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Malta Oil & Gas

Malta Oil & Gas Code of Business Conduct Approved April 2012 Paul R Thomson 1 BC COC 0412 Table of Contents 1. INTRODUCTION page 4 2. LEGAL COMPLIANCE page 5 3. EMPLOYEES page 5 COMMITMENT TO EMPLOYEES page 5 FAMILY CONNECTIONS AND EMPLOYMENT OF RELATIVES page 6 CONTROLLED SUBSTANCES AND DRUGS page 6 ALCOHOL page 6 GAMBLING page 7 4. DATA PRIVACY page 7 5. THE COMMUNITIES IN WHICH WE WORK page 7 6. MISCELLANEOUS page 7 RELATIONSANDDEALINGSWITHGOVERNMENTOFFICI ALS,SUPPLIERS,PARTNERS, CONSULTANTS, AGENTS, INTERMEDIARIES AND OTHER THIRD PARTIES page 7 CONFLICT OF INTEREST page 8 BRIBERY AND CORRUPTION page 8 UNSOLICITED GIFTS, FAVOURS OR OTHER ADVANTAGES page 9 POLITICAL CONTRIBUTIONS

the Company’s high standards require. This includes knowing when to seek guidance on the proper course of action. 2. Legal Compliance

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