Group Policy & Procedure

BUKHATIR GROUP

Strength through Diversity

Insurance Sourcing & Centralized Broker Engagement

GSC as Sole Market Channel, 60-Day Rule & Broker Panel

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 but shall be considered approved only once it has been signed off by all approving authorities. Revision history is recorded below with every revised policy.

Revision History

Distribution List

1. Purpose & Objective

This policy establishes Group Supply Chain (GSC) as the single, centralized sourcing authority for all insurance programs and policies required by Bukhatir Group and its Business Units (BUs). The objective is to consolidate the Group's insurance spend, leverage collective bargaining power with insurers and brokers, ensure consistent coverage standards, and avoid fragmented or duplicate market approaches by individual BUs.

P-POL-028 governs the sourcing process by which those policies are procured from the insurance market.

2. Scope

This policy applies to all insurance policies procured by any Bukhatir Group entity, including but not limited to:

• Property (Fire, All-Risks, Business Interruption)
• Motor Fleet & Commercial Vehicles
• Marine Cargo & Inland Transit
• Group Medical / Health Insurance
• Group Life & Workmen's Compensation
• Public Liability & Third-Party Liability
• Professional Indemnity / Errors & Omissions
• Directors & Officers (D&O) Liability
• Cyber Liability
• Contractor / Erection All Risks (CAR / EAR) for projects
• Machinery Breakdown, Electronic Equipment and other specialty lines

Statutory insurances mandated by UAE law (e.g., Workmen's Compensation, motor third-party) remain subject to this policy for sourcing, even where purchase is obligatory.

3. Governing Principle — Single Market-Facing Channel

GSC IS THE ONLY BUKHATIR GROUP PARTY AUTHORIZED TO APPROACH THE INSURANCE MARKET

No Business Unit, department, project team, or individual employee is permitted to directly contact insurance companies, underwriters, brokers, or intermediaries to request quotations, negotiate terms, bind cover, or renew policies. All such interactions are centralized through the Group Supply Chain function. Any quotation, proposal, or binder obtained outside this channel is deemed unauthorized and will not be honoured by Finance for payment or reimbursement.

This central channel applies regardless of the BU, policy size, or relationship history with a given broker. Long-standing broker or underwriter relationships held at BU level must be transitioned to GSC within ninety (90) days of this policy's effective date.

4. Roles & Responsibilities

5. The Two-Month Rule — Advance Submission of Sourcing Requests

60-DAY MINIMUM LEAD TIME

Every Business Unit must submit its Insurance Sourcing Request to GSC no later than two (2) months (60 calendar days) before the expiry of the existing policy. Requests received with less than 60 days' notice will be treated as late submissions and may result in restricted market access, higher premiums, or short-period extensions at the BU's cost.

Late submissions create the following risks that the BU will be held accountable for:

• Insufficient time to run a proper competitive RFQ — the Group loses bargaining leverage.
• Restricted pool of insurers / brokers willing to quote on a rushed basis.
• Lapse in cover, creating uninsured exposure — a breach of fiduciary duty and, in some lines, UAE statutory obligations.
• Need for emergency short-term cover at punitive rates.

Where a BU genuinely cannot meet the 60-day rule (e.g., newly acquired entity, first-time cover), the BU insurance requestor must submit a written justification to the GSC Head of Supply Chain, who may approve an expedited process (Emergency & Crisis Procurement).

6. Mandatory Supporting Documents for Sourcing

The Insurance Sourcing Request (F-INS-SRC-01) must be accompanied by a complete underwriting pack. Incomplete submissions will be returned to the BU and the 60-day clock will not start until a complete pack is received by GSC.

7. Insurance Sourcing Workflow

The end-to-end workflow from BU request to policy placement is as follows:

1. BU identifies the need — at least 75 days before expiry, the BU begins gathering underwriting information.
2. BU submits F-INS-SRC-01 + supporting documents to GSC no later than 60 days before expiry.
3. GSC acknowledges receipt within 2 working days and confirms pack completeness. Incomplete packs are returned.
4. GSC issues RFQ to the Approved Broker Panel and, where appropriate, directly to selected insurers.
5. Brokers / insurers submit quotations directly to GSC. Any quote received by a BU is redirected to GSC without action.
6. GSC evaluates quotes against cost, coverage scope, insurer financial strength (AM Best / S&P rating), claims service, and alignment with minimum coverage standards.
7. GSC shares the consolidated quote comparison sheet with the BU, with a recommended option and rationale.
8. BU reviews, consults Group Risk if needed, and confirms its selection within 5 working days.
9. GSC instructs the selected broker / insurer to issue the binder and final policy documentation.
10. Finance approves premium payment per DOA. Cover is bound before expiry of the existing policy.
11. GSC files the final policy, schedule and wording in the Central Insurance Register, and enters renewal alerts 75 / 60 / 30 days before the next expiry.

8. Approved Broker Panel

GSC maintains the Group's Approved Broker Panel. Inclusion is based on:

• UAE Insurance Authority / Central Bank of UAE licensing.
• Minimum three (3) years' track record with Group-scale accounts.
• Demonstrated access to A-rated regional and international insurance markets.
• Signed Broker Engagement Agreement incorporating GSC's Code of Conduct and confidentiality terms.
• Acknowledgment that all instructions will come exclusively from GSC.

The panel is reviewed annually. Under-performing or non-compliant brokers are removed. At least two (2) brokers will be invited to each RFQ to preserve competitive pressure.

8.1 Mandatory Broker / Consultant Rotation

MAXIMUM TWO (2) CONSECUTIVE YEARS WITH THE SAME BROKER PER POLICY LINE

No Business Unit may retain the same broker or insurance consultant for any single insurance policy line for more than two (2) consecutive policy years. At the end of the second consecutive year, the incumbent broker must be replaced with an alternative broker from the Approved Broker Panel for that policy line.

This mandatory rotation applies per policy line, per BU — meaning a broker rotated out of one BU's Motor Fleet policy may still serve that BU on a different line (e.g., Property), provided the two-year limit has not been reached on that line.

The rotation requirement ensures:

• Fresh market perspective and competitive tension at each renewal cycle.
• Prevention of complacency, over-reliance, or undue influence by a single intermediary.
• Broader market coverage as different brokers bring access to different insurer panels.
• Reduced concentration risk in the Group's broker relationships.

GSC will maintain a Broker Assignment Register tracking which broker serves each BU on each policy line and the number of consecutive years. Automated alerts will flag any assignment approaching the two-year limit at the T-75 day renewal trigger.

Exception: In exceptional circumstances — for example, a highly specialized line where only one approved broker has the required expertise — the GSC Head of Supply Chain may grant a one-year extension, subject to written justification and Group CFO approval. Extensions beyond three consecutive years are not permitted under any circumstances.

9. Prohibited Practices

THE FOLLOWING ACTIONS ARE STRICTLY PROHIBITED

The following actions by BUs, departments, or individual employees constitute a breach of this policy:

• Directly contacting insurers, underwriters or brokers to request quotations without GSC authorization.
• Accepting or signing binders, cover notes, proposals or policy documents independent of GSC.
• Renewing a policy directly with the incumbent insurer without running a competitive process through GSC.
• Disclosing the Group's consolidated claims data, premiums, or broker relationships to unauthorized third parties.
• Accepting gifts, commissions, rebates or inducements from brokers or insurers
• Splitting insurance spend across multiple BUs or policies to avoid GSC oversight thresholds.

10. Group Consolidation & Master Policies

Where beneficial, GSC will structure Group Master Policies that cover multiple BUs under a single programme (e.g., Group Property, Group Motor Fleet, Group Medical). Master policies typically achieve:

• Premium savings of 10–25% through consolidated purchasing power.
• Uniform coverage standards across BUs.
• Simplified claims handling and single broker / insurer interface.
• Stronger negotiation position at renewal based on aggregated loss history.

BUs benefit from Group Master Policies via an internal allocation mechanism agreed with Group Finance. A BU cannot opt out of a Master Policy without written approval from the Group CFO and the GSC Head of Supply Chain.

11. Minimum Coverage Standards

GSC, maintains minimum coverage standards per line of insurance. These standards are non-negotiable floors — BUs may request higher limits but not lower. Refer to P-POL-024 Section 5 for contract-driven thresholds and to the Group Insurance Standards Annex for line-specific minima.

12. Central Insurance Register & Renewal Tracking

GSC maintains a Central Insurance Register covering every active policy across the Group, including:

• Policy number, insurer, broker, line of cover, sum insured, deductible, premium.
• Inception and expiry dates; next renewal action dates (T-75, T-60, T-30).
• BU / entity covered, location(s), schedule references.
• Claims activity and loss ratio by policy year.

The register is reconciled monthly with Finance and reviewed quarterly by the Group CFO. Automated alerts are issued to BUs at T-75, T-60, T-45 and T-30 days before expiry.

13. Claims Handling — BU-Led, Broker-Interface

Whilst sourcing, renewal and market engagement are centralized under GSC, day-to-day claims handling is managed directly between the Business Unit and the GSC-appointed broker for the relevant policy.

BU’s can raise performance issues of the Broker with GSC. GSC will be required to check into these performance issues and find a solution for the BU’s. Refer clause 13.3 for more details.

13.1 Operating Model

DIRECT BU ↔ BROKER CHANNEL FOR CLAIMS

For every policy placed by GSC, the appointed broker is the BU's single point of contact for claim notification, documentation, loss adjuster coordination, and settlement discussions.

13.2 BU Responsibilities

1. Notify the GSC-appointed broker within 24 hours of any claim event (48 hours for minor / low-value claims), using F-INS-SRC-04 (Claim Notification Form).
2. Provide all supporting evidence: statements, photographs, police / civil-defence reports, invoices, repair quotations, medical reports, asset registers.
3. Liaise directly with the broker, insurer and loss adjuster throughout the claim lifecycle.
4. Review and confirm settlement offers, subject to the escalation thresholds in Section 13.3.
5. Maintain the BU-level Insurance & Claims Register and keep it current throughout the policy period.
6. Report loss ratios, open claims and settlement trends to the BU Head monthly, and to GSC at each renewal cycle.

13.3 When to Escalate to GSC

The BU must involve GSC (and, where relevant, Group Risk / Finance) in any of the following situations:

• The insurer disputes coverage, proposes partial repudiation, or issues a reservation-of-rights letter.
• The claim value exceeds AED 500,000 or triggers a material deductible.
• The claim involves bodily injury, fatality, environmental damage, or third-party litigation.
• The insurer proposes a settlement that the BU considers unreasonable.
• The claim affects a Group Master Policy or has cross-BU implications.
• The broker is unresponsive or performing below expected service standards.
• Any regulatory, media, or reputational sensitivity is attached to the event.

BUs must not sign final releases or settlement agreements on escalated claims without GSC's prior written concurrence.

13.4 BU-Level Insurance & Claims Register

Every Business Unit must maintain its own Insurance & Claims Register covering all policies placed on its behalf by GSC. The register must include policy schedules, wordings, endorsements, claim logs, loss ratio calculations, open-claims aging, and escalation records.

The register is owned by the BU Finance Controller (or HR Head for medical / life policies), reviewed monthly by the BU Head, and submitted to GSC at least 75 days before renewal.

14. Mandatory Document Maintenance by Business Units

All Bukhatir Group entities are required to maintain, update, and readily share the documents specified in this section for each insurance line. Complete and current documentation is essential for competitive sourcing, accurate underwriting, and timely claims resolution.

14.1 Document Ownership

BU FINANCE — All insurance lines except Medical Insurance

BU HR — Medical Insurance documents

BU Finance is responsible for maintaining all insurance-related documents across all lines of cover, with the sole exception of Medical Insurance. Medical Insurance documents — including census data, Table of Benefits, DHA reports, and utilization reports — are the responsibility of BU HR.

Both BU Finance and BU HR must ensure that their respective documents are accurate, up to date, and available immediately upon request from Group Procurement (GSC).

14.2 Common Requirements (All Insurance Lines)

The following documents must be maintained for every insurance policy, regardless of line of cover:

• Claims history — minimum last 3 to 5 years of claims data.
• Loss ratio records — incurred losses versus earned premium, by policy year.
• Current and expiring policy copies — including schedules, wordings, and endorsements.
• Details of any ongoing or outstanding claims — including reserves, status, and expected settlement dates.
• Updated risk information — changes in assets, exposure, operations, locations, or business activities that affect coverage.

Maintained by: BU Finance

14.3 Medical Insurance

In addition to the common requirements above, the following Medical Insurance documents must be maintained by BU HR:

• Trade License copy (current, valid).
• Current Table of Benefits (TOB) — the approved schedule of medical benefits and limits.
• Employee / member census data — including date of birth, gender, salary, grade, dependants, and visa status.
• Claims reports / DHA reports / loss ratio — as issued by the insurer and regulator.
• Historical claims data and utilization reports — covering the most recent 3 policy years at minimum.

Maintained by: BU HR

14.4 Property / Asset Insurance

The following documents must be maintained by BU Finance for all property and asset insurance lines:

• Updated sum insured values — reflecting current replacement or reinstatement costs.
• Asset registers / inventory lists — with descriptions, locations, and values.
• Claims records and loss history — for the last 3 to 5 years.
• Policy schedules and endorsements — current and expiring.

Maintained by: BU Finance

14.5 Workmen's Compensation / Liability Insurance

The following documents must be maintained by BU Finance:

• Updated employee list and wage declarations — current headcount by category with salary data.
• Claims history — including incident details, nature of injury, and settlement outcomes.
• Loss ratio records — for the last 3 to 5 years.

Maintained by: BU Finance

14.6 Fidelity Guarantee / Employee Covers

The following documents must be maintained by BU Finance:

• Updated employee list — covering all employees included under the fidelity guarantee or employee cover.
• Claims history — any past fidelity claims or incidents.
• Loss records — for the last 3 to 5 years.

Maintained by: BU Finance

14.7 Motor Insurance

The following documents must be maintained by BU Finance:

• Loss ratio for the past 3 years — including both paid and outstanding claims.
• Fleet schedule — chassis numbers, make/model, year, sum insured, usage type.
• Accident history — per vehicle, where available.

Maintained by: BU Finance

14.8 Specialty Lines (if applicable)

For any specialty insurance lines (e.g., Marine Cargo, Cyber, CAR/EAR, Professional Indemnity), BU Finance must maintain:

• Policy schedules and insured values — current and expiring.
• Risk exposure details — nature of risk, territorial limits, project values, and any material changes.
• Claims history — for the last 3 to 5 years.

Maintained by: BU Finance

14.9 Important Compliance Requirements

ALL BU FINANCE AND HR TEAMS MUST ENSURE THE FOLLOWING

The following compliance requirements apply to all document owners (BU Finance for all lines; BU HR for Medical Insurance):

• Records must be updated periodically — quarterly updates are recommended as a minimum; monthly for high-activity lines (Motor, Medical).
• Claims data must be accurate and reconciled with brokers and insurers — discrepancies must be resolved before the renewal submission deadline.
• Documents must be available immediately upon request from Group Procurement — GSC may request documents at any time, not only at renewal. Failure to provide documents within 5 working days of a GSC request will be reported to the BU Head and Group CFO.

Non-compliance with document maintenance requirements will be reflected in the BU's insurance KPI scorecard (Section 15) and may result in delayed sourcing, inadequate coverage, or higher premiums — for which the BU will be held accountable.

14.10 Document Ownership Summary

15. KPIs & Performance Measurement

16. Reference Forms

• F-INS-SRC-01 — BU Insurance Sourcing Request (with Underwriting Checklist)
• F-INS-SRC-02 — Insurance Quote Comparison & BU Selection Sheet
• F-INS-SRC-03 — Broker Engagement Instruction
• F-INS-SRC-04 — Claim Notification Form
• F-INS-SRC-05 — Policy Placement & Register Update Record

17. Non-Compliance & Consequences

Breach of this policy — including unauthorized market approaches, failure to submit sourcing requests within the 60-day window, failure to maintain mandatory documents per Section 14, or acceptance of inducements from brokers — will be reported to the Group Head of Procurement and Group CFO. Repeated or material breaches may result in disciplinary action per HR policy, removal of procurement delegation, and formal audit investigation.