Code of Deontology and Ethics of the Commission for the Organization and Supervision of Stock Exchange Operations (COSOB)

THE ALGERIAN DEMOCRATIC AND POPULAR REPUBLIC COSOB CODE OF DEONTOLOGY AND ETHICS OF THE COMMISSION FOR THE ORGANIZATION AND SUPERVISION OF STOCK EXCHANGE OPERATIONS – COSOB Commission for the Organization and Supervision of Stock Exchange Operations

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TABLE OF CONTENTS Letter from the President Page 4 Preamble Page 5 I. The Objective of the Code of Deontology and Ethics Page 7 II. Scope of Application Page 7 III. Our Values Page 8

1. Our Fundamental Values: Page 8

• Commitment to the National Economic Interest Page 8
• Ethics Page 9
• Professionalism Page 9
• Trust and Team Spirit Page 10
• Good Governance and the Quest for Excellence Page 11
• Equity Page 12

2. Our Internal Values: Page 12

• Training and Improvement of Employee Skills Page 12
• Improvement of the Quality of the Work and Social Environment Page 13
• Satisfaction and Respect for Operators and Partners Page 13
• Sustainable Development and Respect for the Environment Page 14 IV. COSOB Code of Conduct Page 14 Section I. In its relations with the public: Page 14
• Institutional Governance Page 14
• Control System Page 15
• Communication and Information to the Market Page 15 Section II. In its relations with operators: Page 16
• Handling of Information Page 16
• Gifts, Free Items Page 16
• Money Page 16
• Advantages Page 17
• Influence Page 17 Section III. In its relations with employees Page 17
• Personnel Selection Page 17
• Establishment of the Employment Relationship Page 17
• Working Hours and Employee Participation Page 17
• Obligations of Employees and Collaborators Page 18 Section IV. In its relations with institutions Page 18 V. Ethical Code 1- Respect for Laws, Regulations, and Internal Policies Page 19 2- Confidentiality Page 20 3- Loyalty / Integrity Page 21 4- Objectivity / Conflicts of Interest Page 22 VI. Implementation Modalities Page 25
• Deontology and Ethics Committee Page 25 a. Composition of the Committee Page 25 b. Responsibilities Page 25 c. Implementation of Agreed Actions Page 26 d. Procedure Prior to Imposition of Disciplinary Measures Page 26 e. Disciplinary Measures Page 26

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Letter from the President: COSOB, entrusted with a public service mission, is today an indispensable partner on the Algerian financial market. It is a set of practices and diverse experiences derived from the numerous operations and interventions carried out since its creation. Our realities and objectives, although sometimes different from those of market participants, remain common in terms of deontology and ethics rules, which must be the same for each of us, regardless of our position. In this spirit, COSOB has adopted a new Code of Deontology and Ethics, a document that defines the duties and responsibilities of each of us in conducting our activities both within the institution and towards all stakeholders of the financial market and our partners. This Code is a code of conduct and has the value of a common identifier for all of us, but also for every participant in the stock market. Therefore, each of us is obliged to read it, make it known, and ensure its respect, while reporting any behavior non-compliant with the principles and criteria of conduct contained in this Code. This obligation is also enforceable against our partners. We count on each of you. Abdelhakim BERRAH

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Preamble: The missions of organizing and supervising the financial market, as a public service, are custodians of the trust of operators, whether savers or investors. It is therefore incumbent upon the management and all COSOB personnel responsible for these missions, towards the public authorities and financial market operators, to demonstrate loyalty to the laws and principles of ethics above all other considerations. Financial market operators, for their part, have every interest in having full confidence in their regulator in terms of ethics and are also entitled to expect that all employees responsible for organizing and supervising stock exchange operations are honest, impartial, and professional in applying their skills, knowledge, experience, and the exercise of official powers conferred upon them. Given that transparency and the dissemination of information constitute the foundation of the integrity and efficiency of a financial market, COSOB aspires to maintain and develop a relationship of trust with all stakeholders (stakeholders) active on the stock market, that is, with all operators and institutions that have a common interest in the optimal fulfillment of its missions and whose contribution is indispensable to their realization. In a broader sense, stakeholders are considered to be all those who make investments, whether issuers or subscribers of securities, first and foremost, and secondly, employees as well as organizations and institutions representing the public, whose interests are influenced by the direct and indirect effects of COSOB's activities. Good reputation is an essential intangible resource; externally, it favors investment by giving more assurance to issuers and strengthening the confidence of creditors, while also contributing to retaining qualified human resources. Internally, it aids decision-making and its implementation without constraints, and organizes work without resorting to bureaucratic controls or excessive exercise of authority.

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It is within this global vision that COSOB has set two key objectives to strengthen a favorable business climate within the stock market; namely:

• The elaboration and publication of a code of deontology and ethics that specifies the particular fiduciary obligations of COSOB towards stakeholders and sets out the rules of conduct to which all its employees must submit, as well as the entire rights and duties attached to them;
• The acceptance by COSOB employees, regardless of their hierarchical level or status, to observe the rules of conduct in the exercise of their missions in the most rigorous manner and to adhere to these same levels of ethics even in their personal lives. This code of deontology and ethics recalls:
• The general principles governing relations with stakeholders, which define in an abstract manner the reference values on which COSOB's activities are based;
• The criteria of conduct and behavior towards stakeholders, which provide in detail the guidelines and rules to which COSOB employees are bound to conform out of respect for its values and to prevent the risk of unethical behavior;
• The implementation mechanisms, which describe the system that ensures respect for this Code and its constant improvement.

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I. The Objective of the Code of Deontology and Ethics: This code of deontology and ethics expresses, in concrete and precise terms, the ethical obligations and responsibilities that must be observed in the exercise of COSOB's activities and the conduct of its employees, whether managers or executives. It constitutes the appropriate framework for the fulfillment of the missions specific to the regulation of the financial market, in respect of the rights and duties governing this activity, the rules of conduct of those who exercise it both collectively and individually, and the relationships between them and the operators of this market. Based on fundamental values that guide securities markets – integrity, honesty, equity, justice, and loyalty... – it aims to guarantee professional deontology and impeccable ethical practice on the part of employees. It supplements other existing normative documents at COSOB, whether individual employment contracts, internal regulations, IT charters, work procedures, or the regulatory framework governing its activities. While it gives an overview of what should be considered proper conduct, this code cannot, however, address all situations that may arise, which is why employees are required to act using their common sense and referring to their conscience.

II. Scope of Application: The principles and provisions of this code of deontology and ethics address COSOB employees, all categories combined, as well as partners linked to COSOB by contractual relations of any nature, whether occasional and/or only temporary. Members of the Commission, for their part, adhere rather to a code of conduct and ethics specific to them. This guide is not a contractual or conventional framework between the administration and the collective workforce of COSOB, but the latter are committed to reading it and taking note of it, applying its content, and confirming to the employer that they have taken note of it at the time of their recruitment and attesting to conforming to it throughout their career.

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COSOB will keep in each employee's file the confirmation of reading and their commitment to comply with it. Any employee who retains the services of interns, contractual workers, consultants, and service providers must ensure that these persons respect the principles and standards established by this Code. The rules provided for in this Code apply at all times and in all places during the exercise of functions on behalf of COSOB, whether for professional or social activities. Administrative and hierarchical managers are the persons responsible for supporting and advising any employee regarding the application of this Code. Furthermore, COSOB requires all operators active on the financial market to adopt, particularly in the context of their relations with its structures, conduct consistent with the general principles of this Code.

III. Our Values: To successfully carry out the missions entrusted to it by regulation and those resulting from the functioning of the financial market, COSOB, in all decisions relating to its relations with financial market operators, the management of its human resources or its internal organization, the selection and choice of its partners, its relations with the surrounding community and institutions representing it; relies on a set of main values that revolve around the following axes:

1. Our Fundamental Values

• Commitment to the National Economic Interest: COSOB, as a public authority entrusted with a mission of organizing and controlling the public service related to the competitive and transparent functioning of the financial market, has the primary objective of serving the national economic interest and contributing to its growth and development based on its intangible values, competence, and the involvement of its human resources.

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Aware of the direct and indirect influences that its activities have on conditions, economic and social development, and the general well-being of the community, COSOB intends to act in a sustainable manner to strengthen its presence in the national financial system and to be uncompromising in preserving the interests of the nation.

• Ethics: COSOB is the guarantor of the application and respect of ethical principles in the conduct of all operations it carries out within the framework of its activities. It bases its relations with all its employees, partners, and all financial market operators on ethical principles closely linked to honesty and integrity. In the fulfillment of its missions, COSOB scrupulously respects the legislation and regulations in force, this code of deontology and ethics, and its internal regulations adopted. Under no circumstances can the preservation of the institution's interests justify disloyal conduct. COSOB avoids all situations where its employees may be or merely appear to be in a conflict of interest. This remains valid not only for situations where an employee pursues an interest contrary to their missions and that of the operators, but also for cases where representatives of operators, partners, or public institutions act in a manner contrary to the fiduciary obligations linked to their position in their relations with COSOB. Every employee should also be aware of their moral responsibility and the ethical duty to detect and report infractions and criminal acts that may harm the reputation and proper functioning of COSOB and the financial market.

• Professionalism: COSOB employees are the indispensable factor in its success, for this reason: It strengthens the professionalism of its staff and encourages individual know-how, innovative spirit, creativity, and initiative.

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It works to defend and promote the value of human resources in order to improve and increase the assets and competitiveness of each employee's skills. It commits to ensuring that authority is exercised fairly and correctly, avoiding any abuse. In particular, it guarantees that this authority does not turn into an exercise of power harmful to the dignity and autonomy of employees, and that choices regarding work organization preserve their value. It ensures that employment contracts and mandates must be executed with diligence and precision according to the terms fixed with full knowledge by the contracting parties. It commits to not exploiting conditions of ignorance or incapacity that may affect them.

• Trust and Team Spirit: COSOB respects its employees, treats them with dignity, trusts them, shows appreciation, preserves their health, ensures their safety, and protects them in their work. It works so that each member of its staff maintains loyal, respectful, and honest relations with colleagues, partners, and all financial market operators. COSOB guarantees the confidentiality of information in its possession and abstains from seeking confidential data concerning stock market operators, except with express and informed authorization, and only in conformity with the legislation and regulations in force. COSOB employees are required not to use confidential information for purposes unrelated to the exercise of their activity, such as in the case of insider trading or market manipulation. COSOB honors its commitments towards its partners, its employees, and all operators and institutions with which it maintains contractual relations.

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Starting from the principle of whistleblowing ratified by COSOB, it encourages any employee who, in the exercise of their functions, acquires knowledge of an infraction or criminal act to notify their hierarchy or the authority having the power to follow up on it, and affirms, to this end, that all possible measures will be taken to protect them against any form of retaliation.

• Good Governance and the Quest for Excellence: COSOB commits to providing complete, transparent, understandable, and precise information, so that it is able to take all decisions relating to its relations with stock market stakeholders, autonomously and informed on all interests and issues as well as the most important alternatives and consequences. In particular, in the conclusion of contracts, COSOB takes care to specify to the counterparty the behaviors to adopt in all foreseeable circumstances, in a clear and understandable manner. COSOB obliges its employees to ensure that the information they provide by correspondence to COSOB partners and financial market operators is accurate and complete. To this end, any correspondence intended for the outside must be subject to prior verification by the hierarchy. COSOB orients its activity towards the satisfaction and protection of operators active on the financial market; it listens to them with the aim of bringing necessary improvements to the quality of its services. For this reason, it orients its research and development activities to achieve high standards of public service quality. COSOB obliges its employees to protect the assets of the institution, notably by taking care of the equipment made available to them and ensuring their proper use. COSOB must constitute an archive fund and conserve all historical documents produced or received by its structures in the exercise of their activities, regardless of their date, form, or material supports. It must mandatory deposit all documents of archival interest to the Institution in charge of national archives as soon as they are no longer necessary to it.

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• Equity: In all decisions relating to its activities, COSOB avoids any discrimination based on age, sex, health status, race, political opinions, or religious beliefs of its interlocutors. It ensures that women and men have the same employment opportunities, professional development, and access to equal skills for positions of responsibility at all levels. COSOB respects the principles of fair competition and prohibits any behavior and practice that could be qualified as anti-competitive. It must defend and ensure respect for competition within the financial market by fighting against collusive behaviors, predation, or any form of abuse of dominant position. It avoids in its relations that anyone acting on its behalf and for its account seeks to take advantage of contractual loopholes or unforeseen events to renegotiate the contract solely to profit from the position of dependence or weakness in which the counterparty might find themselves.

2. Our Internal Values

• Training and Improvement of Employee Skills: COSOB devotes particular effort to the training of its employees and attaches substantial importance to the professional development of its employees; to achieve this, it regularly provides them with training to enable them to reach the required level of expertise and qualification. Upgrading, learning, and acquiring new knowledge is done notably by:
• training necessary within the framework of the employee's functions; and
• training within the framework of professional development. To this end, it gives each employee, in collaboration with their superior, the responsibility to meet their training needs, both for the accomplishment of their tasks and for their professional development. COSOB recognizes the importance and measures the necessity of establishing and maintaining cooperation relations with national and international homologous bodies, in order to access their know-how in the field and draw inspiration from their wide experience.

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In this perspective, it participates in all gatherings, seminars, and meetings organized, as it takes part in research work engaged in within the frameworks of cooperation relating to the standardization of the financial market.

• Improvement of the Quality of the Work and Social Environment: COSOB attaches particular importance to the improvement of its managerial mode, its organization, and the functioning of its structures in order to establish a healthy, stimulating work climate favorable to professional fulfillment and the development of a public institution culture based on the recognition of skills and performance. COSOB guarantees the physical and moral integrity of its employees, working conditions respectful of individual dignity, behavior rules based on good manners, and a safe and healthy work environment. The institution also acts so that cases of intimidation, harassment, or bullying do not occur in the workplace. It tolerates no attempt to incite persons to act against legislation and regulations or this Code, or to adopt behaviors harmful to the convictions and moral and personal preferences of each individual. It rewards and recognizes the loyalty of its employees. It is a moral commitment requiring fidelity and respect. COSOB also affirms that anyone who, by any means whatsoever, has made a calumnious denunciation against one or more of its employees, will be subject to disciplinary measures and may even be prosecuted in court. The obligation without cause, or on a false cause, or on an illicit cause, can have no effect.

• Satisfaction and Respect for Operators and Partners: COSOB employees are required to observe the required standards of ethics and professional conduct in the exercise of their functions and missions. They must act with prudence, efficiency, diligence, and equity, and respect the obligation of loyalty and honesty in all their relations with financial market operators and their employer's partners. In order to address all complaints from operators, every employee must have complete and in-depth knowledge of securities.

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They must understand the structure and functioning of these values, the procedure for their exchange, their liquidity, and all risks associated with them. Every employee must have sufficient knowledge of market operators and maintain up-to-date information bases concerning them. They must also foster trust links with them and provide them, if needed, with sincere, clear, and complete explanations, frankly and without restrictions. They also have the duty to ensure the appropriateness of their recommendations and to keep their fiduciary obligations in mind.

• Sustainable Development and Respect for the Environment: The environment is a primary good...