GFIC s.a.l (“Bank”) adopted the Corporate Governance and Business Ethics Guidelines that set forth the guiding principles and policies governing its activities and its service providers and employees. Thus, the Bank is committed to maintaining high ethical standards and expects all directors, officers and employees, by virtue of their association or employment with the Bank, to adhere to the highest standards of personal and professional integrity and to comply with these Guidelines and all applicable laws, rules and regulations in Lebanon.

The Bank has a legal responsibility to protect clients’ personal and financial information in accordance with Banking Secrecy Law of September 3, 1956. Each employee shall maintain at all times the confidentiality of information acquired in the course of work except when authorized by the client or otherwise legally obligated to disclose. Confidential information acquired in the course of work shall not be used by any employee for any personal advantage. The Bank will strive to maintain compliance with all applicable rules and regulations in Lebanon.

These Guidelines explain the basic principles of ethics and professional business conduct for the Bank and are intended to raise ethical awareness, and as a guide to the day‐to‐day decisions. They can also be used in training programs and to assure customers of the integrity of the Bank. These Guidelines are a codification of standards that are reasonably designed to deter wrongdoing and promote the following objectives:

1. Honest, ethical and professional conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
2. Full, fair, accurate, timely disclosure.
3. Compliance with applicable Lebanese laws, rules and regulations
4. Keep clients’ interest above all personal interests, whereas the bank owes clients a duty of undivided loyalty
5. Maintaining the bank’s reputation and avoiding activities that might reflect adversely on the Bank
6. Accountability for adherence to these guidelines