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employee information. The obligation to preserve proprietary information continues even after you are no
longer involved with the Corporation.
VI.
Insider Trading
Insider trading is unethical and illegal. You may become aware of information about publicly traded
entities and companies that is not publicly available. Such information may constitute insider information.
Insider information is precise information likely to have a significant effect on the price of securities and
which is not publicly available or commonly known to the market. If you are in possession of inside
information, even if acquired incidentally, you have a legal duty of confidentiality to prevent such
information from coming into the possession of unauthorised persons. Any use of inside information
about publicly traded companies for personal gain is prohibited.
Directors, officers, employees, consultants, and non-employees are not allowed to trade in securities of a
company while in possession of material non-public information regarding that company. It is also illegal
to "tip" or pass on inside information to any other person who might make an investment decision based
on that information or pass the information on further.
VII.
Fair Dealing
Each director, officer, employee, consultant, and non-employee
should endeavour to deal fairly with the
Corporation's customers, suppliers, competitors and employees. No director, officer, employee,
consultant, and non-employee
should take unfair advantage of anyone through illegal conduct,
manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any
other unfair-dealing
VIII.
Suppliers, Contractor's and Business Partners
Trusting and transparent business relationships are vital to our business. ORLEN Upstream Canada's
suppliers, contractors and business partners (intermediaries, agents, consultants, lobbyists, etc) are
essential to our ability to do business, but can also expose us to reputational, operational and legal risk.
We expect our suppliers and business partners to comply with applicable laws, respect internationally
recognised human rights and adhere to ethical standards which are consistent with our ethical
requirements when working for or together with us. We seek to work with others who share our
commitment to ethics and compliance, and we manage risk through in-depth knowledge of our suppliers,
contractors, business partners and markets.
IX.
Fair Competition
ORLEN Upstream Canada believes in the benefits of competition. We strive to compete in a fair and
ethically justifiable manner. We will comply with all applicable competition laws. The Corporation will
not engage in or tolerate anyone who engages in anti-competitive behaviour, such as price fixing, bid
rigging, market sharing or abuse of market power.
ORLEN Upstream Canada participates in legal collaborative projects with other companies and shares
necessary information required for such projects. It may nevertheless be a violation of competition laws to
receive or share with competitors non-public commercially sensitive information beyond what is
necessary for the legal cooperation. Commercially sensitive information includes information which may
reduce uncertainty about future market conduct, such as future prices, competitive bids, commercial
strategies, costs, customers and suppliers.
