It is the policy of FIRST E&P to respects its Employees’ right to privacy in their personal affairs and activities. However, a conflict of interest may arise where an Employees’ personal, social, financial or political interest may influence or appear to interfere with the employees’ loyalty to or objective exercise of their duties and performance for FIRST E&P.

In the case where an employee or personnel who works at or with FIRST E&P believe that they have or might have a potential or actual conflict of interest then they must immediately register the conflict with their line manager. In turn, the line manager is responsible to escalate this to the relevant Executive Director.

An increasing number of countries are adopting laws to prohibit bribery even if it takes place outside of their borders. Under both the UK Bribery Act and the US Foreign Corrupt Practices Act (FCPA), a bribery offence can be committed by the provision of a financial or “other advantage” to an individual. Inappropriate and conflicted personal/business relationships could, under certain circumstances, amount to an advantage which could lead to an individual being accused of bribery.

Notification and management of actual or potential conflicts of interest will keep FIRST E&P and its employees from committing an offence under the UK Bribery Act and the US FCPA. The objective of this Policy is to ensure that potential or actual conflicts of interest are identified, disclosed and effectively managed.

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