BUKHATIR GROUP

Strength through Diversity

Group Policy and Procedure

Group Supply Chain (GSC)

Introduction

Framework, Principles & Governance

Document No: P-POL-001

Copyright © 2026 Bukhatir Group

Revision Control

This document is issued under the authority of Bukhatir Group and applies when carrying out the activities described. Revisions may be issued as necessary under the authority of the Group Head of Procurement. Revision history is recorded below with every revised policy.

Revision History

Revision Sign-Off

Distribution List

1. Purpose & Objective

This Introduction establishes the framework for the Bukhatir Group Procurement and Supply Chain Policies (SOP 1 through SOP 6). It sets out the governance, principles, roles and standards of conduct that apply to all procurement activity across the Group.

2. Vision & Mission

Vision

To be a trusted, best-in-class shared procurement function that enables the growth ambitions of every Bukhatir Group business unit through strategic sourcing, supplier partnerships and disciplined value capture.

Mission

Deliver measurable value, manage risk and uphold integrity across the Group's source-to-pay lifecycle — from demand planning to supplier performance — while supporting sustainability, Emiratisation and local content ambitions.

3. Guiding Principles

• Integrity — zero tolerance for bribery, corruption, fraud, collusion or conflicts of interest.
• Transparency — all procurement activity is documented, auditable and traceable.
• Best Value — decisions based on the lowest price with the best technical match and best overall value.
• Fair Competition — suppliers compete on a level, impartial playing field.
• Risk-based Controls — controls scale with value, complexity and strategic importance.
• Digital by Default — Oracle / e-sourcing platforms are the single source of truth.

4. Governance & Roles (RACI)

The following RACI matrix defines accountability for the procurement lifecycle across the Group. R = Responsible, A = Accountable, C = Consulted, I = Informed.

5. Policy Hierarchy

Procurement policy is organised as a 3-tier structure:

1. Tier 1 — Code & Principles: the Group Code of Conduct, this SOP-Intro and the Procurement Charter.
2. Tier 2 — Policies (SOP 1–6): the detailed procedural standards for each lifecycle stage.
3. Tier 3 — Working Instructions, Templates & System Configurations: operational guides, forms, approval matrices and Oracle system controls.

6. Code of Conduct

For Buyers

• Act with honesty, impartiality and integrity at all times.
• Declare any actual, potential or perceived conflict of interest in writing before any transaction.
• Do not accept gifts, hospitality or favours from suppliers beyond the de minimis threshold defined in the Group Gifts & Hospitality Policy.
• Maintain supplier confidentiality and never share competitive information.
• Segregate incompatible duties (issuer, approver, receiver).

For Suppliers

• Comply with UAE law, anti-bribery and sanctions regulations.
• Deliver goods and services that meet contractual quality and HSE standards.
• Protect Group data and honour cyber-security and UAE PDPL data protection obligations.
• Disclose beneficial ownership and any sub-contracting arrangements.

7. Definitions & Acronyms

8. Review & Ownership

This policy is owned by the Group Head of Supply Chain and shall be reviewed at least annually, or whenever a material change in law, business structure or risk profile occurs. Proposed changes are endorsed by the Head of Supply Chain, reviewed by the CFO and Legal, and approved by the Group Vice Chairman & CEO.