The code of business conduct sets out the basic rules and standards that are necessary for OLA Energy to conduct its business in an ethical and compliant manner and in accordance with its values.

These rules must be followed by OLA Energy Employees, senior managers and directors, at all times.

What is the code of business conduct?

A fundamental set of guidelines implemented by the Company setting out the standards of conduct required of us in the day-to-day performance of our business in conjunction with our Core values:

• Safety & Health
• Service Excellence
• Commitment to quality
• Social Responsibility
• Pursuing Excellence

 

Who does the code apply to?

It is applicable to all employees, senior managers and directors at all times

Compliance with local laws and regulations

At OLA Energy we comply with all laws and regulations, local, national or international. We are responsible for understanding the applicable laws and regulations and consult with our Legal departments to ensure compliance.

 

What are my responsibilities as an employee of OLA Energy?

• Read, understand and follow the Code of Business Conduct
• Observe the highest standards of integrity;
• Know where to go for support, information or advice concerning a conduct issue

Who do I refer to for advice or if I witness any breach of Code of Business Conduct?

If you have any questions or doubts about any behaviour not conforming to the Code of Business Conduct, please ask your Human Resources or Legal Department. You can also submit any questions,  via Email to BusinessConduct@olaenergy.com

 

Consequences of failing to comply

Failure to comply with any requirements in the Code of Business Conduct will lead to disciplinary action up to and including dismissal / termination, in accordance with affiliates procedures and countries laws and regulations.

Application and Stakeholders

Unless otherwise stated below all policies are applicable globally (with modifications only as required by country law) and have the following stakeholder roles:

• Responsibilities (Ownership): Human Resources
• Accountability: Human Resources
• Consultation: Legal
• Information: All employees

• Ethics

Overview:

• Description: This policy is describing expected business conduct and behaviour that fully complies with the law and demonstrates the highest course of integrity.

Policy Statement:

OLA and all its employees must strictly observe all laws applicable to its business.

In cases where the law is permissive, the Company chooses the course of highest integrity. Though we operate in many countries with differing cultures, we must hold ourselves to the highest standards of ethics and honesty in all our operations. The Group’s reputation for honest, ethical and scrupulous dealing is an asset that employees must act to protect.

The Company cares about how results are obtained, not just that they are obtained. Employees must keep management informed on their activities, record all transactions accurately, and be honest and forthcoming with our internal and external auditors. Employees must also report suspected violations of law or the corporate policies to management.

The Company expects compliance with its standard of integrity throughout the organization and will not tolerate employees who achieve results by violating laws or dealing unethically. The Company supports any employee who forgoes a business opportunity that would sacrifice ethical standards.

Equally important, the Company expects candour from managers at all levels and compliance with corporate policies, accounting rules, and controls. OLA management is expected to lead by example. When managers conceal or misrepresent information, subordinates within their organizations take it as a signal that company policies and rules can be ignored when inconvenient. This can result in corruption and demoralization of an organization. The Company’s system of management will not work without honesty, including honest bookkeeping, honest budget proposals, and honest economic evaluation of projects.

It is the Company policy that all transactions shall be accurately reflected in its books and records. This, of course, means that falsification of its books and records or the creation or maintenance of any off-the-record bank accounts is strictly prohibited.

• Financial Crimes: Bribery, Corruption, Fraud, Theft and Money Laundering

Overview:

• Description: This policy is in respect of our company’s commitment to prevent bribery,corruption, fraud, theft and money laundering within our business.

Bribery, corruption, fraud, theft and money laundering poses serious risks to our business and our reputation. This policy sets out the steps all employees must take to prevent bribery and corruption in our business and to comply with all relevant legislation.

Policy Statement:

What are bribery, corruption, fraud, theft and money laundering?

• Corruption is the misuse of office or power for private gain.
• Bribery is a form of corruption. It includes offering, promising, giving, accepting or seeking a bribe.
  

  A bribe is a financial or other advantage, promised, requested or given to induce a person to perform a function or activity improperly, or to reward them for doing so.
  A bribe may include cash or cash equivalent, gifts, meals, entertainment, services, loans, preferential treatment, discounts or anything else of value. The timing of the bribe is irrelevant, and payments made after the relevant event are considered bribes. Bribes given or received unknowingly are also prohibited.
  It is not necessary for the individual to receive any benefit as a result of the bribe.
  All forms of bribery and corruption are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with the HR or legal departments.
  This means that you must not:

  • Give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received, or to reward any business received;
  • Accept any offer from a third party that you know, or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
  • Give or offer any payment to a government official in any country to facilitate or speed up a routine or necessary procedure.
  • Threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

   

• Money laundering means the process of turning the proceeds of crime into property or money that can be accessed legitimately without arousing suspicion.
• Fraud is a form of dishonesty, involving either false representation, failing to disclose information or abuse of position, undertaken in order to make a gain or cause loss to another.
  Among the most common types of fraud are:
  • income-related fraud;
  • expenditure fraud;
  • property and investment fraud;
  • procurement fraud;
  • fraudulent fundraising in the organisation’s name;
  • fraudulent invoicing and grant applications;
  • identity fraud/theft;
  • forgery,
  • tax evasion
  • embezzlement
  • banking fraud; and
  • e-crime.
• Theft is dishonestly appropriating property belonging to another with the intention of permanently depriving the other of it. Acts such as false accounting are also forms of theft.

Who can be involved in bribery and other financial crimes and in what circumstances?

Bribery, corruption and other financial crimes may be committed by our:

• staff (employees, directors etc) or anyone authorised to do things on our behalf;
• representatives and other third parties who act on our behalf;
• suppliers;
• customers (because they might try to induce one of our people to give them more favourable terms).
• They can occur in both the public and private sectors.

The legal position on bribery and financial crimes:

Bribery, corruption and financial crimes are criminal offences in most countries where we do business. it is illegal:

• to pay or offer to pay a bribe;
• to receive or agree to receive a bribe;
• to bribe a public official.

A breach of bribery laws can result in fines for both the company and the individual involved and, in some jurisdictions, could also result in imprisonment.

Our position on Financial crimes

Our position is simple: we conduct our business to the highest legal and ethical standards. We will not be party to corruption or bribery in any form. Such acts would damage our reputation and expose us, and our staff and representatives, to the risk of fines and imprisonment. We take a zero-tolerance approach to bribery, corruption and financial crimes by our people and our third-party representatives.

Bribery, corruption and financial crimes may be more widespread in some countries and business sectors than others and appropriate due diligence and risk assessment are carried out depending on the risk we face.

What are indicators of financial crimes?

Common indicators of financial crimes include those listed below. There may well be others:

• payments are for abnormal amounts or purposes (e.g. commission), or made in an unusual way, e.g. what would normally be a single payment is made in stages, through a bank account never previously used, or in a currency or via a country which has no connection with the transaction;
• process is bypassed for approval or sign-off of terms or other commercial matters, or we are prevented from or hindered in monitoring commercial processes;
• individuals are secretive about certain matters or relationships and/or insist on dealing with them personally; they may make trips at short notice without explanation, or have a more lavish lifestyle than expected;
• decisions are taken for which there is no clear rationale;
• records are incomplete or missing.

Areas of specific risk

We have identified certain aspects of our business where we are presented with a higher risk than others. These include:

• Gifts and hospitality—covered in our “gifts and entertainment policy”. Please familiarise yourself with this;
• Facilitation payments. Facilitation payments are usually small amounts paid to officials to provide goods or services to which we are already entitled e.g. speeding up the grant of a licence or permit. Though these payments may be common in some countries where we operate, we do not offer or pay them. If faced with a request of demand for a facilitation payment, contact Corporate Legal immediately
• Commissions—all commissions constitute the giving of a financial advantage, although they will not necessarily be bribes.

Exceptional circumstances

In some circumstances a payment is justifiable.

If one of our staff is faced with a threat to their personal safety or that of another person if a payment is not made, they should pay it without fear of recrimination. In such cases the Legal Coordinator must be contacted as soon as possible, and the payment and the circumstances in which it was made must be fully documented and reported.

Such cases will be rare. All our people visiting regions where these cases are more common should familiarise themselves, prior to travel, with current guidance relating to those countries.

Training

All staff will receive training on this and related policies. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in applicable legislation or our policy and procedure.

Who is responsible for this policy?

The General Manager has overall responsibility for this policy. He will monitor it regularly to ensure the policy is adhered to by all staff.

Risk within the business will vary by area/location. The manager of each department and the General Manager shall be responsible for assessing the level of risk faced by their department and, with the approval of Corporate Legal Department putting in place any necessary additional measures.

Your responsibilities

Everyone in the organisation is responsible for:

• reading and being aware of the contents of this policy;
• complying with this policy;
• reporting cases where you know, or have a reasonable suspicion, that bribery or corruption has occurred or is likely to occur.

We will not penalise anyone who loses business through not paying a bribe.

What should you do if you think something is wrong?

Each of us has a responsibility to speak out if we discover anything corrupt or otherwise improper occurring in relation to our business. Notify the Corporate Legal Coordinator immediately, if you discover or suspect bribery or corruption by an OLA employee, a 3^rd party representative, a supplier or a customer. You can do this anonymously by submitting an anonymous report form detailing the discovery or suspicion.

You may be required to explain any delays.

Consequences of failing to comply

Failure to comply puts both you and the business at risk and may constitute a criminal offense which can carry severe penalties.

OLA takes compliance with this policy very seriously. Failure to comply with any requirement will lead to disciplinary action up to and including dismissal/termination.

If you have any questions or concerns about anything in this policy, do not hesitate to contact the Legal or HR Departments.

• Conflict of Interest

Overview:

• Description: This policy is describing actions to avoid personal or business situations that could result in a conflict between the company’s interests and the employee’s interests.

Policy Statement:

It is expected that directors, officers, and employees should avoid any conflict between their own interests and the interests of the Company in dealing with suppliers, customers and other third parties, and in the conduct of their personal affairs, including transactions in securities of the Company, any affiliate, or any non-affiliated organization.

It is also a conflict of interest for an employee, during or subsequent to employment and without proper authority, to give or make available to anyone, or use for his/her own benefit, information of a confidential nature derived from his/her employment.

While it is not practicable to enumerate all situations, which violate the Conflicts of Interest policy, the examples below indicate some which should be avoided. Additionally, there will be situations which, while perhaps justifiable, create the appearance of a conflict of interest and they should be carefully weighed.

It is considered to be a conflict with the Company’s interest:

For the purposes of this policy OLA defines an employee’s “relatives” as any member of their immediate family, meaning a spouse, parent, sibling or child/dependent, as well as any spouse, parent, sibling or child/dependent of a member of the employees immediate family.

1. For an employee or employee’s relative to have an interest in any organization which has, or is seeking to have, business dealings with the Company or any affiliate where there is an opportunity for preferential treatment to be given or received, except
   1. with the knowledge and consent of senior management
   2. where such an interest comprises securities in widely held Companies which are quoted and sold on the open market, or
   3. in private Companies where the interest is not material
2. For an employee or an employee’s relative to compete with the Company or its affiliates through outside business activities, except with the knowledge and consent of senior management
3. For an employee or an employee’s relative to serve as an officer or director of any other company, or in any management capacity for, or as a consultant to, any individual, firm, or other company doing, or seeking to do, business with the Company or any affiliate, except with the knowledge and consent of senior management.
4. For an employee or an employee’s relative to be employed by a competitor, or be self-employed, in a common field of technical or professional endeavour where the employee and the employee’s spouse or dependent family member normally have access to and use highly sensitive and proprietary information of competitive value, except with the knowledge and consent of senior management
5. For an employee to approve or administratively control contracts or other business arrangements between the Company and a relative of the employee or with a company, firm, or individual employing a relative of the employee in activities under the employee’s administrative control. Review, approval, or administrative control of such contracts and other business arrangements should be referred to senior management. Full information concerning these relationships should be furnished to the employee’s supervisor who shall advise the appropriate senior manager, Legal Department, and Auditor
6. For an employee or an employee’s relative to acquire and hold oil, gas, or mineral leases, royalty interests, or oil payments, except with the knowledge and consent of senior management. Employees and their relatives are not, however, precluded from owning, leasing, and selling property interests acquired by inheritance, or from investing in real estate where the mineral interests, if any, are only incidental to the investment decision and the real estate investment would not be used in competition with the Company’s activities;
7. For an employee, without proper authority, to give or release to anyone not employed by the Company or an affiliate any data or information of a confidential nature concerning the Company or any affiliate, such as that relating to decisions, plans, earnings, financial or business forecasts, discoveries or competitive bids, or otherwise use such information which is not generally known to the public for personal advantage and not in the best interest of the Company;
8. For an employee or an employee’s relative to accept commissions, a share in profits, gifts in cash, gift certificates, travel or other payments, loans or advances (other than from established banking or financial institutions on normal commercial terms), materials, services, repairs or improvements at no cost or at unreasonably low prices, excessive or extravagant entertainment, or gifts of merchandise of more than nominal value from any organization, firm, or individual doing, or seeking to do, business with the Company or any affiliate, or, for personal advantage and not in the best interest of the Company, to provide any of the foregoing to any such organization, firm, or individual. Employees and their relatives are not, however, precluded from accepting gifts that are appropriate for official events and ceremonial occasions sanctioned by the Company
9. For an employee to use Company personnel, facilities, equipment, or supplies for personal benefit contrary to the Company’s policies and procedures
10. For an employee, without senior management approval, to engage in discussions or negotiations concerning employment or other contractual relationship for themselves or a relative with any organization with which they have direct business contact that provides goods or services to the Company or any affiliate
11. For an employee or an employee’s relative to buy, sell, or lease any kind of property, facilities, or equipment from or to the Company or any affiliate where there is an opportunity for preferential treatment to be given or received, except with the knowledge and consent of senior management;
12. For an employee or an employee’s relative knowingly to buy, sell, or lease any kind of property, facilities, or equipment from or to any company, firm, or individual that is, or is seeking to become, a contractor, supplier, or customer of the Company or an affiliate where there is an opportunity for preferential treatment to be given or received, except with the knowledge and consent of senior management.

It is recognized that an employee may have questions concerning whether certain activities constitute departures from these guidelines, including business dealings with third parties who are not dependent or immediate family members but where the appearance of a conflict situation could exist due to the nature of the relationship. Employees must discuss such situations with their management to clarify the appropriateness of the business relationship. Such questions should be addressed to the employee’s supervisor who shall consult, when necessary for resolution of the matter, with senior management.

When further interpretation of the policy is required to answer an employee’s inquiry, the senior manager should consult with the appropriate Legal Department representative and the Auditor.

Conflicts of interest can be avoided by following some simple preventive rules.

For example, employees should not acquire an interest in the business of a competitor, supplier or customer, nor should they engage in any occupation outside the company, without their line management’s prior approval.

When in doubt, employee must seek guidance from HR, Legal or immediate supervisor.

The Human Resources Department has the ownership of the Conflicts of Interest policy. All employees, including supervisors and managers, are subject to disciplinary action up to and including termination for engaging in any activity which constitutes a conflict of interest.

• Gifts and Entertainment

Overview:

• Description: This policy is describing global principles on the practice of giving or receiving

gifts. Affiliates are expected to adopt similar policy that conforms to the policy principles, legal

requirements, and customary practices in their operating areas.

Policy Statement:

The Company’s business interests are best served when commercial decisions are based on commercial criteria and not influenced by such factors as donation, gifts or entertainment. This principle, which governs the day-to-day conduct of business, have been embodied in the policy provisions which follow.

A gift includes anything of value, transferred to another, for which no specific service or compensation is expected or received. The company does not encourage the giving or receiving gifts, even those of nominal value (40 Euros or less). However, it recognizes that gifts of nominal value may be appropriate from time to time. Good judgment must be exercised in all cases.

Employees should neither give nor receive gifts in the form of cash, commissions, loans, shares in profit, securities or their equivalent. Employees should neither give nor receive materials, services, repairs, or improvements at prices lower than would otherwise be available in the marketplace.

On occasion, it is permissible for employees to give or receive entertainment of nominal value of 40 Euros or less, assuming a definite business purpose is being served. However, it is the employee’s responsibility to avoid even the appearance of impropriety. If there is any doubt about whether or not a particular activity complies with this policy, employees should contact his or her supervisor for guidance.

Employees may pay, on behalf of the Company, reasonable and appropriate expenses incurred in connection with discussions of specific business matters with other persons, and may attend meetings at which such expenses are paid for by persons with whom the Company does business or is seeking to do business. Such expenses may include, for example, the cost of meeting rooms and meals.

Employees giving gifts to public employees or officials should be especially sensitive to the appearances of such gifts and to the legal propriety of such gifts and should consult with the Legal Department. Gifts that would be proper if given to private persons may be improper if the recipients are government or quasi-government employees or officials, foreign officials, or officials of public international organizations. Such gifts must comply with all relevant policies, including the Political Activities policy.

If the gift or business entertainment exceeds the limits of this policy, the employee or officer should report the matter to his or her supervisor, who, in unclear cases, should review the matter with the Auditor.

If you witness any breach of Code of Business Conduct related to Gift and entertainment policy or If you have any questions or doubts about any behaviour not conforming to the Code of Business Conduct, please ask your Human Resources or Legal.

• Political Activities

Overview:

• Description: This policy is describing Guiding principles on contribution or involvement of

Employees into political activities.

Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

Policy Statement:

The Company does not make contributions to political candidates or political parties except as permitted by applicable laws and authorized by the Board of Directors.

It is the Company’s policy to communicate information and views on issues of public concern that have an important impact on the Company.

Employees engaging in political activity will do so as private citizens and not as representatives of the Company. An employee’s personal lawful political contributions, or decision not to make contributions, will not influence the employee’s compensation, job security, or opportunities for advancement.

At OLA Energy we comply with all laws and regulations, local, national or international. We are responsible for understanding the applicable laws and regulations in all our affiliates and consult with our Legal departments to ensure compliance.

• Protection of Environment

Overview:

• Description: This policy is describing Guiding principles on Environment Protection.
  Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.
• Application: All employees (modifications only as required by country law)
• Stakeholders:
  • Responsibilities (Process owner): Safety, Health and Environment
  • Accountability: All employees
  • Consultation: Legal
  • Information: All employees

Policy Statement:

It is Company’s policy to conduct its business in a manner that is compatible with the balanced environmental and economic needs of the communities in which it operates. The Company is committed to continuous efforts to improve environmental performance throughout its operations.

Accordingly, the Company’s policy is to:

• Comply with all applicable environmental laws and regulations and apply responsible standards where laws and regulations do not exist;
• Encourage concern and respect for the environment, emphasize every employee’s responsibility in environmental performance, and ensure appropriate operating practices and training;
• Work with government and industry Companies to foster timely development of effective environmental laws and regulations based on sound science and considering risks, costs, and benefits, including effects on energy and product supply;
• Manage its business with the goal of preventing incidents and of controlling emissions and wastes to below harmful levels; design, operate, and maintain facilities to this end;
• Respond quickly and effectively to incidents resulting from its operations, cooperating with industry organizations and authorized government agencies;
• Communicate with the public on environmental matters and share its experience with others to facilitate improvements in industry performance;
• Undertake appropriate reviews and evaluations of its operations to measure progress and to ensure compliance with this policy.

Procedures:

SHEMS is the Management system detailing Safety, Health and Environment Protection, it includes a full set of procedures and guidelines managing all the SHE aspects.

This Management System is available within your SHE Department at affiliate level, the procedures address areas of protection and prevention of hazards and harm to the environment including Spill and emission prevention and management.

• Equal Employment Opportunity

Overview:

• Description: This policy is describing the Group’s actions to provide equal employment
  opportunity in conformance with all applicable laws and regulations to individuals who are qualified to perform job requirements.

• Stakeholders:
  • Responsibilities (Ownership): Human Resources
  • Accountability: General Managers/All Departments Managers
  • Consultation: Legal
  • Information: All employees

Policy Statement:

The intent of this policy is to provide equal employment opportunity in conformance with all applicable laws and regulations to individuals who are qualified to perform job requirements. The Company administers its personnel policies, programs, and practices in a non-discriminatory manner in all aspects of the employment relationship, including recruitment, hiring, work assignment, promotion, transfer, termination, wage and salary administration, and selection for training.

Managers and supervisors are responsible for implementing and administering this policy, for maintaining a work environment free from unlawful discrimination, and for promptly identifying and resolving any problem area regarding equal employment opportunity.

In addition to providing equal employment opportunity, it is also the objective of the company to undertake special efforts to:

• Develop and support educational programs, recruiting sources, and practices that facilitate hiring of minorities and women;
• Develop and offer work arrangements that help to meet the needs of the diverse work force in balancing work and family obligations;
• Establish company training and developmental efforts, policies, and programs that support diversity in the work force and enhance the representation of minorities and women throughout the company;
• Assure a work environment free from sexual, racial, or other harassment;
• Make reasonable accommodations that enable qualified disabled individuals to perform the essential functions of their jobs;
• Emphasize management responsibility in these matters at every level of the organization.

Examples of discriminatory situation:

Any hiring, evaluation, promotion, training, development, discipline, compensation or termination decisions are informed by or made on the basis of race, colour, religion, age, gender, sexual orientation, marital status, disability, ethnic origin or nationality are violations of the anti-discrimination policy.

These decisions should be based solely on qualifications, merit, performance and business considerations. personal feelings, prejudices or preferences must not influence these decisions.

Individuals who believe they have observed or been subjected to prohibited discrimination should immediately report the incident to their supervisor, higher management, or their designated Human Resources contact. Complaints will be investigated and handled confidentially. Individuals will not be subjected to harassment, intimidation, discrimination or retaliation for exercising any of the rights protected by this policy and the various Equal Employment Opportunities statutes.

• Alcohol and Drugs

Overview:

• Policy statement and guidelines on alcohol and drug use in workplace

Policy Statement:

OLA Energy is committed to a safe, healthy, and productive workplace for all employees. OLA Energy recognizes that alcohol, drug, or other substance abuse by employees will impair their ability to perform properly and will have serious adverse effects on the safety, efficiency and productivity of other employees and OLA Energy as a whole. The misuse of legitimate drugs, or the use, possession, distribution or sale of illicit or unprescribed controlled drugs on company business or premises, is strictly prohibited and is grounds for termination. Possession, use, distribution or sale of alcoholic beverages on company premises is not allowed without prior approval of appropriate senior management. Being unfit for work because of use of drugs or alcohol is strictly prohibited and is grounds for termination of employment. While this policy refers specifically to alcohol and drugs, it applies to inhalants and all other forms of substance abuse.

OLA Energy recognizes alcohol or drug dependency as a treatable condition. Employees who suspect they have an alcohol or drug dependency are encouraged to seek advice and to follow appropriate treatment promptly before it results in job performance problems. Company health advisor or medical professional staff will advise and assist in securing treatment. Those employees who follow approved treatment will receive disability benefits in accordance with the provisions of established benefit plans and medical insurance coverage consistent with existing plans.

No employee with alcohol or drug dependency will be terminated due to the request for help in overcoming that dependency or because of involvement in a rehabilitation effort. However, an employee who has had or is found to have a substance abuse problem will not be permitted to work in designated positions identified by management as being critical to the safety and well-being of employees, the public, or OLA Energy. Any employee returning from rehabilitation will be required to participate in a company-approved after-care program. If an employee violates the Alcohol and Drug Use policy, disciplinary action cannot be avoided by a request at that time for treatment or rehabilitation. If an employee suffering from alcohol or drug dependency refuses rehabilitation or fails to respond to treatment or fails to meet satisfactory standards of effective work performance, appropriate disciplinary action, up to and including termination, will be taken. This policy does not require and should not result in any special regulations, privileges, or exemptions from normal job performance requirements.

The Company may conduct unannounced searches for drugs and alcohol on company owned or controlled property. The Company may also require employees to submit to medical evaluation or alcohol and drug testing where cause exists to suspect alcohol or drug use, including workplace incidents. Unannounced periodic or random testing will be conducted when an employee meets any one of the following conditions: has had a substance abuse problem or is working in a designated position identified by management, a position where testing is required by law, or a specified executive position. A positive test result or refusal to submit to a drug or alcohol test is grounds for disciplinary action, including termination.

Contractor, common carrier, and vendor personnel are also covered by paragraph one and the search provisions of paragraph four of this policy.

Procedures:

A full set of procedures managing this policy is available within your HR Department, the procedures address areas of use of prescribed legal medication at the workplace especially for critical positions, measures that make sure the Laboratory and medical staff implementing the tests are trained to perform tests.

• Workplace Harassment

Overview:

• Description: This policy is describing global principles on harassment and inappropriate conduct in the workplace. Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

• Stakeholders:
  • Responsibilities (Process owner): Human Resources
  • Accountability: General Managers/All Departments Managers
  • Consultation: Legal
  • Information: All employees

Policy Statement:

Our success as a business is attributable to the high quality and superior performance of our employees. We are therefore committed to creating a positive, supportive work environment for our employees to foster their professional growth, to maximize their individual contributions and to realize our business goals. Creating and maintaining this environment requires our workplace be free from any form of harassment. While all employees share in the responsibility for maintaining a harassment-free work environment, supervisors and managers have specific responsibilities for administering the Company’s harassment policy. The purpose of these guidelines is to clearly outline these responsibilities.

It is the policy of the Company to prohibit any form of harassment in any company workplace. The objective of this policy is to provide a work environment that fosters mutual employee respect and working relationships free of harassment.

Under the Company’s policy, harassment is any inappropriate conduct which has the purpose or effect of:

• Creating an intimidating, hostile, or offensive work environment;
• Unreasonably interfering with an individual’s work performance; or
• Affecting an individual’s employment opportunity.

Forms of harassment include, but are not limited to, unwelcome verbal or physical advances and sexually, racially, or otherwise derogatory or discriminatory materials, statements or remarks. All employees, including supervisors and managers, will be subject to disciplinary action up to and including termination for any act of harassment.

Individuals who believe they have been subject to harassment should immediately report the incident to their supervisor, higher management, or their designated Human Resources contact. All complaints will be promptly and thoroughly investigated. The Company will treat such complaints as confidentially as possible, releasing information only to those with a need or right to know.

Any employee or supervisor who observes or becomes aware of harassment should immediately advise their supervisor, higher management, or their designated Human Resources contact. No employee should assume that the Company is aware of a problem.

No retaliation will be taken against any employee because he or she reports a problem concerning possible acts of harassment. Employees can raise concerns without fear of reprisal. Questions about what constitutes harassment should be directed to the employee’s supervisor or Human Resources contact.

1. Categories of harassment
   There are two major categories of harassment
   • Hostile Work Environment
     The purpose or effect of this type of harassment is to unreasonably interfere with an individual’s work performance or to create an intimidating or offensive work environment. To determine if specific behaviour is truly intimidating or offensive a “reasonable person” test is applied. Would a reasonable person genuinely find this behaviour to create an intimidating, offensive or hostile work environment?
     Managers, supervisors, employees and non-employees can create a hostile work environment through their unwelcome offensive conduct.
   • Tangible Employment Action
     The purpose or effect of this type of harassment is to condition an employment action to the submission to inappropriate demands, often of a sexual nature.
     Generally, only managers and supervisors who have the ability to condition job benefits
     or opportunities to the acquiescence to sexual propositions can commit this type of harassment. However, employees in quasi supervisory roles (trainers or team leaders) can also be guilty of this type of harassment, if they make compliance with demands for sexual favours a basis for a tangible employment action e.g., being certified on an operating post, awarding of overtime or being given a special assignment
2. Forms of harassment
   Listed below are some of the forms that harassment might take, along with examples of prohibited behaviours:
   • Verbal: degrading jokes, comments or innuendoes relating to an individual’s characteristics; racial or ethnic slurs or epithets; sexually graphic comments unwanted sexual flirtations or propositions; threats of harm or violence. Verbal harassment can be in the form of oral or written communications, E-mail and voice mail.
   • Visual: derogatory, demeaning or suggestive posters, cards, cartoons, graffiti, drawings, suggestive gestures or objects, intimidating or threatening gestures.
   • Physical: unnecessary and unwanted touching; impeding or blocking movements; physical interference with normal work or movement; assault.
3. Manager’s and supervisor’s responsibilities
   Managers and supervisors (including temporary and relief supervisors) are responsible and accountable for:
   • Strict personal compliance with all provisions of the Company’s Equal Employment Opportunity (EEO) and harassment policies and objectives while at work and in those off-the job situations where the supervisors may be viewed as a company spokesperson or representative.
   • Ensuring that all personnel decisions are based on job related criteria and implemented in accordance with the Company’s EEO and harassment policy.
   • Ensuring that all company-sponsored social and recreational activities are administered in accordance with the Company’s EEO and harassment policy.
   • Ensuring the harassment and EEO policy are communicated to their employees; holding employees accountable for complying with the policies.
   • Ensuring the harassment policy is communicated to contractors at the work site and that contract workers are held to the same standards of conduct as employees; determining if a contract worker needs to be removed from the work site as a result of his/her actions.
   • Ensuring that the site has in place a process for resolving harassment complaints and that employees are aware of it.
   • Ensuring that Company facilities are free of all potential visual forms of harassment.
   • Creating and maintaining a work environment that fosters mutual respect among individuals and enables employees to bring harassment complaints forward.
   • Being mindful of working relationships among individuals in the work unit regarding verbal or physical forms of harassment.
   • Ensuring that employees are not subject to retaliation as a result of making a complaint or participating in an investigation.
   • Distributing this document to employees in who, while not formally designated as supervisors, might be perceived by others to be in a supervisory capacity. Examples are team leaders and lead professionals who would be perceived as having significant input into the employee’s conditions of employment, including overtime assignment and performance assessment.
4. Intervention requirements
   Managers and supervisors (including temporary and relief supervisors) are responsible and accountable for taking immediate corrective action when they become aware of behaviour that is potentially a violation of the harassment policy, for promptly contacting Human Resources, and for notifying their management when appropriate.
   • Harassment Complaint Received
   • Treat the complaint seriously and sensitively as you would any employee request for help. Your initial reaction will have a significant impact on how the employee will view you as a supervisor and whether other employees will come to you with similar concerns.
   • Be open and objective. Don’t be dismissive of, or prejudge, the allegation.
   • Manage requests for anonymity appropriately. Complainant should be advised that allegations of possible Company policy violations must be investigated. Complete anonymity cannot be assured once the investigation commences.
   • Obtain complete information from the complainant on the details of the incident
   • Advise complainant that the Company will investigate as confidentially as possible and will involve only those individuals who have information relevant to the complaint. Remind the complainant that information regarding the investigation will be disclosed only to those individuals with a need or right to know about the case.
   • Stress that retaliation against a complainant is prohibited by Company policy. Any retaliatory acts should be reported immediately to the supervisor or to an appropriate Human Resources contact.
   • Advise complainant that he/she will be informed of the investigation results and that if the evidence confirms harassment has occurred, appropriate disciplinary action will be taken. However, the employee will not be told of the specific action taken against an individual.
   • Contact Human Resources. Human Resources will advise regarding the extent of investigation required.
   • If an investigation team is determined to be appropriate, Human Resources (HR) will lead the investigation team and will review preliminary findings and recommendations with Legal. HR will then present the final report to the supervisor.
   • Review planned disciplinary and corrective actions with Human Resources, Legal and appropriate line management.
   • Advise the complainant of the results of the investigation in general terms (harassment did or did not occur) and if corrective action has or will be taken.
   • Implement endorsed action plan.

 

• Dress Code

Overview:

• Description: This policy is describing global principles on Dress Code policy.
  Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

Policy Statement

The dress code policy is designed to help us all provide a consistent professional appearance to our customers and colleagues.

Employees are expected to dress in business casual or smart casual attire unless the day’s tasks require otherwise. The last worked day of the week is generally considered as “casual day”.

Employees must always present a clean, professional appearance. Everyone is expected to be well-groomed and wear clean clothing.

Clothing with offensive or inappropriate designs or stamps are not allowed.

Clothing should not be too revealing.

Dress Code Violations

Managers or supervisor are expected to inform employees when they are violating the dress code. Employees in violation are expected to immediately correct the issue. Repeated violations or violations that have major repercussions may result in disciplinary action being taken up to and including termination.

• Health & Safety

Overview:

• Description: This policy is describing Guiding principles on Health matters.
  Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

• Application: All employees (modifications only as required by country law)
• Stakeholders:
  • Responsibilities (Process owner): Human Resources
  • Accountability: General Managers/All Departments Managers
  • Consultation: Legal
  • Information: All employees

Policy Statement:

It is Company’s policy to:

• Identify and evaluate health risks related to its operations that potentially affect its employees, contractors or the public;
• Implement programs and appropriate protective measures to control such risks, including appropriate monitoring of its potentially affected employees;
• Communicate in a reasonable manner to potentially affected individuals or organizations and the scientific community, knowledge about health risks gained from its health programs and related studies;
• Determine at the time of employment and thereafter, as appropriate, the medical fitness of employees to do their work without undue risk to themselves or others;
• Provide or arrange for medical services necessary for the treatment of employee occupational illness or injuries and for the handling of medical emergencies;
• Comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist;
• Work with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration of risk;
• Undertake appropriate reviews and evaluations of its operations to measure progress and to ensure compliance with this policy;
• Provide voluntary health promotion programs designed to enhance employees’ well-being, productivity, and personal safety. These programs should supplement, but not interfere with, the responsibility of employees for their own health care or their relationship with personal physicians. Information about employees obtained through the implementation of these programs should be considered confidential and should not be revealed to non-medical personnel except: at the request of the employee concerned, when required by law, when dictated by overriding public health considerations, or when necessary to implement the guidelines of the Alcohol and Drug Use policy.

Procedures:

SHEMS is the Management system detailing Safety, Health and Environment Protection, it includes a full set of procedures and guidelines managing all the SHE aspects.
This Management System is available within your SHE Department at affiliate level, the procedures address areas of protection and prevention of hazards and harm to employee’s Health and Safety.

• Protection of Intellectual Property and Critical Business Information

Overview:

• Description: This policy is describing Guiding principles on Policy for management and protection of information used by all affiliates. It communicates objective, defines the scope of information addressed, and defines actions to be taken to protect information that affiliates use to conduct their business.
  It sets a guideline for management and protection of information that might otherwise lead to a negative impact on the interests of the affiliate and its employees.
  Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

• Application: All employees (modifications only as required by country law)
• Stakeholders:
  • Responsibilities (Process owner): Human Resources
  • Accountability: Huma Resources
  • Consultation: Legal
  • Information: All employees and Contractors’ staff

Policy Statement:

Company Confidential Information:

For the Company, its confidential information is a valuable asset and every director, employee and agent of the Company must protect it. Confidential information includes all non-public information. It also includes personal information (regardless of its source) that we obtain in the course of business. We must take care that all confidential information is used for Company business purposes only and in case of personal information, in addition, it must be processed on instructions from the Company in accordance with laid out policies, procedures and guidelines and as per applicable privacy laws and regulations.

Upon joining our company, all employees sign a Confidentiality and Nondisclosure Agreement which details their confidentiality obligations to the Company. As employees, we have access to significant amounts of company information that may not be available to the public, and we should preserve the confidentiality of information obtained in the Company’s service. Information of a confidential, private and sensitive nature must be used responsibly and controlled and protected to prevent its prohibited, arbitrary or careless disclosure.

Unless the Company has provided its specific consent, which should preferably be in writing, or there is a legal or professional right or duty to disclose, we are prohibited from disclosing confidential Company information. Confidential or proprietary information about clients, our organization, or other parties, which has been gained through employment or affiliation with our company, may not be used for personal advantage or for the benefit of third parties.

Our Information Security Policy sets out the expectations on each of us to safeguard confidential information of OLA Energy and our third parties with the assurance of security, availability, integrity and confidentiality. The Acceptable Usage Policy provides the purposes for which OLA Energy IT resources may be legitimately used and our cybersecurity responsibilities. These policies together provide employees with the mandatory directive of safeguarding OLA Energy and client information. Our Company Privacy Policy sets out the expectations on each of us to process personal information belonging to our employees, clients, agents, consultants, suppliers, and contractors in a manner so as to ensure compliance with all applicable privacy laws and regulations, including processing through cross border data transfer between group entities. Unless authorized and contractually agreed, we are committed to protect the confidentiality of such personal information while processing such personal information, implement adequate technical and organizational measures and employees are made aware of and required to comply with mandated processes under Privacy Policy for responsible use, disclosure, storage, retaining or any other processing of such personal information.

Improper Opportunities

When we receive information as part of our job, we should not trade with it for our personal benefit. Neither should we pass on the information to our friends and family members or indirectly compete with the Company. Information obtained as part of our job should not be taken advantage of even after we leave the organization.

Classification of the information

Classified information should be clearly labelled by its originator and protected by recipients in a manner consistent with these guidelines and any other procedures issued by management. Information and materials (including visually transmitted information) that is not labelled in accordance with these guidelines and procedures is termed “unclassified information”. The absence of labelling does not indicate that the information may be disclosed or used outside the company. Employees are required to take reasonable steps to protect such unclassified information from inappropriate disclosure and use (including asking the originator to review its classification, where appropriate).

Business management may choose to add additional document labeling, particularly to communicate protection expectations related to third parties or joint ventures. For example, the term “Confidential” may be used to establish Company intellectual property rights for information shared with universities and research partners. While incremental labeling is at business management discretion, the base classification level should be clear.

All information should be considered for classification using the structure below and appropriately safeguarded against unauthorized actions, whether accidental or intentional. Furthermore, any information which, if inappropriately disclosed, modified or lost, could result in significant negative consequences to the Company on a competitive, legal or productivity basis is considered sensitive and should be classified as either Company Proprietary or Private based upon the following descriptions:

Proprietary

Materials containing sensitive operational, financial or technical information such as strategic business plans, supply chain strategy, and assessment of the competitive position. Some organization charts and research results may warrant this classification should they provide insights to strategic business plans and activities

Private

Sensitive personnel data relating to individual employees such as salary data, performance appraisal, potential, medical history, pre-employment background screening reports. This information must be handled in compliance with the Management and Protection of Information guidelines.

Company Use Only

Information that does not qualify as Proprietary or Private, but for which special attention is warranted prior to release outside the company may be classified as Company Use Only. Examples include telephone directories, some technical guidelines, some meeting agendas or notes, and training modules, etc. While not requiring the level of protection warranted by the categories above, discretion and judgment should be used in handling information bearing this classification.

Restricted Distribution

Extremely sensitive information may be further identified as “Restricted Distribution.”

For example:

Company Proprietary – Restricted Distribution

Company Private – Restricted Distribution

This designation is intended to prevent reproduction or forward without the authorization, or the authorization of an individual at a higher organizational level who is familiar with such information.

Privileged and Confidential

Used at the direction of and in compliance with guidance issued by the Law and Tax segments to designate attorney work product, attorney-client communications, and other privileged communications. Handling requirements are similar to those defined for Company Proprietary.

Roles and responsibilities

Management is responsible for ensuring compliance with the MPI policy and standards by their business unit. They provide guidance for the originators, owners, and users of information, including contractual arrangements with third parties, to ensure appropriate classification, handling, and reclassification/declassification.

The roles and responsibilities of people manipulating the information include the following:

Originators are responsible for determining the level of sensitivity of information, classifying and labelling it, accordingly, establishing distribution/declassification requirements, and complying with requirements for release of information outside the company. Management also designates owners of information, communicates requirements to staff, and monitors employee compliance.

Owners are responsible for periodic review of information classification and implementation of appropriate control measures

Employees and contractors are responsible for properly handling information and making appropriate arrangements for safeguarding information with third parties to whom information is transmitted. Such information includes, but is not limited to, financial, technical, and personnel information regardless of media form, whether written, electronic, magnetic, oral, or any other means, and whether being used, transmitted or stored. Recipients of classified information may not change classification levels and must provide protection consistent with that classification. Recipients of inappropriately classified information should notify originators, owners, or management.

Human Resources and Medical Unit

Focal points within the Human Resources and Medical Unit (where applicable) define requirements and provide guidance for handling Private information. HR and Medical Units also own respectively information generated by HR processes (e.g. performance appraisal, salary budgeting, medical appeals) and by Medical processes (e.g. fitness for duty reports).

Law and Tax

The Law and Tax Units provide specific guidance for protecting and designating information as Privileged and Confidential, as well as guidance on proper internal and external releases of information.

Research and Engineering

Research and engineering organizations are responsible for the oversight of research agreements that facilitate development, sharing, and licensing of technical research and engineering information among operating affiliates. They provide guidance on the proper internal and external release of technical information covered by the agreements and endorse intellectual property agreements that may affect research agreement rights and obligations.

Information technology (IT)

Information technology provides the services for storing electronic information. In support of MPI, IT Units maintain controls as outlined in service descriptions and service control statements. They provide end-user tools, training, and consulting expertise for risk-assessment processes and current electronic barriers. They provide support, as needed, in the investigation of incidents. IT maintains an electronic repository of the MPI policy and standard, handling guidelines, and awareness documents.

Public Affairs

Public Affairs provide guidance for the release of information through public appearances, speeches, news releases or any other disclosure to identify possible sensitivities associated with the event and ensure that communications activities are aligned with the Company’s business objectives. They maintain Public Statement Guidelines to provide guidance in preparation for public presentations.

Company Intellectual Property

The intellectual property (IP) of the Company must be protected as a vital business asset. Our IP portfolio includes copyrights, patents, trademarks, service marks, trade secrets, design rights, logos, brands and know-how. We must use our IP focusing on protecting these assets. It is important to ensure that to the extent permitted by law, the rights to all IP created using the Company’s time and expense that which are within the scope of our duties are assigned to and are the property of the Company. We should promptly disclose any works, inventions or developments we create to obtain legal protection over them.

Classification Guide and Handling Matrix Preparation

A classification guide provides the functional or business unit originators and owners of information with a tool for identifying, analyzing, classifying, declassifying, and handling classified information initially and on-going. The implementation of specific control point options is based on the level of classification, the assessment of risks, and the control point alternatives.

The MPI guidelines should be reviewed periodically and changed appropriately to meet the changing business environment, as well as to leverage more cost-effective safeguards as they evolve. The general approach for building a classification guide is as follows:

Identify the types of business unit information processed (e.g., financial, operational, technical, production, or sales) as well as the owners of this information. Determine whether third-party information is involved and what contractual restrictions may exist for that information.

For information not subject to third-party commitments, assess the value of the information, evaluate the impact to the company if this information was to become unavailable, inappropriately disclosed or compromised, and determine the likelihood of an incident occurring. Examples of impact include lost revenue, increased costs, financial liabilities incurred, and/or adverse publicity.

Prepare the classification guide to help determine the classification levels and control points that are most appropriate.

Implement handling procedures and control points that are tailored to business requirements and commensurate with the classification of information and level of risk. Be sure to include special contract requirements for third-party information.

Business units also have the flexibility to deploy powerful protection measures (such as encryption) as a means for streamlining control points, as well as deal with special circumstances such as extremely high volumes of information, abbreviated time schedules, etc.

Plan for declassification/reclassification (to include determination of the expiration of the classification and its re-labelling.)

• Protection of Employee Information

Overview:

• Description: This policy is describing Guiding principles on protection of employee information used by the Group. It Communicates objective, defines the scope of information addressed, and defines actions to be taken to protect information about employees. It sets a guideline for management and protection of employee privacy.

Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

Policy Statement:

In this age of the Internet where privacy has become an increasing concern, we take your privacy very seriously. The privacy and security of personal data (the “Personal Information”) is important to us.

By being an employee of OLA Energy, you acknowledge that you have read, understood and agreed to all the terms of this Privacy Policy as outlined below in the last page of the Code of Business Conduct.

• Collection of Information:

In the course of conducting business and complying with local regulations governing such matters as employment, tax, insurance, etc., we must collect Personal Information from you. The nature of the Information collected varies somewhat for each employee, depending on your employment responsibilities, your citizenship, the location of the facility where you work, and other factors.

We collect Personal Information from you solely for business purposes, including those related directly to your employment with the Company, and those required by local governmental agencies such as Tax authorities, Ministry of Labor.

Data collected may include, but is not limited to:

• Your name
• User ID(s)
• Phone numbers
• Email address (es)
• Mailing addresses
• Banking and other financial data
• Government identification numbers, e.g., Social Security number, ID number
• Date of birth
• Gender
• Health and disability data
• Family-related data, e.g., marital status,
• Personal and health – related data for you and your family

The Company will not knowingly collect or use Personal Data in any manner not consistent with this Policy.

Because the Personal Information collected by the Company is necessary for business purposes, you are required to provide it. Your refusal or failure to provide the requested Personal Information may, therefore, disqualify you from employment or from receipt or enjoyment of certain Company benefits.

• Use of collected information

The objectives of collecting, storing and using employee Personal information include, but are not limited to:

1. Human Resources Management:
   Personal Information is collected, stored, analyzed, and shared (internally) in order to attract, retain and motivate a highly qualified workforce.
   This includes recruiting, compensation and benefits administration, succession planning, reorganization, performance assessment and management, training, compliance with applicable legal requirements, and communication with employees and/or their representatives.
2. Business Processes and Management:
   Personal Information is used to run our business operations including, for example: scheduling work assignments, managing company assets, reporting and / releasing public data (e.g., Annual Reports, etc.); and populating employee directories.
   Information may also be used to comply with local government regulations.
3. Safety, Health and Security Management:
   Personal Information is used as appropriate to ensure safety, health and protection of our employees, assets, resources, and communities.
4. Communication and Identification:
   Personal Information is used to identify employees and to communicate with them.

• Disclosure of Data

The Company acts to protect Personal Information and ensure that unauthorized individuals do not have access to Information by using security measures to protect Personal Information.

It is not permitted to knowingly disclose, sell or otherwise distribute Personal Information to any third party without employee knowledge and, where appropriate, express written permission, except under the following circumstances.

• Legal requests and investigations:

The company may disclose Personal Information when such disclosure is reasonably necessary (i) to prevent fraud; (ii) to comply with any applicable statute, law, rule or regulation; or (iii) to comply with a court order.

• Third-party vendors and service providers:

The company may, from time to time, outsource services, functions, or operations of our business to third -party service providers. When engaging in such outsourcing, it may be necessary for us to disclose Personal Information to those service providers, e.g., a payroll service, a benefits provider. In some cases, the service providers may collect Personal Information directly from employees.

Service provider agreements are inclusive of clauses to restrict how the providers may access, use and disclose your Information. When using a third party provider, the company selects reliable third parties and written agreements are signed to ensure (i) the rights and obligations of each party are specified; (ii) that the third party has adequate security measures in place to protect the Personal Information; and (iii) the provider will only process Personal Information on the specific written instructions of the Company.

• Business Transfers:

During the employment period, company may buy other companies, create new subsidiaries or business units or sell part or all of its assets. It is likely that some or all of Personal Information will be transferred to another company as part of any such transaction. However, Personal Information will remain subject to protection outlined in the Privacy Policy.

• Protection of Company and Other:

Personal Information may be released when release is necessary to comply with the law; enforce or apply policies and other agreements; or protect the rights, property, or safety of Company, health of our employees, or others. This disclosure will never, however, include selling, renting, sharing or otherwise disclosing Personal Information for commercial purposes in violation of the commitments set forth in this Privacy Policy.

• Security of Personal Information

The Company implements reasonable security measures and technologies, such as password protection, encryption, physical locks, etc., to protect the confidentiality of Personal Information.

Only authorized employees have access to Personal Information. Below are some safeguards to help protect such Information:

• Paper and other hard copy containing Personal Information (or any other confidential information) should be secured in a locked location when not in use.
• Computers and other access points should be secured when not in use by logging out or locking.
• Passwords and user ID’s should be guarded and not shared.
• When no longer necessary for business purposes, paper and hard copies should be immediately destroyed using paper shredders or similar devices.
• Do not leave copies in unsecured locations waiting to be shredded or otherwise destroyed.
• Do not make or distribute unauthorized copies of documents or other tangible medium containing personal data.
• Electronic files containing Personal Information should only be stored on secure computers and not copied or otherwise shared with unauthorized individuals within or outside of Company.

Compliance with this Privacy Policy is important to the Company. Any violation or potential violation of this Policy should be reported to the Human Resources Department. The failure by any employee to follow these privacy policies may result in discipline up to and including termination of the employee.

Any questions or suggestions regarding this policy may also be directed to the Human Resources Department.

• Protection of Company’s Assets

Overview:

• Description: This policy is describing Guiding principles for the protection of company assets
  Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

Policy Statement:

We are all obligated to protect the Company’s assets and to ensure their careful and legitimate use. Our assets include resources such as office supplies, equipment, communications systems and vehicles, as well as proprietary information, intellectual property, financial resources and information. Theft, wasteful use of resources, and fraudulent activities are detrimental to our Company objectives and are prohibited.

Examples of fraudulent activities include, but are not limited to:

• Physical Access Control
• Misuse of Company Assets
• Abuse of Expense Claims
• Physical Access Control

OLA energy has developed procedures covering physical access control to ensure privacy of communications, maintenance of the security of the Company communication equipment, and safeguard Company assets from theft, misuse and destruction. We are responsible for complying with the security policies in your location. You must not defeat or cause to defeat the purpose for which the access control was implemented.

• Misuse of Company Assets

The use of the company assets for individual profit or any unlawful, unauthorized personal or unethical purpose is prohibited. Our information technology, intellectual property (e.g., copyrights, patents, and trademarks), facilities, equipment, machines, software, and cash may be used for business purposes only, including responsible and accurate expense reimbursement, and in accordance with applicable policies. Other assets (e.g., computers, printers, and copiers) may be used for minor and incidental personal purposes provided such use is kept to a minimum, and does not create any significant incremental costs, interfere with work duties, or violate any laws or Infosys policies. The use of any company resources for personal political activities is prohibited. Computer hardware, software, data, and facilities are valuable resources that need protection from potential destruction, theft, or misuse. These resources may also include confidential client or OLA Energy information that requires safeguarding. It is your responsibility to prevent unauthorized access through the use of ID badges, passwords, or other security codes, and physical security measures (such as using computer cable locks, not leaving computers unattended in cars, and other normal precautions). Software used in connection with the business of OLA Energy should be properly licensed and used only in accordance with that license. Using unlicensed software could constitute copyright infringement and may be grounds for disciplinary action.

• Abuse of Expense Claims

In a reasonable manner and for Business use only, employees are enabled to claim back expenses they incurred on behalf of the company.

Each supervisor, manager, and individual employee has an obligation to each other and to the Company to comply with the company business expenses and reimbursement policies and practices. All business-related expense claims must be authorized by your manager before being incurred. Personal expenses will not be reimbursed by the Company

• Social Media and External Communication

Overview:

• Description: This policy is describing Guiding principles for external communication and the use of Social Media
  Affiliates are expected to adopt similar policy that conforms to the policy principles, legal requirements, and customary practices in their operating areas.

Policy Statement:

Employees and representatives of OLA Energy are expected to demonstrate best practices and appropriate etiquette on social media, including but not limited to the following:

• Be respectful to all,
• No hate or racist speech,
• No confidential company info disclosure
• No negative reaction even on negative comments
• No use of personal social media account on behalf of the company

Guidelines for employees:

• How to respond to Customer Inquiries?

Employees are not expected to engage on Social media on behalf of the company, customer inquiries should be redirected to brand and communications unit for response.

• How to react to Questionable content

Employees are not expected to react or fight negative comments when coming across misinformation, news leaks, confidential information, or other questionable content regarding the company on social media. Only authorised spokesperson who have received proper media training should handle this with the approval of Brand and communications department.

• When do I need approval to post a message on social media?

Personal social media accounts must not be used for business purposes as it only represents the person’s own views and perspectives.

Social media networks, blogs and other types of online content sometimes generate press and media attention or legal questions. Employees should refer these inquiries to authorized spokespersons.

• What should I do on social media during a PR crisis?

Employees are not expected to react on behalf of the company, during PR crisis, OLA Energy Crisis Management Plans are in force.

• Can I share company results on Social Media?

Employees are not allowed to disclose information that are financial, operational and legal in nature, as well as any information that pertains to clients and customers

Consequences of Breach:

Social media use shouldn’t interfere with employee’s responsibilities; OLA Energy’s computer systems are to be used for business purposes only. When using computer systems, use of social media for business purposes is allowed (ex: Facebook, Twitter and LinkedIn), but personal use of social media networks or personal blogging of online content is discouraged and could result in disciplinary action.

Failure to comply with the social media policy may lead to employee termination.