1. Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between employees in both personal and professional relationships;
2. Achieving the fair and just structure of labor regulations to secure self-esteem and respect amongst employees;
3. Understanding how the successful and healthy relationships among coworkers can result in intriguing results that would help endorse the organization;
4. Realizing the essence of team work, cooperation and solidarity, the features of successful organizations;
5. Forming an outline that employees shall abide by in order to work in a healthy environment, develop their skills, create and build new humanitarian principles through learning how to act and react with their coworkers and to gain equal opportunities;
6. The prompt internal violation of this code;
7. Accountability for adherence to this Code.

This Code should help guide your conduct in the course of our business. However, many of the principles described in this Code are general in nature, and the Code does not cover every situation that may arise. Use the Common Sense, Good Faith and Good Judgment in applying this Code. Should you have any questions regarding this Code; it is your responsibility to seek guidance.

The Code is not the exclusive source of guidance and information regarding the company’s regulations relating to the conduct of our business. You should consult applicable policies and procedures in specific areas as they help. The Code is intended to supplement other policies and procedure in the company, and not to replace them.

The company is committed to continuously reviewing and updating its policies and procedures. The company, therefore, reserves the right to amend, alter or terminate this Code at any time and for any reason.

This short summary is obviously not meant to address every instance in which we are called upon to observe and practice sound business ethics. However, it is meant to remind us that if we each strive to live and abide by basic ethical principles in the day-to-day conduct of our business, we will foster an environment of mutual trust and respect, and continue to build on our global reputation for integrity, which is the foundation of the company.

Believes that trusting, long-term relationships are built through honesty, openness and fair play. All aspects of our business must be based on the highest ethical standards. Since our employees are the key to our success and we’re all part of the corporate team, we all must take responsibility for our own actions and conduct. In addition, since managers are responsible for directing the actions of others and for setting an example for other employees, they should be familiar with this Statement of Values and Business Ethics and how it applies to them and to those under their supervision. It should be remembered that no one has authority to require or influence another employee to violate this code of conduct, and any attempt to do so may result in immediate disciplinary action, up to and including termination of employment.

Since good judgment is a fundamental basis of everything Karen Petroleum does as a company, understanding our ethical and legal parameters can only strengthen that judgment. Since we are a global company, we have a responsibility to follow applicable laws and regulations in all locations where we do business.

Instances where the law is not explicit require using good judgment, adhering to the spirit of the law, and following the principles of honesty, integrity, and common sense. Also, on occasions where local country law is in conflict with the Karen Petroleum Statement of Values and Business Ethics, local country law will apply.

All employees are expected to contribute to the success of Karen Petroleum by performing their jobs as required and conducting themselves in a professional manner consistent with the company’s business philosophy, values and standards of business conduct. Employee honesty and integrity are essential to ethical business practices. Employees are required to prepare all reports, including expense reports, time cards, and sales reports accurately and truthfully. Additionally, it is essential to avoid making misrepresentations or dishonest statements to anyone inside or outside the company.

The following list includes, but is not limited to, unacceptable conduct that is considered detrimental to the company’s best interests and may result in immediate disciplinary action, up to and including termination of employment:

• Falsification of facts or company records
• Unethical, immoral, indecent or illegal conduct
• Harassment (which includes, but is not limited to, sexual harassment, physical fighting, or other abusive conduct creating an intimidating, hostile or offensive work environment)
• Discrimination against any employee or applicant due to race, religion, color, national origin, gender, sexual orientation, age, disability, veteran or marital status.
• Deliberate destruction of company or other employee’s property
• Deliberate work stoppage or slowdown
• Theft, misappropriation, or unauthorized personal use of company property or property of others
• Insubordination/refusal to follow legitimate direction from a manager or deliberately undermining a manager’s authority
• Any action which seriously impacts the company business or image in a negative or destructive way
• Any conduct that poses a serious threat to the health or safety of employees or company operations
• Unsatisfactory attendance or abuse of sick leave
• Consumption or being under the influence of alcoholic beverages on company premises
• Misuse of Karen Petroleum property, including the company’s equipment, supplies, e-mail, internet, and computer systems can constitute unethical conduct.

These tools and resources are intended to assist employees in conducting legitimate company business, and any other use of such property is discouraged.