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CODE OF BUSINESS CONDUCT AND ETHICS

SHELL CORPORATION PETRON CORPORATION


In the shell corporation, the It is the responsibility of every
COE, Addressee is held director, officer, and employee
accountable for the full and the policy of the Petron
compliance with this Code with Group to encourage directors,
Accountability respect to any issues within his officers, and employees to ask
control. questions, seek guidance, and
report suspected violations of
this Code of Conduct and
Ethical Business Policy.
Shell companies recognize that The Petron Group shall prepare
regular dialogue and and maintain its accounts fairly,
engagement with our timely, accurately and reliably
stakeholders is essential. We in accordance with the
are committed to reporting of accounting and financial
our performance by providing reporting standards which
Reporting full relevant information to represent the generally accepted
Legitimately interested parties, guidelines, principles,
subject to any overriding standards, laws and regulations
considerations of Business of each jurisdiction or location
confidentiality. in which the Petron Group
conducts its business affairs.
You must be aware of the rules All directors, officers and
on conflicts of interest and employees must avoid any
ensure that your participation in conflict between their personal
politically motivated activity interest and the interest of the
does not involve you or Shell in Company. A director, officer or
a conflict of interest. employee shall not engage in
any business relationship or
Conflict of Interest activity which might
detrimentally conflict with the
interest of the Petron Group or
in any manner influence his/her
ability to exercise objectivity or
act in the best interests of the
Petron Group, its shareholders
and its other stakeholders.
Data privacy laws safeguard The Petron Group protects the
information about individuals – confidentiality of employee
their personal data. At Shell, we records and uses them in
respect the privacy rights of our accordance with applicable data
Data Privacy staff, customers, suppliers and privacy laws.
business partners. We are
committed to managing
personal data in a professional,
lawful and ethical way.
At Shell, we build relationships The Petron Group prohibits
based on trust, and we are bribery or other improper
determined to maintain and payments in any of its business
enhance our reputation. For this operations. The Petron Group
reason, we never accept or pay and its directors, officers, and
bribes, including facilitation employees shall neither solicit
payments. Even unsubstantiated or receive nor offer or make,
Anti-bribery and claims of bribery and directly or indirectly, any illegal
Corruption corruption may damage Shell’s or improper payments,
reputation. remuneration, gifts, favors,
commission, donations or other
comparable benefits which are
intended or perceived to obtain
business or uncompetitive
favors in the conduct of the
business of the Petron Group.
Money laundering occurs when
the proceeds of crime are
hidden in legitimate business
dealings, or when
legitimate funds are used to Not Applicable
Anti-Money Laundering support criminal activities,
including terrorism. All
companies are at risk of being
exploited in this way – and we
must be on our guard to help
protect our reputation and
ensure we comply with the law.
We all have our own interests The Petron Group does not
outside work and you have the make payments or contributions
right to engage in lawful to political parties,
political activity in your own organizations, or their
time. However, we also need to representatives or take part in
protect Shell’s interests and partisan politics. However,
reputation. It is therefore when dealing with the national
Political activity and important that individuals and local governments, the
Payments keep their personal political Petron Group has the right and
activities separate from their responsibility, in the pursuit of
role at Shell. its legitimate commercial
objectives, to make its positions
known on any matter
which affects the Petron Group
or its employees, customers,
shareholders and other
stakeholders.
Like any other global company, Directors, officers and
we must comply with all employees are responsible for
applicable national and the protection of all corporate
international trade compliance information and intellectual
regulations. Trade compliance property of the Petron Group,
includes regulations governing such as copyrights, patents,
the import, export and domestic trademarks and technology. As
trading of goods, technology, the Petron Group may license
software and services as well as intellectual property fromother
international sanctions and persons, all directors, officers
restrictive trade practices. and employees must also ensure
Trade Compliance Failure to comply with the that property of
applicable laws could lead to this nature is protected in
fines, delays, seizure of goods accordance with the agreements
or loss of Shell’s export or giving the Petron Group the
import privileges, as well as right to use such property.
damage to Shell’s reputation or
imprisonment for individuals. It
is crucial that you are aware of
the requirements and how they
apply to your role. By doing so,
you are helping the company to
continue doing business
internationally.
Shell aim to earn the confidence Petron assure the health and
of their customers and security of their employees,
shareholders, as well as customer, suppliers and etc.
contribute to the communities Petron Group is committed to
in which to operate as good preventing the wasteful use of
Neighbors, creating lasting natural resources and
Health, Safety and social benefits. compliance with minimized any hazardous
Environment the law and to achieve impact of the development,
continuous performance production use and disposal of
improvement,while promoting a any of its products and services
culture in which all Shell staff on the ecological environment.
and contractors share this
commitment
You must not offer, pay, make, Soliciting and accepting gifts,
seek or accept favors and/or services from any
a personal payment, gift or current or potential third
favor in return party provider are strictly
Accepting Gifts for favorable treatment or to prohibited. For purposes of this
gain a business Code, a “third party provider”
advantage. You must not allow refers to an individual, entity,
anybody else organization and/or its
to do so on your behalf. representatives that have
existing and/or intended
business dealings with the
Petron Group. This includes,
but shall not be limited, to
prospective or existing
contractors, providers,
suppliers, buyers, dealers,
customers, and all other
business partners who are or
may be similarly situated.
Conducting our activities in a The Petron Group provides safe
way that respects human rights work conditions and promotes
is a business imperative for the development and best use of
Shell and supports our licence employee talent (including
to operate. Human rights through the conduct of outside
requirements are embedded in and in-house trainings) and
our existing framework, equal
manuals and policies and opportunity employment.
Human Rights include:Social performance, The Petron Group protects the
security, human resources, confidentiality of employee
contracting and procurement. records and uses them in
accordance with applicable data
privacy laws. Every director,
officer and employee in the
Petron Group shall deal with
professionalism, honesty,
integrity and uphold high moral
and ethical standards. Such
conduct shall be fair and
transparent.

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