amendments shall be binding upon issuance and proper notification.

IX. Acknowledgment

All employees shall acknowledge in writing that they have read, understood, and agreed to comply with this Code of Ethics.

Such acknowledgment shall form an integral part of the employee’s personnel file and employment records.