Anti-Corruption Policy

VERSION NUMBER: VOL-ANC-POL-00001

VAUXOIL LIMITED ANTI-CORRUPTION POLICY

As a company duly registered to carry out legitimate business in Nigeria in accordance with the Company and Allied Matters Act, VAUXOIL LIMITED is committed to a high ethical standard of unwavering integrity in all its business dealings, considerations and execution of work.

SPECIFIC GUIDELINES FOR EMPLOYEE OF THE COMPANY AND BUSINESS PARTNERS

All decisions related to the activities of VAUXOIL LIMITED are made exclusively and entirely based on the benefits of the company and not for any individual person, whether employee or otherwise.

Employees who are in a position to make commitment on behalf of VAUXOIL LIMITED shall not solicit, accept, offer or give gifts, favours, loans etc. to or from outside parties who might be doing business with the company. Also, cash gifts and/or gifts in cheques having an investment value such as stocks, bonds, etc. are prohibited.

The policy applies to all employee of VAUXOIL LIMITED and specifically employees who are involved in:

• Placing purchase order with suppliers or sub-contractors
• Selecting, recommending or approving suppliers
• Receiving or testing inspection for quality or technical functionality
• Evaluating supplier proposals, paying invoices or collecting money from consumers
• Approving or signing sales contracts with costumers
• Dealing with the authorities in a manner to have them influence or elicit favours.

HANDLING OF CONFLICTS OF INTEREST

In the event of a conflict of interest and if the employee is not sure about the correctness of an action, he/she should consult with the line manager or supervisor or if the circumstance warrant consult with legal counsel of the company. Any employee who becomes aware of a conflict should bring it to the attention of his/her superior or Managers.

ACCOUNTABILITY

If the board of directors of VAUXOIL LIMITED (BOD) or the Chairman/CEO determines that this policy has been violated, either directly or by failure to report, or by withholding information related to a violation, the offending party may be disciplined for non-compliance. Such disciplinary action or sanction may include suspension, demotion, re-assignment or dismissal. Violation of this policy may also constitute violation in law and will therefore attract criminal prosecution/penalties.

SIGNED BY CEO  - Date: April 12th 2021