Page 31 - JTC-Annual Report-2025-Eng

The Code also sets out clear controls prohibiting the misuse or exploitation of inside or non-
public information for personal gain or for the benefit of third parties, and affirms the principles
of fairness and equal treatment in dealings with all related parties.

The Company has established internal mechanisms that allow for the reporting of any improper
practices, violations, or suspicions related to financial reporting, internal control systems, or other
matters, while ensuring the necessary protection and confidentiality for whistleblowers, and
without exposing them to any retaliatory or adverse actions as a result of such reporting.

Conflict of Interest Policy

The Company adopts a clear conflict of interest policy approved by the Board of Directors, which
aims to mitigate and manage situations in which a conflict may arise between personal interests
and the interests of the Company.

This policy provides, without limitation, that a Board member is required to disclose to the Board
of Directors any personal interest in business or contracts entered into for the account of the
Company. Such disclosure shall be recorded in the minutes of the Board meetings, and the Board
member concerned shall refrain from participating in the deliberation and voting on resolutions
relating to such businesses or contracts.

In addition, the Chairman of the Board is required to inform the General Assembly of any
businesses or contracts in which any Board member has a personal interest, accompanied by a
special report from the external auditor, in accordance with the requirements of the applicable
laws and regulations.

The Seventh Rule: Ensure Timely and High-Quality Disclosure and Transparency

Summary of the Implementation of Accurate and Transparent Disclosure Mechanisms
covering the Aspects, Areas, and Characteristics of Disclosure

The Company adopts a Disclosure and Transparency Policy aimed at enabling shareholders,
investors, and stakeholders to access material information related to the Company, its activities,
performance, and financial position, in a manner that enhances confidence, clarity, fairness, and
equal opportunities.

The Company is committed to providing accurate and timely disclosure of all material information
in accordance with the requirements of the Capital Markets Authority, Boursa Kuwait, and
other relevant regulatory authorities. Such disclosure includes, but is not limited to, financial
statements, business results, ownership structure, and any material developments that may
affect the Company’s activities or financial position.

Overview of the Implementation of the Disclosure Register requirements for Board
Members and Executive Management

The Company maintains a special register that contains the disclosures of members of the Board
of Directors and the Executive Management. It includes the data relating to their transactions
according to the insider trading disclosure rules for companies listed on Boursa Kuwait. The
data of the Register is updated periodically and contains information related to remunerations,
salaries, incentives and other financial advantages included in the annual report presented to the
General Assembly. The register is made available to any shareholder upon request, free of charge.

30 JTC LogisTiCs TransporTaTion & sTevedoring Company K.s.C.p.