Policies, Code of Conduct

One of the most critical success factors for Campanile Consultants Ltd is the trust and confidence that people have in our ability to conduct business reliably, efficiently and in a manner that complies with legal and ethical requirements wherever we are present. The trust and confidence that our stakeholders have in us comes from a reputation that has taken Campanile Consultants Ltd management and employees many years to cultivate, and which we must continuously strive to develop and protect in our individual and collective behaviours and through our business conduct.

We all - managers and employees alike - have the duty to safeguard and protect Campanile Consultants Ltd’s reputation. It is with this objective in mind that the Campanile Consultants Ltd Code of Conduct has been devised as a set of guidelines and standards for managing and conducting our day-to-day business affairs. Its guiding principle is that no business transaction is worth endangering Campanile Consultants Ltd’s reputation for.

The Campanile Consultants LtdCode of Conduct is based on three core values and long-standing traditions that we all share wherever we are and whatever we do. These core values are:

· Honesty & Integrity,

· Compliance & Responsibility,

· Respect.

These core values are further expanded on and explained in the Campanile Consultants Ltd Code of Conduct. By adopting these core values and applying basic common sense, there is no doubt that we will succeed in protecting the Company’s reputation and ensuring that Campanile Consultants Ltd continues to be a Company that we can all be proud of. We should all remember, however, that the Campanile Consultants Ltd Code of Conduct is a supplement and not a replacement for existing Company affiliate policies.

Violating the Campanile Consultants Ltd Code of Conduct could have serious consequences for individual employees and affiliate companies alike. Transgressions could also lead to significant reputational damage for Campanile Consultants Ltdin its entirety.

We therefore ask you all, directors, managers and staff, to read the document and abide by its policies, principles and guidelines. In case you have any doubts or questions about how the Code of Conduct applies to your job, please raise them with your line managers, local senior management or the Campanile Consultants Ltd Compliance Team whose contact details are provided in this document.

Campanile Consultants Ltd’s shareholders and directors are committed to upholding the Company’s reputation and core values. I ask you all to join us in sharing and upholding our commitments.

Sincerely,

Campanile Consultants Ltd, MD

B. Introduction

This Campanile Consultants Ltd Code of Conduct (the "Code") is binding on Campanile Consultants Ltd and all entities directly or indirectly wholly-owned, majority-owned or controlled by Campanile Consultants Ltd and is applicable to every board member, officer, director and employee or other staff across the Company. Campanile Consultants Ltd staff is required to comply with the core values and the rules set out herein.

As an international company active in the trading and downstream oil industry, Campanile Consultants Ltd faces complex legal, commercial and regulatory situations every day. Its operations and business activities can give rise to numerous risks to Campanile Consultants Ltd’s staff and to Campanile Consultants Ltd itself. These risks may jeopardize the achievement of Campanile Consultants Ltd’s corporate objectives, workplaces and Campanile Consultants Ltd’s reputation. It is up to all of us to protect Campanile Consultants Ltd’s reputation because Campanile Consultants Ltd’s success is closely related to it. Campanile Consultants Ltd undertakes to promote awareness of this Code among its staff.

Campanile Consultants Ltd carefully checks for compliance with this Code by providing suitable information, prevention and control tools, ensuring transparency in all transactions and behaviours and by taking corrective measures if and as required.

Campanile Consultants Ltd remains deeply committed at all times to all applicable laws across the entire spectrum of its activities in all jurisdictions.

Where this Code should deviate from, or conflict with, mandatory requirements of national laws, regulations or codes, the mandatory requirements of the national laws, regulations or codes prevail.

C. Protect Campanile Consultants Ltd

In order to put this Code into practice:

- Read through the entire Code.

- Ask questions when you have doubts about a business decision, a proposed deal or payment or any other business.

- Feel free to make suggestions for improvements to this Code.

- If you have reason to believe that a violation of this Code may have occurred please contact your line manager or the Local Compliance Officer.

- Comply with the rules. For our continued business success, it is vital to comply with laws and act in accordance with our ethical standards.

- Protect Campanile Consultants Ltd from risks and maintain its reputation.

Your contact for all questions, requests and reports is your line manager or the Local Compliance Officer.

D. Campanile Consultants Ltd’s Core Values

Campanile Consultants Ltd is committed to the core values as described here below.

I. Honesty & Integrity

· We conduct ourselves and our business to a high ethical and legal standard: We act honestly and with a high degree of integrity.

· We comply with applicable national and international laws, regulations as well as this Code. We reject bribery, corruption, fraud, anti-competitive practices as well as all other criminal activity. Violations will not be tolerated and Campanile Consultants Ltd will take all necessary actions to address this.

· We take all necessary steps to prevent money laundering.

· We must avoid situations in which individual interests diverge with the interests of the Company or with those of our business partners.

II. Compliance & Responsibility

· We conduct our business in accordance with the laws and regulations that protect the environment and the natural resources.

· We are committed to protecting health and to respecting safety and security. We consider occupational health and safety at work to be just as important as providing safe quality products.

· We use our IT systems responsibly and securely. We respect and protect the data privacy of our employees, business partners and other persons.

· We comply with the applicable labour and immigration laws and never condone or support child labour or any form of forced labour.

· We reject every kind of illegal employment.

· We are sensitive to the principle of corporate social responsibility. We are mindful of economic, social and environmental issues.

III. Respect

· It is at the core of our business dealings to treat each other, our customers and our business partners in a respectful manner. We respect internationally recognized human rights.

· We give everyone an equal opportunity. We will not tolerate any unlawful discrimination at Campanile Consultants Ltd.

· We maintain a transparent and honest work environment at Campanile Consultants Ltd. An open and transparent communication with all our employees plays an important role in our business.

E. The Risks

It is essential to act with honesty, integrity, compliance, responsibility and respect because:

· Compliance is a commitment to legality. We are committed to complying with the laws of the country in which we operate. If we fail to comply with legal requirements, we may be subject to criminal investigations, heavy fines, penalties and damages claims;

· Compliance promotes our continuous business success. It builds up confidence in our employees and customers that we comply with laws and regulations; and

· Compliance protects us all from harm. We want to protect Campanile Consultants Ltd from risks and maintain its reputation. Transgressions can result in considerable reputational damages and revocation of governmental licences.

In the following sections, Campanile Consultants Ltd’s commitments and expectations in the most important areas are described as well as the principles and responsibilities around how to exercise and live Campanile Consultants Ltd’s core values in the day-to-day business in order to minimize risks to Campanile Consultants Ltd.

I. Doing Business

Campanile Consultants Ltdis committed to being a free, fair and ethical enterprise. Wherever Campanile Consultants Ltd operates, Campanile Consultants Ltdmust respect and conform to each country’s unique customs and business practices, laws and regulations. A failure to comply with these laws and regulations can severely damage Campanile Consultants Ltd’s business and expose it and its staff to criminal charges.

1. Trade Sanctions and International Trading Practices

Campanile Consultants Ltd complies with the laws of the countries in which it operates, particularly with respect to international export and import controls, customs regulations, economic sanctions and levies.

Campanile Consultants Ltd does not conduct any business involving individuals or entities listed under applicable (e.g. UN, EU or Swiss) sanctions rules. In any transaction we will comply with sanctions issued by the official authorities in the applicable country and will not conduct any business involving individuals or entities designated by the said official authorities.

Your Role:

• Follow the internal applicable guidelines and applicable policies with regard to Trade Sanctions.

• Ensure prescribed Know-Your-Counterparty-Checks are performed.

• Be aware that your transaction might require approval of one or several authorities.

• Do business with known and reputable partners.

• Ask your line manager if you are uncertain about the application of trade sanctions or tell them about potential conflicts.

2. Competition and Antitrust Law

Competition and antitrust law aims to ensure protection of free competition between independent companies. Therefore, these rules prohibit behaviour that reduces the intensity of competition, limits trade or restricts other companies’ commercial freedom to act. These rules apply to every level of business. They combat illegal practices like price-fixing, market-sharing or bid-rigging conspiracies, or behaviour aimed at achieving or maintaining a monopoly.

Infringements of competition and antitrust law may have severe consequences for all individualsconcerned and for Campanile Consultants Ltd’s global business. The possible consequences are high fines for Campanile Consultants Ltd(potentially up to 10% of Campanile Consultants Ltd’s annual global turnover), high fines (and in some countries imprisonment) for individuals involved in such infringements, hefty obligations to pay damages, the invalidity of agreements, and substantial reputational damage. Therefore, the various risks resulting from infringements of competition and antitrust law constitute a major risk for Campanile Consultants Ltd.

All Campanile Consultants Ltd staff, including employees, board members, officers, directors and others are obliged to observe competition and antitrust law.

Your Role:

• Follow the applicable internal guidelines and policies relating to Competition Law Compliance.

• Do not violate competition and antitrust law.

• Exercise particular care when dealing with competitors.

• Keep Campanile Consultants Ltd’s sensitive information in strict confidence.

• Contact your line manager or the Local Compliance Officer when unclear situations occur.

• Inform your line manager or the Local Compliance Officer about potentially anti-competitive practices.

3. Corruption and Bribery

Corruption is the abuse of public or private office for personal gain. It generally refers to obtaining, or attempting to obtain, a personal benefit or business advantage through improper or illegal means.

Corruption and bribery undermine legal business activities, distort competition and can ruin a company's reputation. Campanile Consultants Ltd does not tolerate any form of corruption or bribery by its staff or any party Campanile Consultants Ltd does business with, whether in the private or public sector.

Bribery is the act of:

· offering, promising, giving, paying or authorizing anyone to give or pay anything of value such as a material, a financial or other advantage to an official or a private party (active bribery) or

· accepting or authorizing anyone to accept a request or solicitation from an official or private party of anything of value such as a material, a financial or other advantage (passive bribery),

when the intention is

· to induce an official or private party to perform improperly any function of a public nature or any activity connected with a business or reward them from the improper performance of such a function or activity;

· to influence any official act (or omission) by an official or any decision in violation of any official duty;

· to obtain or secure an improper advantage in the conduct of business; or

· to violate the applicable laws.

Campanile Consultants Ltd staff and its representatives must comply with this Code and applicable rules and regulations in order to successfully prevent, detect and investigate any form of corruption and bribery.

Bribery of any official in any country is strictly against Campanile Consultants Ltd’s policy. The offer of anything of value, especially gifts and hospitality, to officials needs the permission of the President (CEO).

Furthermore, Campanile Consultants Ltd does not tolerate that gifts and hospitality influence business decisions or cause others to perceive an influence. For this reason, granting or accepting, directly or through anyone acting on our behalf, high-value gifts, monetary gifts and financial benefits is forbidden.

Nevertheless, Campanile Consultants Ltd recognizes that the occasional acceptance or offer of modest gifts and hospitality may be a legitimate contribution to good business relationships. For this reason, gifts and normal hospitality are only accepted if the frequency and the value of the gifts are reasonable and within the Company’s prescribed limits.

Non acceptable gifts and hospitality such as:

· Cash payments or equivalents (such as gift certificates or vouchers),

· Personal services,

· Loans,

· Gifts or hospitality of an inappropriate nature or in inappropriate venues,

· Gifts or invitations at periods when important business decisions, such as tendering processes, are taken,

· Gifts, hospitality or events with a value exceeding the value or the length prescribed in the internal anti-corruption and bribery applicable guidelines and policies.

If in doubt contact your line manager or the Local Compliance Officer.

Your Role:

• Follow the internal applicable guidelines and policies with regard to Anti-Bribery and Corruption.

• Do not threaten your or Campanile Consultants Ltd’s reputation.

• Make business partners aware of the internal applicable guidelines and policies with regard to giving and receiving of gifts and hospitality at the beginning of every new business relationship.

• Disclose any gift and invitation you offered, accepted or declined to your line manager in advance (where possible to do so, or as soon as possible afterwards),

• Inform your line manager whenever you suspect corruption and bribery in Campanile Consultants Ltdor any third party Campanile Consultants Ltddoes business with.

• Inform your line manager about potentially non-compliant practices. Please ask questions if you are unsure of how to deal properly with invitations or gifts etc.

4. Conflicts of Interest

Business decisions should be made free from a conflict of interest with objectiveness, impartiality and loyalty to Campanile Consultants Ltd. A conflict of interest may occur when an individual's personal relationships, social, financial or political activities or participation or interest in another venture influence or could be perceived to influence his or her business decisions. Work decisions must not be influenced by personal or private considerations.

More detailed information on this topic can be found in the internal applicable guidelines and policies.

Campanile Consultants Ltd undertakes the necessary steps in order to avoid undue conflicts of interests.

In consequence, Campanile Consultants Ltd employees should:

- Avoid situations that could lead to conflicts of interest.

- Act professionally and impartially in business dealings and relationships with contractors and suppliers.

- Withdraw from decision-making processes that may create, or be perceived to create, a conflict of interest.

- Report any conflict or potential conflict between your personal interest and the interest of Campanile Consultants Ltd to your line manager or the Local Compliance Officer.

5. Money Laundering

Money laundering is the process whereby the proceeds of crime are transformed into ostensibly legitimate money or other assets. The definition of money laundering also covers the use of legitimate funds in order to support criminal activities, including the financing of terrorism. Campanile Consultants Ltdcomplies with national and international laws, rules and regulations to successfully prevent, detect and investigate suspicious money laundering activities.

Campanile Consultants Ltdtakes the necessary precautions to prevent Campanile Consultants Ltdand its staff from being misused for money laundering activities. Before entering into business relationships or executing a contract with an external partner, Campanile Consultants Ltdemployees are required to carry out appropriate, risk-based due diligence checks to verify the counterparty’s identity, integrity and reputation.

Your Role:

· Follow the internal anti-money laundering applicable guidelines and applicable policies.

· Conduct appropriate, risk-based due diligence KYC- checks to verify the counterparty’s identity and integrity.

· Watch out for warning signs of money laundering and other unusual actions by any counterparty you are dealing with which make a transaction look suspicious.

· Seek advice from your line manager whenever you have any doubt about requested payments, or you detect any suspicious circumstances and incidents of money laundering.

II. Campanile Consultants Ltd’s People

Campanile Consultants Ltd’s people are its most important asset and therefore, Campanile Consultants Ltd’s priority is to protect them. Staff should be treated equally, fairly and with respect. Discrimination, harassment and bullying are unacceptable.

Campanile Consultants Ltdis committed to developing the abilities and skills of its staff with regard to both mental and physical health and dignity. Undue pressure is prohibited while appropriate working conditions promoting development of personality and professionalism are fostered.

1. Health, Safety, Security and Environment (HSSE)

Campanile Consultants Ltd must ensure safe technologies and a safe working environment with healthy working conditions.

Campanile Consultants Ltd identifies and evaluates health and other specific risks related to its workplace operations that may potentially adversely affect its staff, business partners or others.

Campanile Consultants Ltd works hard to minimize the impact on the environment by reducing waste, emissions and discharges and by producing safe, high-quality products and implements appropriate systems and processes to prevent environmentally harmful incidents.

Your role:

· Observe the governing laws and regulations on labour protection and environmental safety.

· Always comply with internal health and safety manuals, policies or procedures.

· Act in a careful manner so that no one will be put in danger.

· Behave responsibly to avoid situations that endanger safety. Do not perform activities for which you do not have necessary competence or training.

Contact your line manager whenever you notice anything that threatens safety in the workplace.

2. Equal Opportunities

Campanile Consultants Ltd represents diversity, tolerance and equal opportunity. Campanile Consultants Ltd believes in giving each employee equal opportunities for development without discrimination in all aspects of the employment relationship, including recruitment, hiring, work assignment, work-time allocation, working conditions, training, professional development, wage and salary, administration and selection for training.

Campanile Consultants Ltd does not tolerate unlawful discrimination. Campanile Consultants Ltd endeavours that each employee should have equal opportunities irrespective of gender, sexual orientation, marital status, race, colour, nationality or ethnic origin, disability, age or religion.

Your role:

· Deal respectfully with each other and with suppliers, customers, competitors and other third parties.

· Do not discriminate your colleagues according to race, colour, religion, age, gender, marital status, sexual orientation, disability, ethnic origin or nationality.

· Respect local practices and customs. Be aware of local legislation and cultural factors that may impact decisions.

3. Labour and Immigration Laws

Campanile Consultants Ltd complies with labour and immigration laws in the countries in which it operates. Campanile Consultants Ltd rejects child labour and all forms of exploitation of children. We do not tolerate any form of forced labour.

4. Controlled Substances, Drugs and Alcohol

The use, sale or distribution of illegal drugs and the misuse of drugs or other substances is prohibited at Campanile Consultants Ltd’s premises while conducting business for Campanile Consultants Ltd or while operating Campanile Consultants Ltd’s equipment.

Performing activities under the influence of alcohol, drugs or other substances which impair the Employee’s ability to operate safely and efficiently will not be tolerated.

Except where specifically authorised by your Company’s Management for official company events and outside of designated alcohol-free sites, alcohol consumption is not permitted during working hours.

Your Role:

· Report any use of drugs and alcohol and the misuse of controlled substances to your line manager.

5. Harassment and Bullying

Campanile Consultants Ltd prohibits any kind of actual or threatened violence, harassment, bullying and any action, conduct or behaviour which is humiliating, intimidating or hostile.

Your Role:

· Do not physically or verbally intimidate or humiliate others.

· Report (immediately) any kind of violence, harassment and bullying to your line manager.

III. Social Responsibility

Campanile Consultants Ltd is committed to actively contribute to promoting the quality of life, the socioeconomic development of the communities where it operates and to the development of their human resources and capabilities, while conducting its business activities according to standards that are compatible with fair commercial practices.

1. Social Sponsorship and Donations

Campanile Consultants Ltd iscommitted to transparent social sponsorship and transparent charitable donations, in order to avoid improper payments or bribes.

Campanile Consultants Ltd’s sponsorships and donations are limited to social and humanitarian projects such as education, culture and science. Campanile Consultants Ltddoes not make donations or contributions to politicians or political parties. The identity of the recipient, the reason and the use of the sponsorship, donation or contribution must be clear, justifiable and documented. Furthermore, organizations or individuals receiving donations or sponsorships must be in line with our core business values.

2. Corporate Social Responsibility

By helping to meet the world's growing energy needs in ways that are socially responsible, Campanile Consultants Ltd aims at achieving sustainable development and creating lasting social benefits.

IV. Campanile Consultants Ltd’s Assets & Property

Campanile Consultants Ltd’s physical, financial and intellectual assets are valuable and must be preserved, protected and managed properly. Waste, loss, damage, fraud, misappropriation, theft, infringement, abuse or misuse is unacceptable and punishable.

1. Assets and Property

Campanile Consultants Ltd’s assets include buildings, equipment, funds and intellectual property like know-how, trademarks, patents and trade secrets. All these assets are important for Campanile Consultants Ltd’s business purposes and goals. It is prohibited to use Campanile Consultants Ltd’s assets for personal benefit or for the benefit of anyone else.

Your Role:

Protect Campanile Consultants Ltd’s assets against waste, loss, damage, misuse, theft, misappropriation and infringement.

2. Records Management

Campanile Consultants Ltd’s books and records such as contracts, audit reports, financial information, travel and entertainment expense reports, policies and minutes of meetings are essential for managing its business activities as well as for legal, tax, regulatory and accounting purposes. The records must be prepared accurately and honestly. All books and records must be supported by sufficient documentation to provide a complete, accurate, valid and auditable record of each transaction. After the expiry of the retention period, records have to be disposed of appropriately.

All employees are required to cooperate fully with internal and external audits by providing truthful information and cooperating fully during the audit process.

Your Role:

Store your records properly and protect them from unauthorized access or interference.
Report violations to your line manager whenever you detect any improper handling of books and records.

3. Product Specifications

Campanile Consultants Ltd’s customers expect to receive products in compliance with the agreed specifications or standards and excellent services.

Your Role:

• Observe applicable procedures in checking specification of cargoes.

• Contact your line manager whenever you are in doubt about a certain procedure, issue or action.

• Report cargo quality-problems immediately to your line manager.

V. Data and Information Management

Information which Campanile Consultants Ltd provides about its business and finance must be true, accurate, consistent and not misleading.

1. Data Privacy and Protection

Campanile Consultants Ltd uses information and communication tools securely and responsibly. Campanile Consultants Ltd collects, processes and uses personal data only in accordance with applicable laws and applicable internal guidelines and applicable policies.

Campanile Consultants Ltd makes sure that the confidentiality of the data stored or transmitted is protected. Campanile Consultants Ltd respects the personal privacy of its staff, customers and contractual partners. Campanile Consultants Ltd protects and keeps confidential any sensitive personal information, e.g. sexual orientation, financial or employment situation or disabilities of its employees.

Your Role:

· Ensure data security: Treat documents with personal or sensitive data confidentially and protect them from misuse. Protect your passwords and user IDs. Make sure that your password is not made available to third parties.

· Be aware of privacy laws: Operate in compliance with the applicable laws. Collect, use, store or share personal data only insofar as it is absolutely necessary for the specific purpose and only if you are allowed to do so by law. Do not keep data longer than required, and destroy or delete data as soon as it is no longer needed.

· Report violations: Tell your line manager if you detect any improper handling of personal data or security gaps.

2. Personal use of IT

Where Campanile Consultants Ltd provides to its staff IT and communication facilities for business use, we expect that high ethical and business conduct standards are observed. Campanile Consultants Ltd staff must never endanger the security of Campanile Consultants Ltd’s information.

The personal use of IT could endanger the security of Campanile Consultants Ltd’s information. Campanile Consultants Ltd wishes a clear distinction between your personal information and Campanile Consultants Ltd business information. Websites aiming at personal use are increasingly being used to spread viruses, spyware and other malicious software designed to exploit vulnerabilities in personal computers and IT networks. Unauthorised installation of software may also endanger information security.

The usage of IT and communication facilities may be monitored by Campanile Consultants Ltdin accordance with local laws and regulations.

Your Role:

Use Campanile Consultants Ltd IT and communication facilities and equipment in a professional manner.
Any personal use of Campanile Consultants Ltd IT and electronic communications must be moderate, responsible and in accordance with the internal guidelines.
Do not upload, download or transmit objectionable material, install software or connect hardware to Campanile Consultants Ltd IT.

· Keep all Campanile Consultants Ltd IT access codes, e.g. passwords, secure and do not share them with others. This obligation remains even after the end of the employment relationship pursuant to applicable law.

· Contact your line manager whenever you are in doubt about a certain procedure, issue or action.

3. Information

Relations with the media are exclusively dealt with by the managers specifically appointed to do so; information to be supplied to media representatives as well as the undertaking to provide such information, have to be agreed upon beforehand with these managers.

Non-public information must not be disclosed. Non-public information is any information that Campanile Consultants Ltd has not disclosed or made generally available to the public, e.g. information related to employees, trade flows, contracts, strategic and business plans, major management changes, mergers and acquisitions, technical specifications, pricing, financial data. Even when disclosure of non-public information is required for business purposes appropriate steps to prevent misuse of the information have to be taken, such as execution of a confidentiality agreement.

It is forbidden to make, induce or encourage false statements to authorities. It is prohibited to disclose non-public information to anyone outside Campanile Consultants Ltd at all times, even after employment or Campanile Consultants Ltd’s engagement ends.

Your Role:

Be aware that all communication has to be in line with Campanile Consultants Ltd’s rules.

· Do not provide any information to the media without approval of the appropriate managers.

F. Disciplinary Actions and Acknowledgement.

I. Disciplinary Actions

Failure to comply with the principles of the Code, as well as any violation of the rules stipulated and referred to herein, may have severe consequences for the Employees.

Employees who are being investigated for a potential violation of this Code will have an opportunity to be heard prior to any final determination.

II. Signature and Acknowledgement

All new staff members must sign that they received this Code and abide its provisions. Existing staff members will be notified of the implementation of this Code via e mail. Failure to read this Code does not excuse a staff member from compliance with this Code.

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Code of Conduct

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