Purposes and Overview

The Standard is applicable to all officers, directors, employees and temporary employees (each, a “Covered Person”) of KRU Overseas Limited and all of its subsidiaries and affiliates.
The Standard summarizes the values, principles and business practices that guide the business conduct of the Company and also provides a set of basic principles to guide Covered Persons regarding the minimum ethical requirements expected of them. The Standard supplements the Company’s existing employee policies and also supplements various other codes of ethics, policies and procedures that have been adopted by the Company or by particular entities within the Company. All Covered Persons are expected to become familiar with the Standard and to apply these principles in the daily performance of their jobs.
Overriding Responsibilities
It is the responsibility of all Covered Persons to maintain a work environment that fosters fairness, respect and integrity. The Company requires all Covered Persons to conduct themselves in a lawful, honest and ethical manner in all of the Company’s business practices.
All Covered Persons are expected to seek the advice of a supervisor, a manager, the Human Resources Department, the Legal Department, the Directors of KRU Overseas Limited for additional guidance or if there is any question about issues discussed in this Standard.
If any Covered Person observes possible unethical or illegal conduct, such concerns or complaints should be reported. It is important to note that violations of the Standard, or the policies referred to in the Standard, could result in consequences such as discipline, including termination of employment or criminal prosecution or both.
Definition of Government Agency, Government Body
For purposes of this Standard, the term “Government Agency”, “Government Body” includes any Cyprus or non-Cyprus. national, federal, provincial, regional, state, or local government agency, commission or legislative body, or self-regulatory organization, including, by way of representative example only, any securities, financial, employment and labor regulators.

The Standard is based on our core values. The purpose of the Standard is to set forth our commitment to high ethical standards. The Standard highlights the values that guide our business conduct, provides relevant questions and answers for situations that you might encounter on the job, and lists resources for help or further information.

However, it is impossible for the Standard to address every possible workplace situation or list every policy and procedure. Use the Standard for guidance about our ethical standards, where to take your questions or concerns, and where to review relevant company policies.

When each of us follows the Standard, we “walk the talk” and communicate our commitment to the values that have made KRU Overseas Limited admired both as a business partner and as an employer.