Ethics and Code of Conduct for Clients

INTRODUCTION

Clients, although independent organisations, are actively involved in Prime Energy Ltd’s (“Prime Energy) value chain. Therefore, Prime Energy shall promote and foster knowledge of its Ethics and Code of Conduct with them.

This Code, marked by an ideal of cooperation, is aimed at mutual benefit, always respecting the role of
each party. Prime Energy considers that its clients must maintain minimum guidelines for conduct detailed below to perform activities properly.

Guidelines for conduct of Prime Energy & Clients

1. CURRENT LEGISLATION

A Prime Energy client must comply with applicable legislation in the countries where it operates, avoiding any conduct that, without violating any law, may harm Prime Energy’s reputation and cause adverse consequences for the company or its environment. When the client is required to address conflicting demands, they must seek alternatives that allow them to respect internationally recognized human rights.

2. HUMAN RIGHTS

The Prime Energy client must respect internationally recognized human rights, including those in the “International Bill of Human Rights” and Fundamental Conventions of the International Labour Organization, according to the declaration on fundamental principles and rights at work. The client’s responsibility to respect human rights requires them to prevent their activities from causing or contributing to causing negative consequences on human rights, to address these consequences when they occur and to try to prevent or mitigate negative consequences on human rights directly related to operations, products or services provided by their partners.

3. ETHICAL BEHAVIOR AND MEASURES AGAINST BRIBERY AND CORRUPTION

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

The purpose of this policy is to publicly communicate to third parties our position on bribery and corruption.

Third party means any individual or organisation that comes into contact with us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisers, representatives and officials, politicians and political parties.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.

We will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.

4. HEALTH, SAFETY AND ENVIRONMENT

Prime Energy and its clients shall perform their activities in order to minimize negative environmental impact according to the legislation in force in the country of operation, and reaching a high level of safety in its facilities, products and services, with particular attention to protecting employees, contractors, customers and the local environment. Particularly, when these are carried out at Prime Energy’s facilities, the client shall understand and enforce among its employees and subcontractors, all Company health, safety and environment norms applicable to them.

5. CONFIDENTIALITY

5.1 The client must respect the principles of confidentiality of the information they have access to as a result of their relation with Prime Energy in carrying out their professional activity.

5.2 Responsibility of Clients:

  • Respect this code while maintaining their status as a Prime Energy client.
  • Participate in verification activities of this code that may be established by Prime Energy.
  • Implement the corrective actions, if necessary, resulting from any verification activity carried out by Prime Energy in the organisation.
  • Notify Prime Energy of any information considered relevant regarding the requirements set in this Code.

6. VIOLATIONS OR NON-COMPLIANCE OF THIS CODE

Violations by the client of the content of this Code may have different consequences in their contractual relation with Prime Energy. According to the severity of the violation, these can range from a simple warning to disqualification as a Prime Energy client; without prejudice to other applicable legal or administrative actions.

Download the Prime Energy Ethics and Code of Conduct here

Prime Energy Ltd