The Policy on Business Conduct and Ethics (PBCE) is a statement of the principles to which Lechwe Maritime & Logistics Limited is committed and upholds across its operations worldwide.

The Policy and associated (Annual) Ethics Awareness raining reflect our Values and commitment to conduct business safely, in an ethically, socially and environmentally responsible manner. It explains the way we do business and sets standards for everyone who works for, or on behalf of, Lechwe to follow. It has also been developed to be consistent with the law in jurisdictions where we operate and internationally recognized standards that Lechwe adheres to, including the United Nations Global Compact, the Voluntary Principles on Security and Human Rights and the Extractive Industries Transparency Initiative. In the upstream business we are subject to many different laws and local customs in different parts of the world, and of course often what we do in one part of the world is reflected and played back in another.

That is the benefit and price of being a global company. We must take great care to apply consistent standards to the way we do business everywhere. It is each employee’s accountability to know about this Policy and to apply it in all situations. This Policy applies not only to Lechwe employees, officers and directors, but also to dependent contract workers to the extent they conduct activities at or for Lechwe. The Company expects co-participants and third party suppliers to apply these same ethical business practices. Everyone conducting work on the Company’s behalf is an ambassador of Lechwe. You are encouraged to act in a manner that upholds the spirit of the Policy and demonstrates Lechwe’s values every day. As such you have the responsibility to read this Policy and consider what it means for you.

In particular we want to draw your attention to several areas. Changing legislation and the expectations of stakeholders have raised the profile of anti bribery and corruption. We want to send a clear message that our corporate culture does not sanction things that can be construed as unethical. We have a “zero tolerance” approach to corruption, which also means prohibiting facilitation payments: this puts us in line with the top tier operators in our industry. Equally, the Policy on Business Conduct and Ethics makes reference to and supports enhanced commitments in the areas of safe operations and community relations to reflect progress made over the past two years.

If at any time you have a question, are unsure about what to do, or have a concern that someone has undertaken an action inconsistent with the Policy you have the responsibility to raise the issue even if the message is difficult. Honest communication is critical. You can do this a number of ways including speaking with the Legal department or your Supervisor, Manager, Country Manager or Executive Vice President. Furthermore, you are strongly encouraged to report any business ethics concerns via Lechwe’s Integrity Matters.

Maintaining the goodwill of our stakeholders, including employees, governments and communities is critical to our Company’s objective of maximizing shareholder value. All activities undertaken by Lechwe must, of course, be lawful and safe, but it is equally important that these be conducted in an ethical, honest and fair manner, free from deception and impropriety, and with constant regard for Lechwe’s reputation. This is the foundation of our license to operate and without that we have no business. By our continued commitment to the principles embodied in this Policy.