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You should never enter into anti-competitive agreements or engage in anti-competitive conduct, such as
agreeing with competitors to fix prices or to allocate markets by territory, by products or by customers.
Never share non-public commercially sensitive information with our competitors. Be vigilant of situations
where such information can be exchanged, and speak up against disclosure of information by others.
X.
Compliance with Laws, Rules and Regulations
A concern for what is right underlies all business decisions. The Corporation may be held liable for the
wrongful actions of its directors, officers, employees or consultants in certain circumstances. Directors,
officers, employees, consultants, and non-employees must, therefore, ensure that their dealings and
actions on behalf of the Corporation comply with the requirements and intent of all relevant legislation
and regulations. This includes rules, regulations and guidelines established by self-regulating bodies or
professional organizations.
Compliance with both the letter and spirit of all laws, rules and regulations applicable to our business is
critical to our reputation and continued success. All directors, officers, employees, consultants, and non-
employees must respect and obey the laws of the cities, provinces and countries in which we operate and
avoid even the appearance of impropriety. Directors, officers, employees, consultants, or non-employees
who fail to comply with this Code or applicable laws will be subject to disciplinary measures, up to and
including discharge from the Corporation or, in the case of a director, provision of a resignation as a
director.
In addition to the laws imposed by statute, there is a duty upon a company to honour agreements, whether
in writing or not, and to act reasonably and in a manner that will not cause harm to others. Directors,
officers, employees, consultants, and non-employees must diligently ensure that their conduct is not and
cannot be interpreted as being in contravention of any laws governing the affairs of the Corporation in
any jurisdiction where it carries on business.
Ignorance of the law will not usually excuse a party who contravenes a law. Directors, officers,
employees, consultants, and non-employees must, therefore, work together with the Corporation to keep
informed of laws which may affect those affairs of the Corporation which are under his or her control.
Whenever in doubt about the application or interpretation of any legal requirement, the director, officer
employee, consultant or non-employee should seek the advice from one of the Corporation's senior
management team.
XI.
Compliance with Health & Safety and Environmental Laws
ORLEN Upstream Canada is committed to providing safe and healthful working conditions for all
employees and non-employees and to conducting its activities in an environmentally responsible manner.
We are all responsible for maintaining a safe workplace by following safety and health rules and
practices. The Corporation is committed to keeping its workplaces free from hazards. Please report any
accidents, injuries, unsafe equipment, practices or conditions immediately to a supervisor or other
designated person. Threats or acts of violence or physical intimidation are prohibited.
Employees, consultants and non-employees are expected to read and be aware of the Corporation's
Health, Safety and Environmental Policies and Procedures. Your awareness of such procedures should
assist the Corporation in improving operations thereby avoiding injury or sickness to all persons, and
damage to property and the environment, by giving due regard to all applicable safety standards,
regulatory requirements, technical, and conventional standards and restraints.
