Business Conduct Policy – Code of Ethics

General
Hod Assaf Industries Ltd (hereinafter: “Hod Assaf Industries” or the “Company”) is a company incorporated and operating under the laws of the State of Israel, whose shares are traded on the Tel Aviv Stock Exchange.
The company has various subsidiaries in Israel, the United States, and Europe.
Hod Assaf Industries believes that it has a responsibility to act in accordance with fundamental principles concerning human behavior, which transcend the fields of industry, culture and economics, as well as local, regional and national borders.

    Incidence
    All employees of Hod Assaf Industries worldwide, including agents and marketers acting on behalf of the company, if any.

    Definition of information assets
    The term “information assets” is defined here as information relating to the company’s business, financial and marketing fields, as well as information regarding sales, service and intellectual property of any kind, in any media.
    This definition includes, but is not limited to, programs, know-how in engineering and manufacturing processes, software, patents, application for patents and the application of patents (and all documents, materials and information supporting or involving them), copyrights (and copyrighted materials), trademarks, as well as any other intellectual property of any kind.
    In addition, employee data and salary-related information.

    Guidelines
    4.1. Compliance with laws and regulations:
    Under no circumstances shall an employee negotiate with any person or entity, shall will he offer to sell them or offer the use of products, without obtaining prior managerial approval, or in violation of any applicable law or regulation.
    All employees will comply with all laws and regulations in Israel, as well as any recognized jurisdiction related to the sale of Hod Assaf Industries products, including other countries in which Hod Assaf Industries or its subsidiaries conduct business.

    4.2. Information Assets:
    Employees will maintain confidentiality, and will not disclose or use, directly or indirectly, both during their employment with Hod Assaf Industries and after its termination, any information assets they receive or create during their employment, whether during working hours or outside these hours, unless this is approved by Hod Assaf Industries.
    Employees are not permitted to copy such information assets, except for legitimate business purposes, or as authorized by Hod Assaf Industries.

    4.3. Conflict of Interest:
    Hod Assaf Industries expects loyalty from its employees.
    It also expects them to be free of any interest, influence, or relationship that may create a conflict of interest with the Good of the Company.
    Employees must avoid any investment or relationship that interferes, or could reasonably be perceived to interfere, with the exercise of their independent judgment in the best interests of the Company.
    In order to fulfill these obligations, employees must avoid conflicts of interest, including, but not limited to, the following:

    4.3.1.
    Employees are not permitted to accept, directly or through their family members or in any other way, any payment, fee, service, privilege, loan (other than from banks or other financial institutions), other benefits or other things of value from any person or business entity that conducts or seeks to conduct business with Hod Assaf Industries, or that is a competitor of Hod Assaf Industries.
    This policy does not prohibit the random and occasional acceptance of gifts, hospitality, and gestures that are generally associated with accepted business practices, provided their value and frequency do not create the appearance of impropriety.

    4.3.2.
    Employees are not permitted to use any information assets of Hod Assaf Industries that they have access to due to their employment with the company, nor are they permitted to disclose them to others, whether for their own personal benefit or for the benefit of others.

    4.3.3.
    A manager will not serve as a member of the Board of Directors, or in any managerial position, or as a consultant to any business entity in the business of manufacturing, processing and/or marketing of steel products (or in any related field), or that maintains any other business relationship with Hod Assaf Industries, without prior disclosure to the General Manager of Hod Assaf Industries, as well as receipt of his written approval.

    4.3.4.
    Employees must disclose to the Company any investment or relationship that could reasonably be considered to interfere with the exercise of their independent judgment in the best interest of the Company.
    There is no need to disclose ownership of less than 5% of the issued securities of a public company.

    4.4. Protection of Hod Assaf Industries assets and their use:
    4.4.1.
    Had Asaf Industries’ assets include not only physical objects but also information assets.
    Each employee is responsible for protecting the assets of Hod Assaf Industries entrusted to him/her, in addition to helping protect the company’s assets in general.
    Accordingly, no information assets may be disclosed without the permission of Hod Assaf Industries.
    Any question posed by anyone outside the company (e.g., analysts, reporters, etc.) will be directed to the CEO or CFO, who will consult Hod Assaf Industries’ legal advisors if necessary.

    4.4.2.
    Hod Assaf Industries’ facilities, equipment and inventory will be used solely for the purpose of conducting the company’s business or for purposes approved by management.

    4.4.3.
    Hod Assaf Industries has the right to access all company assets, including computers, and all communications, e-mail, voice messages, records and information generated within the business environment.
    By using the company’s assets, including its computers, or by creating such records and information, employees grant Hod Assaf Industries their consent to such access.

    4.5. Commitment to employees:
    Every employee in the company is entitled to basic fundamental rights, alongside rights granted to them under labor laws.
    The company is committed to treating every employee with respect, equality and appreciation, and to providing every employee and candidate with an equal opportunity for positions and professional advancement.
    Discrimination of any kind, including on the basis of age, race, ethnicity, sex, religion, disability, sexual orientation, marital status, political opinion, or length of reserve service, is strictly prohibited.

    4.6. Commitment to quality:
    In order to achieve the highest level of quality, Hod Assaf Industries employees are required to focus on continuous improvement of their work activities.
    This includes increasing value to customers through new and improved products and services; reducing errors, defects and waste; improving the level of customer responsiveness; and improving the productivity and efficiency of the utilization of all resources.
    To this end, all employees are expected to know, understand and comply with the quality policies and procedures applicable to their business unit.

    4.7. The company’s commitment to occupational safety and health:
    The company considers occupational safety and health to be a supreme value that constitutes an integral part of all activities in the company and is a necessary condition for meeting the organization’s goals.
    The organization’s policy is based on the prevention of accidents and harm to the health of employees by systematically identifying risk factors in advance, assessing risks and reducing them, and implementing work procedures and methods to meet the organization’s goals and legal requirements, including appropriate training for employees, issued by supervisors on the subject.
    Each manager will be responsible for implementing the safety policy and overseeing safety in his area, while ensuring proper equipment and materials.

    4.8. Commitment to environmental protection:
    As one of the largest recycling facilities, the company adheres to environmental protection rules, including various laws and regulations.
    The company has allocated resources to the issue in order to comply with the requirements of the various laws.
    The person in charge of compliance with environmental protection regulations will ensure that all employees and managers are extremely careful in this regard.

    4.9. Information recording and reporting:
    Every employee creates information records of some kind.
    For example: reporting working hours, product inspection results, service reports and expense reports.
    Company employees must submit reliable reports, both inside and outside the company, since unreliable reporting is not only strictly prohibited, but also constitutes grounds for immediate termination of employment and may lead to civil and even criminal legal liability.
    The above also includes reporting information or organizing it in a manner intended to conceal information or to mislead or misinform those who receive it.
    Particularly serious is external reporting of false or misleading financial information.
    Accordingly, the information must be recorded and reported accurately and honestly.

    4.10. Prohibited payments:
    In dealing with customers, suppliers, government employees or any other person or entity, employees of Hod Assaf Industries or any of its subsidiaries may not, directly or indirectly, give, or offer to give, any payment or anything of significant value, to obtain government or commercial deals or to reward the recipient for a deal that was already obtained.
    The above includes “bribery”, according to the conventional meaning of the term.

    4.11. Political donations:
    No illegal political contribution may be made, directly or indirectly, by or on behalf of Hod Assaf Industries.

    4.12. Prohibition of money laundering:
    The company prohibits any type of money laundering, terrorist financing or any other financing for illegal or illegitimate purposes, and acts in accordance with applicable laws and regulations.
    Company employees are obligated to conduct due diligence on customers, suppliers, and business partners to ensure that the company’s activities are not exploited for illegal purposes.
    Any suspicion of illegal activity or potential violation of anti-money laundering and terrorist financing laws will be brought to the attention of the authorized parties in the company and will be handled in accordance with the provisions of the law.

    4.13. Business relations:
    Any business relationship with others will be in accordance with all applicable laws and regulations.
    Such relationships shall be of such scope and nature that they avoid compromising the integrity of others or of Hod Assaf Industries, and they shall be managed on the basis of the assumption that they will become a matter of public knowledge.

    4.14. Insider information:
    Company employees are required to refrain from using insider information for the purpose of obtaining personal or other advantage, both during their tenure and after termination of their employment.
    Insider information is defined as material information concerning the company, its shareholders, its assets or its business activities, which has not been released to the public and may affect investment decisions or the value of the company’s securities.
    It is strictly prohibited to provide insider information to unauthorized parties or to carry out transactions in the company’s securities based on inside information.
    Prohibited use of insider information may lead to civil and criminal sanctions.

    Compliance
    5.1.
    All company employees working in the positions specified in the procedure for signing the Code of Business Conduct Policy at the date of application of the procedure and upon the entry of each new employee into one of the positions specified in the procedure are required to read this Business Conduct Policy and sign a “Business Conduct Approval Form” (Appendix “A” to this document).
    A signed copy of the approval form will be kept in the employee’s personal file.
    The Company may also request from time to time that the Employee sign such authorization form or similar document (electronically or in any other form) as it deems appropriate.

    5.2.
    All Company employees listed in Section 5.1 above will strictly comply with the Company’s Code of Business Conduct Policy.

    5.3.
    Employees who are aware of violations of this policy must report it to the Company’s CEO or their supervisor or to the Company’s internal auditor or to the Company’s Human Resources Manager.
    The company recommends that employees consult with their supervisors or managers if they have any doubts about the appropriate course of action in a particular case.
    Upon receipt of a report of a violation of this policy, an immediate investigation will be initiated and its findings will be submitted in writing to the Company’s General Manager.
    If a violation of this policy has occurred, it will be grounds for disciplinary action, up to and including termination of employment.