April 20th, 2012

Dear Sirs,

We are pleased to confirm that ALBINA SAL reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this communication on Progress Report, we summarized ALBINA's main operations and policies which are aligned with the Global Compact strategy and reflects its Ten Principles, and the other main policies which ALBINA is in process of developing. We also commit to share this information with our stakeholders using our primary channels of communication; particularly through the Human Resources Manager, Quality Manager, Communication Manager and Administrative Officers.

Yours sincerely,

Maher Tabbara
Chair-General Manager

No written Human Rights policy available, ALBINA is in process of developing this section among many other policies such as:

- General Employee Conduct
- Business Ethics and Conduct
- Employee Relation and Communication
- Violence in the Workplace
- Accidents and Emergencies
- Internal Complaint Procedures
- Grievance Procedure
- Problem Resolution
- Suggestion
- Drug Free Workplace
- Smoking Policy

Therefore, all the above mentioned policies are being applied by ALBINA; Top Management is always conscious to make sure that human rights are appropriate within the organization.

Regular meetings and awareness seminars are conducted to stress on the "Code of Ethics", teamwork values, workplace security, etc. as well as to spread the corporate culture and consistently share the company's strategy, quality policy, mission and vision across all organization levels.
Management representatives are present on the ground anytime at all of ALBINA branches for efficient control.
Any breach of ALBINA rules will result in immediate warning and/or legal action to all concerned parties leading to termination of the employment.

Regular performance appraisals are conducted by Managers (initiated by the HR Manager) in order to evaluate the yearly performance, assess the staff maturity level and set clear objectives with plans and required trainings for the coming year.
Probationary performance appraisals are covered as well for the new employees after three months of their first working day.
There is a clear Performance Appraisal Procedure which clarifies the importance, frequency, process and documents to be used.
No external audits were considered to assess the Human Rights performance; we are aiming to apply it this year.

ALBINA has committed to implement the Balanced Scorecard principles where each member contributes by himself to achieve the company's strategy, mission and vision. Cascading, prioritization and budgeting of initiatives were successfully established this year in an attempt to diffuse them to the right personnel and implement them step by step. The execution of the Balanced Scorecard perspectives is based on employee empowerment, leadership, loyalty, integrity and responsibility values.
We believe in the Open Door Policy where all ALBINA personnel have the right to raise and discuss with Top Management any problem or concern they might necessary need to clarify.
Within the framework of Lebanese Law, ALBINA is an equal opportunity where employment is based on personal capabilities and qualifications without discrimination because of race, color, religion, sex, age, national origin, disability, or any other protected characteristics as established by law.

Each member of ALBINA has a detailed job description where all responsibilities, requirements and duties are specified and acknowledged by personnel.
Compensation and Benefits are clearly defined by Management and acknowledged by personnel.
Any breach of ALBINA rules will result in immediate warning and/or legal action to all concerned parties leading to termination of the employment.

ALBINA is certified ISO 9001:2008, thus external auditors are assessing on yearly basis the implementation and efficiency of company's documents based on ISO standards and requirements.
The Internal Audit and Quality Department aims to continuously control the company's operations, assess figures, solve discrepancies and suggest opportunities for improvement. Based on the latter department's tangible reports, some personnel were promoted and others were fired or removed from their positions: eg. based on the last internal audit report, discrepancies were detected at the level of stock control, transactions and invoicing. Thus as corrective actions, two positions were borne:
1- An employee was promoted to Operation Manager in order to specifically keep a closed eye on the inventories' operations.
2- A second employee was promoted to Chain Supply Manager in order to efficiently manage the operations from procurement till delivery.

Building on its continuously evolving Corporate Social Responsibility Program and to address its environmental and social responsibilities, ALBINA SAL has engaged Sustainable Environmental Solutions (SES) - ALBINA's sister company, to assess, quantify, reduce and offset its direct and indirect emissions of greenhouse gases (GHG) to achieve "Carbon Neutrality".
As a brief description of the concept, Carbon balancing is a part of an overall environmental or climate strategy where entities aim to measure, reduce and offset their carbon emissions through the purchase of carbon credits. These credits are usually purchased in the form of Verified Emission Reductions (VERs), where the proceeds go towards funding projects around the world that have issued emission reduction credits under a globally recognized standard, and to encourage eco-friendly technologies.
ALBINA has issued the GHG report assessment to better understand the environmental impact of their operations, and to develop proactive approaches to improve on industry best practice, by developing the "Paper Less" policy.

The Lebanese Center for Energy Conversation "LCEC" has chosen ALBINA as one of the companies' eligible to promote solar water heaters under the program of the Ministry of Water and Energy. The first 7500 stakeholders in the program will benefit of a subsidy of 200 USD at the purchase of a solar water heater with interest-free (0%) loan through a commercial bank in Lebanon.
ALBINA has won several projects under the CEDRO-UNDP projects which is funded by the Lebanon Recovery Fund by means of a grant from Spain, and aims at supporting the greening of Lebanon's recovery and reconstruction activities through the implementation and activation of end-use energy efficiency and renewable energy applications. The objective of these projects was to supply the installation of solar water heaters with forced circulation in public buildings, hospitals and Roumieh prison; in addition of their photovoltaic project for 20 sites (schools and municipalities).
ALBINA supported SES (sister company) with all the logistics from manpower to logistics to execute the first national awareness campaign related to Waste Management across Lebanon. Under the Direction of the Office of the Minister for Administrative Reforms - OMSAR and in joint venture with the Lebansese NGO Arcenciel, SES has designed and executed the national awareness campaign related to Waste Management "Faker Abel Ma Tkeb". During the Campaign, SES designed all the communication outputs such as: "Faker Abel Ma Tkeb" Slogan and Logo, Main Awareness Posters (for Municipal Solid Waste - MSW and Health Care Waste - HCW), Sticker (MSW), 2 Leaflet / Brochure (MSW and HCW), Awareness Booklet, 2010-2011 Awareness Calendar, Awareness 35 min dvd film, 10 min Awareness Video for Children, Awareness Song for Children and 4 Awareness TV Spots.

The environmental solutions are just recommended; ie there is no serious action taken by ALBINA Management in case of non-abidance by the Paper-Less policy and other environmental measures.
There was no Internal neither External Audit considered in this regard.
Next year, ALBINA plans to undertake audits and reviews to the environmental measures.

No written policy is available but all ALBINA parties are abiding by this law as described below, however a new policy is being prepared to be official publicized among all ALBINA Member of Staff.
- "Employees shall not receive payment or compensation of any kind, other than those mentioned in the agreement.
In particular, ALBINA strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others.
Any violation of this rule will result in immediate legal action to all concerned parties leading to termination of the employment".

No assessment of risk corruption is being applied at ALBINA SAL.
The goals for the upcoming year are to publish the policy for anti-corruption, kickbacks and commissions to all personnel with an acknowledgment of understanding and receipt.

Any violation of Anti-Corruption rule is being legally treated, and in accordance with the disciplinary procedure.
There was no previous Internal Audit in this regard. But with our new objective, this audit is inclusive in our Assessment Plan for the coming year.
No external audit was considered as well, we are aiming to apply it in the coming year.