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OUR CODE OF CONDUCTS

Takoradi Gas Ltd hereby adopts the following Code of Conduct with respect to all commercial transactions, whether local or international:

LOCAL AND FOREIGN LAWS

Neither Takoradi Gas Ltd, nor anyone acting on behalf of Takoradi Gas Ltd, may, directly or indirectly, break or seek to evade the laws or regulations of any country in, through, or with which Takoradi Gas Ltd seeks to do business. That an illegal act is a “customary business practice” in any country is not sufficient justification for violation of this provision.

BRIBERY AND FACILITATING PAYMENTS

Neither Takoradi Gas Ltd, nor anyone acting on behalf of Takoradi Gas Ltd, may, directly or indirectly, offer or provide a bribe, and all demands for bribes must be expressly rejected. Bribery includes any offer, promise, or gift of any pecuniary or other advantage, whether directly or through intermediaries, to a public official, political party, political candidate or party official or any private sector employee, in order that the official or employee act or refrain from acting in relation to the performance of their duties, in order to obtain or retain business or other business advantage. Neither Takoradi Gas Ltd, nor anyone acting on behalf of Takoradi Gas Ltd, shall offer or make facilitating payments to government officials in order to encourage them to expedite a routine governmental task that they are otherwise required to undertake. Takoradi Gas Ltd, or anyone acting on behalf of Takoradi Gas Ltd, shall have discretion to deviate from this prohibition if he/she believes that there is an immediate threat to his/her or another’s health or safety. The circumstances of such payment must be reported as soon as possible after the event and the payment properly recorded. Takoradi Gas Ltd recognizes that extortion is wide spread and that participation by the business community increases demand for facilitating payments.

KICK-BACKS

Neither Takoradi Gas Ltd, nor anyone acting on behalf of Takoradi Gas Ltd, may offer or accept a “kick-back” of any portion of a contract payment to employees of other parties to a contract or use other vehicles such as subcontracts, purchase orders or consulting agreements to channel payments to government officials, political candidates, employees of other parties to a contract, their relatives or business associates. A “kickback” is a particular form of bribe which takes place when a person entrusted by an employer or public function has some responsibility for the granting of a benefit and does so in a way that secures a return (kickback) of some of the value of that transaction or benefit for that person without the knowledge or authorization of the employer or public body to which the person is accountable.

CONFLICTS OF INTEREST

Takoradi Gas Ltd, and anyone acting on behalf of Takoradi Gas Ltd, shall avoid any relationship or activity that might impair, or appear to impair, the ability to render objective and appropriate business decisions in the performance of our jobs. subcontractors in Environment, Health and Safety to raise awareness.

POLITICAL CONTRIBUTIONS

Neither Takoradi Gas Ltd, nor anyone acting on behalf of Takoradi Gas Ltd, may make a political contribution in order to obtain an unlawful business advantage. Takoradi Gas Ltd shall comply with all public disclosure requirements.

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