The Capital Markets Authority has issued a set of instructions for the management of companies subject to the supervision of the Capital Markets Authority, which stresses the need to provide accurate, comprehensive, detailed, adequate and recent data and information on the shareholders and other stakeholders in those companies, allowing them to assess the level of management of the company and take important investment decisions based on Complete and comprehensive information.

Kuwait Resorts Company K.S.C.P. (hereinafter referred to as the “Company”) has developed a policy in line with the instructions of the Capital Markets Authority and other relevant regulators with regard to disclosure and transparency.

Purpose

The company is committed to providing accurate and realistic disclosures of all material information related to its business, while seeking justice and equality in providing the right to access that information.

The purpose of this policy is to enhance the Company's ability to:

• Compliance with the rules, laws and instructions issued by the Capital Markets Authority and other relevant regulatory authorities.

• Determine the roles and responsibilities of the Compliance and Compliance Department and the role of the main parties in the disclosure process (including the Secretary of the Board of Directors, the Financial Manager, the Risk Management Department, the Internal Audit Department, and others).

• Assisting the main parties in the disclosure process in determining the nature and level of detail regarding the information to be disclosed, in addition to the controls that will be adopted during the disclosure process.

• Determine the methods of disclosure of financial and non-financial information and data related to the company's financial position, performance and ownership through appropriate means of disclosure, in a way that helps stakeholders to see the company's situation in an integrated manner.

• Consolidate the financial soundness of the company in particular and the financial sector in general.

• Providing data and information to all those interested in the company, whether they are current or potential investors.

• Achieving continuous follow-up of what is happening within the company.

• Facilitate the process of accountability of the Board of Directors and the Executive Management.

Confidentiality

Undisclosed information is strictly confidential information. In the event of accessing any undisclosed information, the employee must treat it with the utmost confidentiality.

The company bears the legal responsibility with regard to maintaining the confidentiality of customer information and not disclosing it to any person who is not legally authorized to view that information.

Disclosure of confidential information to external parties is permitted only in the event of signing a “confidentiality agreement” between the company and those parties, or in the case of parties subject to the obligations of the rules of professional conduct related to maintaining confidentiality, such as legal advisors, accountants, business advisors, suppliers, and any other parties that the company deems necessary to sign with.

To limit the possibility of disclosure or misuse of confidential information, whether intentionally or unintentionally, the following procedures must be followed at all times:

• Keeping documents and files that contain confidential information in a safe place, while limiting access to them to employees whose job duties require access to such information.

• Not discussing confidential information in open spaces, which may lead to the access of such information to parties that do not have the right to view such information.

• Do not exchange documents that contain confidential information through electronic means, except when making sure that the process of sending and receiving is secure.

• Avoid copying documents that contain confidential information unless necessary, with the disposal of all extra copies in meeting rooms and work sites in the event that they are no longer needed.

Policy document distribution

The Conformity and Compliance Department is responsible for owning the disclosure and transparency policy, maintaining it and supervising its issuance or modification. All inquiries and requests related to the directory should be directed to him.

Responsibility for applying the policy

The Conformity and Compliance Department is responsible for implementing and following up this policy on behalf of the Board of Directors. All contents of this policy are confidential and intended for the company's internal use only.
This policy is permanently kept in the form of a read-only copy, and may not be copied or made available to third parties without the written approval of the Board of Directors or those authorized by the Board in this regard.
Requests to circulate electronic copies of this policy shall be submitted to the employees concerned with the disclosure process and who are defined within the general framework of disclosure.

Definitions

For the purposes of this policy, the following terms have been defined as described below:
The main parties in the disclosure process
The main parties responsible for disclosure in the company, including members of the Board of Directors and executive management, all departments/functions/business units that have information that must be disclosed, related parties (subsidiaries and associates), employees, public opinion and others.

General Disclosures

Making information or data available to stakeholders, including the company's customers, regulators, shareholders and others. Some examples of public disclosures include quarterly reports to the capital markets, annual reports, oral or written statements that are disclosed to the public opinion, bulletins and publications that are published in newspapers or the Official Gazette.
Members of the executive body/ executive management/ senior executives
People who hold executive positions and do important and essential work.

The knowledgeable person

Any person who, by virtue of his position, has access to internal information or data of material impact on a listed company that was not available to the public.
The person is familiar with the listed company in the following cases:
Members of the Board of Directors and administrative staff of each of the listed company, its subsidiaries and the parent company who have access to internal information related to the listed company and its clients, whether directly or indirectly.
Any other person or entity with whom I have direct contactThis includes internal information related to the listed company and its clients, including - for example - the parent company, the auditor, banking agencies, advisory agencies, credit rating agencies, information technology companies, and entities entrusted with carrying out one of the activities carried out by the listed company.

The beneficiary person

Every person who has an interest representing 5% or more in the capital of a company listed on the stock exchange, whether directly or indirectly, as a group, or in alliance with others.
Indirect interest or alliance with others
It is considered as an indirect interest or in alliance with others, that interest that amounts to 5% or more of the capital of a listed company.

Dominator

Any person, whether natural or legal, who has control over a company listed on a stock exchange.

The lowdown

Information or data that is not disclosed to the public and which, if disclosed, would affect the price or trading of the security.

Material information

Any data and information the company has related to its activity, person, financial position, management or clients, and its knowledge is not available to the public and has an impact on the assets, liabilities, financial position or the general course of the company’s business or its clients and may lead to a change in the price or volume of trading or attraction or The reluctance of dealers in the company's securities or other securities in which the company or its clients have an interest or that could affect the ability of the company or its clients to fulfill their obligations.

Intrinsic effect

An impact resulting from a transaction, disposition, arrangement or contract that may affect the user of the company's financial statements.

Stock balance

It is the total ownership of the securities of the insider and his children and minor children under his guardianship in the listed company.

Disclosure process procedures

• The disclosure process is handled centrally by the Compliance and Compliance Department, which has the authority to disclose to the competent regulatory authorities.

• The company's board of directors determines the powers related to approving the disclosed data before disclosing them to the concerned authorities, within the authority guide approved by the company.

• The main parties in the disclosure process assess the materiality of the disclosed data based on the workshops and training programs that are provided to them. The Conformity and Compliance Department also discusses any questions or doubts that the main parties may have regarding the disclosure process.

• The Compliance Unit reviews all disclosed information to verify its completeness and correctness. The accuracy and completeness of the disclosed data is one of the main performance indicators of the main parties to the disclosure process and compliance and compliance management.

• The Conformity and Compliance Department makes sure that the main parties approve the data disclosed by the concerned authority in accordance with the approved authorities matrix in the company before it receives it.

• The Conformity and Compliance Department provides the Information Technology Unit with a copy of the issued disclosures in order to publish it on the company's website.

Responsibilities of the Board of Directors towards disclosure of material information

The Board of Directors must be fully and comprehensively acquainted with the operations and activities of the company and its various sectors, and be sufficiently aware of the company's developments, which makes it in a suitable position that allows it to evaluate and discuss events and developments that may affect the process of disclosure and disclosure of information.

Establishment of an Investor Affairs Organizing Unit: The Board of Directors shall establish an Investor Affairs Unit that is responsible for providing the necessary data, information and reports to potential investors of the company. One of the characteristics of this unit is that it is sufficiently independent to allow it to provide data and information in a fair, timely and accurate manner. The name of the person in charge of the Investor Affairs Unit and his contact numbers are announced on the company's website.

Transparency towards clients

customer information

The company is legally and ethically committed to protecting customer information in order to ensure that it is not misused in a way that harms the customer's interests or the company's reputation.

All employees are responsible for protecting customer information and not disclosing any information that they are not authorized to disclose in accordance with relevant regulatory requirements; It is important that the company's employees are fully aware of all policies related to the protection of information flow, distribution, transmission, preservation or disposal.

The company is keen to protect stakeholders, including the company's clients, and for this reason, the company has developed a "Stakeholders Protection Policy", which includes detailed instructions for stakeholder protection mechanisms.

General Disclosures

The company verifies the awareness and knowledge of the members of the Board of Directors, executive management employees and others with the disclosure policies and practices of the company; These policies and practices provide the guiding principles for these persons during the disclosure process. Disclosures are made in a timely manner as required by applicable local and international laws and relevant regulatory requirements.

The company's website

All public disclosures are posted on the company's website; As needed and with the approval of the Compliance and Compliance Department and the Executive Management.

The company's information technology department manages the disclosures that are published on the company's website and ensures their safety and security. The company constantly emphasizes the use of its website to communicate with stakeholders (shareholders, investors, customers, regulatory authorities, etc.) and to publish the information that must be published about the company.

Disclosures of the Capital Markets Authority

The Conformity and Compliance Department is responsible for supervising the process of disclosing information in accordance with the requirements of the Capital Markets Authority to ensure full compliance by the company with the laws and regulations of the Authority.
Accordingly, the Compliance and Compliance Department works to provide any clarifications or advice related to the disclosure requirements of the Capital Markets Authority. The Conformity and Compliance Department is the body responsible for communicating with and responding to the inquiries of the Capital Markets Authority and the relevant regulatory authorities.