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Become aBetter CorporateCitizen
06
Codeof BusinessConduct
DolphinEnergy is committed toactwith
integrityandhaveno tolerance for corruption.
It is important thatweare clear about the
behavioral standardsweexpect fromall our
employees andanyonewhoactsonour behalf,
and that theyunderstand the importanceof
actingwith integrity. This iswhereourCode
of BusinessConduct (CBC) comes in. OurCBC
is the fundamental tool for communicating
theseexpectations. It serves as themainethical
guidance referenceand is a compilationof all the
policies andprocedures intended toensure that
the company conducts itself ina legal andethical
manner andavoids conflictsof interest.
All employeesare required tocertify that they
have reviewed theCBCandconfirmunderstanding
of their responsibilitiesbycompletinganannual
Professional ConductDeclaration.
TheComplianceOfficer takes responsibility for
theCBC,making sure that employees adhere toall
policies, anddelivers the requiredcommunication
and training for staff.
In2014, DolphinEnergy rolledout anonline
CBC trainingand certificationprogrammade
mandatory for all employees. In2015, theLegal
Department launcheda campaign to reinforce
information contained inourCBC. All staffwere
invited to sessionsheldatRas Laffanand inDoha
which sawaverypositive turnout. As a result
of these sessions, staffaremoreawareof the
way their conduct affectsour business and staff
membershave raisedqueries andbeenmore
mindful of theCodeof BusinessConductwhen
interactingwithothersboth insideandoutside
of theorganization.Wewill sustain this effort
in2016 toensure thatwe conduct our affairs
transparentlyandethically.
DolphinEnergymaintains an integrityhelpline
andemail address for confidential reportingof
matters related to theCBCor anydisclosure
ofmalpracticewithout the fear of retaliation.
In2015, therewereno reportsof concernor
violations. Should the company receivea report
ofmisconduct,wehaveaCorporate Investigation
Policy toguide investigationsof alleged incidents
of corruptionor fraudand toensure integrity
andaccountabilitywithin the coreof the
company’sgovernance.
Inorder to safeguard the integrityof the
organization, DolphinEnergy refuses to conduct
businesswithvendorsor suppliers inwhich
directorsor close familymembersof employees
havevested interests, orwhichmayaward
benefitswhollyor partiallyderived from the
business todirectors, employees, or employees’
relatives. All vendors and contractorswith
singleor cumulative commitmentsor potential
yearlybusinesswith the companyexceeding
USD50,000must receivea copyof theCBC
andacknowledge compliance inwriting. Full
compliancewith thispolicy is a conditionof
entering intobusinesswithDolphinEnergy,
andviolationswill be regardedas amaterial
breachof agreement. Therewerenobreaches
of integrityby contractors that led to termination
of contracts in2015.
