Policies & Code of Conduct

Gunvor has established clear policies for ABC, AML, market conduct, market abuse, economic sanctions### Economic Sanctions: **Definition:** Economic sanctions are a form of punitive measure taken by one or more countries against a targeted country, group, or individual in an attempt to influence..., and other risk areas. They have been communicated from the top-down. Importantly, we have also created a whistleblowing policy that has been clearly communicated by the CEO to all Gunvor employees.

Specifically regarding ABC, policies and procedures and systems and controls meet standards put forth by the US. Foreign Corrupt Practices Act, UK Bribery Act and those propagated by the OECD. With respect to breaches, Gunvor maintains a zero-tolerance approach.

In the context of Gunvor’s Payments to Governments Policy, the company has expressed support for the Extractive Industries Transparency Initiative (EITI) to establish a consistent means by which to reliably report on its payments to governments, with the aim to improve transparency and reduce the potential for corruption in cooperation with these governments.

Gunvor’s reporting includes purchases of crude oilCrude oil refers to unrefined petroleum that is found with the Earth’s crust. and refined oil products**Oil Products** Oil products, also known as petroleum products, are the end products derived from the processing of crude oil in oil refineries. Crude oil is a fossil fuel that... acquired from state-owned enterprises in EITI implementing countries.