Bribery Statement

The following principles outline Circle Oil’s unwavering commitment against all acts of bribery and other corrupt practices, through the measures set forth below. Bribery and corrupt practices are never tolerated in the pursuit of Circle Oil business objectives or goals or within business relationships or the actions of its employees and associated parties.

This commitment is driven from the CEO and Board throughout the entire Company and a reciprocal commitment is expected of all who work with the Company and who act on our behalf, in partnership with us, or are employed or engaged in any capacity by us or in the pursuit of our business.

Explanation for guidance regarding an act of Bribery.

The Company considers an act of bribery, or attempt to commit an act of bribery, to include the actual or possible offering, suggestion, requesting or accepting of a financial or other type of advantage or inducement with the:

(i) purpose of rewarding or initiating improper performance of a function or activity within an actual or potential business relationship, function, activity or negotiation involving the Company ;

and/or

(ii) the knowledge or belief that the acceptance of such an inducement or payment would constitute the improper performance of such a relationship, function, negotiation or activity.

Company Principles

Circle Oil shall carry out our business fairly, honestly and respectfully, in accordance with any applicable laws and regulations.
Circle Oil shall not offer, nor suggest the offering of bribes or other inducements, nor will we condone the offering of bribes or other inducements on our behalf, so as to gain a business advantage or maintain an existing business relationship or business activity. This includes the use of illicit facilitation payments.
Circle Oil shall not accept, nor tolerate the suggestion of an acceptance, of bribes or other advantage, nor will we agree to them being accepted on our behalf in order to influence business.
Circle Oil will stand by these principles in all circumstances and situations
Circle Oil shall avoid doing business with others who do not accept our values and who may harm our reputation. Circle Oil will not undertake business with any others who do not uphold similar commitments nor accept our Company commitment against corrupt practices.
Circle Oil seeks to conduct business relationships in such a way that direct or indirect bribery are never considered nor undertaken on our behalf or in our name, and that all parties, including partners contractors, advisers etc. act in accordance with and support our values
Circle Oil expects the pursuit of its business and the undertaking of all business relationships shall be undertaken within the boundaries of all applicable laws at all times, including those of an extraterritorial scope such as the UK Bribery Act 2010.
Circle Oil maintains for inspection accurate books and records that properly and fairly document all financial transactions in all our directly controlled entities.

Risk Assessment & Due Diligence

Circle Oil shall analyse which specific areas pose the greatest risks from bribery, to design and implement policies and guide the undertaking of any business transaction or relationship accordingly
Circle Oil shall implement this commitment against bribery in all business entities over which we have effective control. In cases where Circle Oil maintains influence through business relationships or acts as operator or lead partner, to use our influence to encourage a reciprocal programme and to implement procedures that assess the ethics of the third party.
Circle Oil shall not allow improper payment to be actionned through Agents or associated companies or any other third party.
Circle Oil shall undertake properly documented due diligence before appointing contractors, agents or any for any relationship that requires any other directly engaged third parties and would expect this to be undertaken by them in turn for any party the former may engage in pursuit of our business, an associated party, such as a contractor or an advisor or partner.
Any significant agreements with contractors, associates and third parties shall require approval at least by the CFO and/or CEO.
Compensation paid to contracted parties, agents and other intermediaries shall be appropriate and justifiable remuneration for legitimate services rendered
Contracted Parties and other intermediaries shall comply with the Company stance against corrupt practices including against bribery.
Circle Oil maintains the right to monitor the conduct of any contracted third parties and other intermediaries and shall have the right of termination in the event that they pay bribes or offer inducements or illicit payments or act in a manner unbefitting of our Company policies or any applicable law.

Gifts and Hospitality

Circle Oil does not allow the offer or receipt of gifts, hospitality or expenses whenever they could affect or be perceived to affect the outcome of business transactions and are not reasonable and bona fide.

Employment

Circle Oil commits that no employee will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes or undertake any other illicit facilitation inducement, even if such refusal results in the Company losing business.

Charitable and Political Donations

Circle Oil shall ensure that charitable donations and sponsorships are not used as a subterfuge for bribery, nor that any hospitality or gift should be used similarly.
Circle Oil documents all charitable contributions made, with this being reviewed for appropriateness on a timely basis.
Circle Oil does not allow the payment of any political donation to be undertaken in the name of or on behalf of the Company. This is in addition to the fact that Circle Oil does not allow any payment or advantage sought or offered by or to any government or public official or body to be accepted proffered or given in its name or on its behalf.

Revision and Monitoring

Circle Oil shall at least annually review and update our policies, commitments and processes or may revise any element of our business practices and principles including these as needed.

Last revised 25th June 2011

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