We respect the dignity and rights of every person connected to our business, from our own people to the communities in which we operate. Our approach is guided by the United Nations Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, the core conventions of the International Labour Organization, and the OECD Guidelines for Multinational Enterprises.

What We Commit To
•We do not engage in, and we do not knowingly assist in or benefit from, any activity that violates human rights, and we do not stay silent where we become aware of one.
•We prohibit forced labour, bonded labour and human trafficking in our operations and our supply chain.
•We do not permit child labour, and we uphold the International Labour Organisation's minimum-age standards.
•We provide safe and secure working conditions for everyone working on our behalf.
•We respect freedom of association and the right to collective bargaining.
•We do not discriminate, and we treat every person fairly, regardless of background or belief.

How We Uphold It
We expect our business partners, vendors and suppliers to share these commitments. We embed them through training, and through open dialogue with our employees, shareholders and other stakeholders on human rights matters. Anyone who believes a human rights concern has arisen in connection with our business can raise it through our speak-up channels, free from retaliation, and we take every report seriously.

Doing the right thing depends on people feeling able to speak up. We encourage anyone with a genuine concern about our business to raise it, and we protect those who do. Our people are often the first to see when something is wrong, and we want them, and anyone who works with us, to tell us, so we can put it right. Concerns can be raised openly or in confidence, and reports can be made anonymously.

What to Raise
•Fraud, financial malpractice or corruption.
•Failure to comply with a legal or regulatory obligation.
•Risks to health, safety or the environment.
•Criminal activity or other improper or unethical conduct.
•Any attempt to conceal these.

Our Protection
We do not tolerate retaliation of any kind against anyone who raises a concern in good faith, or who supports an investigation, even if the concern turns out to be mistaken. Every report is reviewed, and the person raising it is told how it will be handled.

What Happens Next
Concerns can be raised with a supervisor or line manager, or, where appropriate, with senior leadership or Internal Audit. Once a concern is raised, we respond within 10 working days with an investigation plan, and we tell the person who raised it the outcome.

How to Speak Up
We also operate an independent whistleblowing service, managed externally to protect confidentiality. Concerns can be raised by telephone, email, web or app through that service, available to employees, contractors, suppliers and partners alike.

Safety means everyone gets home. It is the foundation on which we build everything else, and it is We are committed to protecting the health and safety of our people, our contractors and the communities around our operations, and to operating in a way that protects the environment. We comply with the health, safety and environmental regulations that govern our industry and we hold ourselves to recognized international good practice.

Our Commitments
•We put safety first in every task, every day, and we empower our people to stop work that is not safe.
•We identify, assess and manage the risks in our operations before they cause harm.
•We comply with applicable environmental laws and work to reduce the footprint of our operations.
•We prepare for emergencies and respond quickly and openly when incidents occur.
•We learn from what goes wrong and we share those lessons across the Group.
•We expect everyone who works for and with us to share this commitment and to hold us to it.

We are committed to delivering safe, reliable and efficient oil and gas exploration, production and project execution services in Nigeria. The quality of our projects and operations is critical to sustainable growth, operational excellence and long-term value for our stakeholders.

Our Commitments
•We comply with ISO 9001:2015 and the statutory, regulatory and contractual obligations that apply to our work.
•We work collaboratively with our vendors to ensure the equipment, materials and services we rely on meet defined quality standards.
•We promote a culture of quality, safety and accountability across every level of the organisation.
•We provide effective quality oversight across our exploration, production and operational activities.
•We monitor and evaluate our performance continuously, through audits, inspections, vendor evaluations and feedback.
•We improve our Quality Management System continually, through risk-based thinking, corrective action and management review.
•We develop and empower our people through training, competence development and adherence to best practice.

We are committed to engaging openly and consistently with the people and institutions our business affects. We are guided by honest, respectful and timely engagement with our stakeholders, from the communities that host our operations to our regulators, partners and the wider public. We listen first, communicate clearly, and back up what we say with what we do.

How We Engage
•We engage our host communities as partners, and we make space for their voices in decisions that affect them.
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We deal with our regulators precisely, transparently and in good faith.
•We communicate openly with our partners and the public, including when the news is difficult.
•We stand behind a single, consistent account of who we are and what we do.

A safe workplace depends on everyone being fit to do their job. In line with our commitment to Oil and Gas Industry Safety Standards, we maintain a zero-tolerance policy on substance abuse and enforce a workplace free from the influence of alcohol and drugs.

Our Commitments
•We prohibit the use of banned substances and alcohol at work, across our offices and facilities, for employees, contractors, third-party staff and anyone engaged to work on our behalf.
•We comply with the Mineral Oil Safety Regulations 1997, the Work Health and Safety Act 2012 and the Work Health and Safety Regulations 2022.
•We accommodate genuine medical need: anyone on prescribed medication for a legitimate ailment can declare the ailment to Human Resources and the specific medication to their supervising officer.
•We carry out random periodic testing, at management's discretion or a supervisor's request.
•We treat a verified breach as a serious matter, addressed through disciplinary action up to and including termination of appointment.

We treat people fairly. Everyone connected to our business deserves equal opportunity and freedom from discrimination and bias. We are committed to a workplace where decisions are based on ability and merit, never on personal characteristics such as race, religion, age, national origin, sex or disability. We promote diversity and equal rights across every part of our organisation.

Our Commitments
•We make employment decisions on merit, free from discrimination.
•We provide equal opportunity in recruitment, training, promotion and reward.
•We foster a workplace where everyone can contribute and progress on equal terms.
•We apply this standard consistently and hold ourselves accountable for it.
•Anyone who believes they have experienced or witnessed discrimination can raise it through our grievance and speak-up channels, free from retaliation.

What This Looks Like
This means we do not tolerate offensive remarks or stereotyping about a person's background, unfair treatment based on political or religious belief, or biased criteria in hiring and promotion decisions. Our leadership reviews progress regularly, and Human Resources reports on compliance to the Board.

Everyone has the right to work with dignity, in an environment free from harassment and bullying. We do not tolerate harassment, bullying, victimisation or any behaviour that undermines a person's dignity. We expect everyone who works for and with us to treat colleagues, partners and stakeholders with respect.

Our Commitments
•We maintain a workplace free from harassment, bullying and victimisation in any form.
•We treat physical attacks or threats in the workplace with zero tolerance, and report confirmed incidents to the relevant authorities in addition to internal disciplinary action.
•We provide clear, confidential routes to raise concerns, and we take every report seriously.
•We protect anyone who raises a concern or supports an investigation in good faith.
•We address behaviour that falls short of this standard promptly and fairly.

Raising a Concern
We encourage concerns to be raised informally in the first instance, in confidence, wherever that is possible and appropriate. Where a matter is serious, or informal steps do not resolve it, we address it through our formal grievance process, judging every case on whether a reasonable person would consider the behaviour to amount to harassment, not simply on intent.

We are committed to a cohesive, coordinated approach to gender equality, recognising that societal stereotypes can restrict women and men from fully exercising free choice and accessing equal opportunity. This policy applies to all employees across our organisation and locations. Our approach is guided by the principles of the UN Convention on the Elimination of All Forms of Discrimination against Women, and we work to advance gender equity both within the Group and in the communities where we operate.

Our Commitments
•We provide equal opportunity for women and men to participate in, contribute to and benefit from the Company, and we make recruitment, transfer, pay and promotion decisions without gender bias.
•We support career development for everyone, including formal mentoring and coaching, and, where appropriate, give candidates of both genders equal consideration for available positions.
•We maintain a gender-sensitive, family-friendly workplace, with benefits and policies that respond to the realities of pregnancy, childcare and family responsibilities.
•We build gender awareness through training, and hold ourselves accountable for measurable progress.
•We build gender awareness as a criterion in our partnership strategies, and support partners in developing and applying gender equity of their own.

We are committed to an inclusive workplace where people with disabilities have equal opportunity to demonstrate and realise their potential. We comply with the Discrimination Against Persons with Disabilities (Prohibition) Act 2018 and make reasonable adjustments so that disability is never an unnecessary barrier to employment or advancement.

Our Commitments
•We assess the needs of employees who disclose a disability individually and confidentially.
•We make reasonable adjustments to working arrangements and premises.
•We provide fair and equal treatment throughout the employment relationship.
•We work to ensure the experience of a colleague with a disability is comparable to that of their peers.

We are committed to equal rights, opportunities and treatment for women and men across our business and the communities we serve.

We do not condone child labour in any form, and we take action to prevent it in our operations and supply chain. Our approach follows the International Labour Organisation Minimum Age Convention (No. 138) and the Worst Forms of Child Labour Convention (No. 182), the Nigerian Labour Act, and the UN Convention on the Rights of the Child.

Our Commitments
•We do not employ children below the legal minimum age, and we verify age at recruitment.
•We require our contractors, vendors and partners to uphold the same standard.
•We act on any credible report of child labour connected to our business, up to ending the relationship.
•We support awareness and prevention in the communities where we operate.

Anyone can report a concern about child labour through our speak-up channels, in confidence and free from retaliation.

We respect the privacy of the people whose data we hold, whether they are colleagues, customers or partners, and we protect it. We handle personal data responsibly and in line with the Nigeria Data Protection Act 2023. Proper handling of personal and official information is central to how we operate and to the trust our stakeholders place in us.

Our Commitments
•We process personal data lawfully, fairly and transparently.
•We collect personal data for clear purposes and use it only for those purposes.
•We apply appropriate safeguards to keep personal data secure, across the full lifecycle of how we acquire, store, use and disclose it.
•We respect individuals' rights over their data and respond to their requests.
•We treat unauthorised disclosure of personal data as a serious matter, and it is unlawful

Independent assurance strengthens how we are governed. Our internal audit function provides it. Internal Audit gives our Board and management independent, objective assurance on the effectiveness of the Group's governance, risk management and internal controls. It operates with independence and reports in a way that protects that independence.

What the Function Provides
•Independent and objective assurance across the Group's operations.
•Evaluation of the effectiveness of governance, risk management and control.
•Recommendations to strengthen controls and address weaknesses.
•Reporting that preserves the function's independence and objectivity.

We manage risk deliberately, so that we can deliver on our commitments with confidence. Risk is a normal part of doing business, and we take a structured, proactive and consistent approach to identifying, assessing and managing it at every level of the Group.
Our Commitments
•We identify and assess the risks that could affect our people, our operations, our stakeholders and our performance, and we keep that picture current.
•We put controls and mitigating actions in place to bring risk to an acceptable level, choosing the response that fits each risk: accept it, reduce it, share or transfer it, or stop the activity that creates it.
•We assign clear ownership for every significant risk, so that action follows identification.
•We report on risk regularly, from business-unit level up to our Board's Audit and Risk Committee, so decisions are made with a current view of exposure.
•We review this policy at least annually, and update it as our business and environment change.