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conflict immediately by completing and submitting a Declaration of
Conflict of Interest Form attached
hereto (refer to Schedule B).
III.
Corporate Opportunities
Directors, officers, employees, consultants, and non-employees are prohibited from taking for themselves
personally opportunities that arise through the use of corporate property, information or position and from
using corporate property, information or position for personal gain.
IV.
Confidentiality
Directors, officers, employees, consultants, and non-employees must maintain the confidentiality of
information entrusted to them by the Corporation or that otherwise comes into your possession in the
course of your retention or employment by the Corporation or in performing your duties to the
Corporation, except when disclosure is authorized or legally mandated. The Corporation is in a highly
competitive environment with other petroleum companies seeking the advantage of technical ideas or
information. Certain records, reports, papers, devices, processes, plans, methods and apparatus of the
Corporation, including methods of doing business and information on P&NG rights held, cost
information, geological maps, seismic, engineering and information system technologies, etc. are the
"intellectual property" of the Corporation and are considered to be strictly confidential. Officers,
employees, consultants and non-employees are not to reveal or use for any personal purpose such
confidential information without written consent from the Chief Executive Officer or Senior Vice
President, Finance. Directors are not to reveal or use for any personal purpose such confidential
information without the approval of the Board. The obligation to preserve confidential information
continues even after you are no longer involved with the Corporation.
Confidential information does not include information which is already in the public domain. Certain
information may be released by the Corporation (to comply with applicable laws and regulations for
example); however, the release of such information is a decision of the Board and/or senior management.
If there is any doubt as to what can or cannot be discussed outside of the Corporation, employees,
consultants or non-employees should err on the side of discretion and not communicate any information.
For more specific advice, an immediate supervisor or the Senior Vice President, Finance should be
consulted.
V.
Protection and Proper Use of Corporation Assets
All directors, officers, employees, consultants, and non-employees should endeavour to protect the
Corporation's assets and ensure their efficient use. You are responsible for safeguarding those assets
against theft, loss and misuse (as these have a direct impact on the Corporation's profitability). ORLEN
Upstream Canada's assets include facilities, equipment, computers, software, information, intangible
property rights and financial assets.
Any suspected incidents of fraud or theft should be immediately
reported for investigation.
Corporation assets such as funds, products or computers may only be used for legitimate business
purposes or other purposes approved by management. Corporation assets may never be used for illegal
purposes.
The obligation to protect Corporation assets includes proprietary information. Proprietary information
includes any information that is not generally known to the public or would be helpful to our competitors.
Examples of proprietary information are intellectual property, business and marketing plans and
