Policy of the Company regarding zero-tolerance to enforcement, bribery and corruption events 

Update date: March 21, 2021 

Israel Shipyards Industries Ltd. (hereinafter: the ‘Company’) is obligated to conduct business with integrity, according to the strictest principles of ethics, and a policy of zero-tolerance in respect of enforcement events in the field of securities and bribery and corruption events of any kind (hereinafter: the ‘Policy’). 

Accordingly, the Company obliges its employees and the employees of its subsidiaries to engage in proper business conduct at any time and prohibits each employee and each officer in the Company to take any part, whether actively and/or passively, in acts of bribery and corruption and in acts that constitute violation of the enforcement program of the Company. 

In addition, the Company expects from each of its business partners, including suppliers, contractors, agents, brokers or consultants who act on behalf of and in the name of the Company, or together with the Company with a customer or a potential customer, or with a government agency (hereinafter: a ‘Business Partner’) to apply similar policy and to avoid taking any part, whether actively and/or passively, in the breach of securities laws and in acts of bribery and corruption. 

The following are the principles of the Policy: 

1. The Company practices a zero-tolerance policy with respect to the breach of securities law and acts of bribery and corruption. The Company and its employees will not take part, by way of an act or omission, whether directly or indirectly, in the breach of securities laws and in acts of bribery and corruption. 

2. The Company will not give and will not receive from any person, whether directly or indirectly, anything valuable for the purpose of obtaining or rewarding a benefit that was achieved by improper action or any other action for the purpose of gaining an undue advantage. 

3. The Company and its employees will comply with the requirements specified in any laws, contracts and standards for the purpose of preventing bribery and corruption applicable to them. The Company and its employees will observe strictly the entire provisions set forth in the enforcement program that was adopted by the Company, even where this program is stricter compared to the governing provisions of the law.

4. The Company observes strictly a policy of protection of integrity in connection with contractors and service providers, including avoidance from conflict of interests towards its managers and employees. 

5. The foundations of this policy are based on honest and direct communication, while observing fairness and dignity towards government agencies, customers and suppliers. 

6. The Company is committed to the protection of the rules of fair competition, while avoiding from agreements and understandings that fail to comply with the provisions of the law. 

7. The Company will keep accurate and true records that will be displayed in a proper and full manner for the purpose of assuring reliable reporting to its stakeholders. 

8. The Company will notify the employees of the Company and its business partners about the policy of the Company, and will publish its policy in the internet website of the Company. 

9. The managers and employees of the Company will keep in confidence and avoid any act that constitutes abuse of inside information. 

10. The Company also encourages any person to report to the Company about any attempt, suspicion or actual violation of the principles laid down in the policy and the instructions set forth in the program, and will apply an anonymous reporting mechanism together with instructions in the procedure that prohibit harm or harassment against the reporting person.