ETHICAL CODE

In 2012, Shikun & Binui adopted a Code of Ethics that reflects the Group’s values and the professional ethical principles which apply to its employees and executives. The primary purpose of the Code of Ethics is to provide employees and executives with tools to help them make a decision that is in line with the proper conduct in various situations in the course of their work. The Code of Ethics also specifies functions which may be contacted in order to report, or seek advice for, related issues, as well as information about the hotline and an email address for anonymous inquiries. According to our Code of Ethics, all Shikun & Binui employees must comply with the law, act in good faith and integrity, and in accordance with our guiding principles, the sustainability approach, and the Group’s policies, enforcement programs and procedures. The Code of Ethics includes instructions, guidelines and guidance on a wide range of topics, such as: Treating colleagues and stakeholders with respect; preventing conflicts of interest; prohibition on giving and accepting bribes; information security; use of the Group’s resources; obligations arising from Shikun & Binui’s status as a publicly traded Company; safety; donations; community outreach, etc. According to the Code of Ethics, Shikun & Binui has adopted a zero tolerance approach towards bribes and corruption. We implement an extensive enforcement program for preventing bribes and corruption. We strictly adhere to the provisions of the law and the rules of the Tel Aviv Stock Exchange, in order to maintain shareholders’ confidence in the Company. We implement an enforcement program in the securities domain, which outlines rules, guidelines and provisions on the topic. Shikun & Binui is constantly working to instill the principles of its Code of Ethics in various ways, in Israel and in all of our sites around the world, including: activities and lectures for employees and executives in the countries of operation; onboarding day for newly hired employees; animated videos; circulars outlining potential dilemmas, accompanied by examples which illustrate how to implement the Code of Ethics’ principles, etc.