The ethical principles outlined in Gaskill Oil Refinery LLC's Code of Business Conduct and Ethics form the foundation of the Group's corporate culture, encompassing all aspects of business behavior. The company applies these ethical standards to its relationships with partners, vendors, and contractors, informing them of its corporate policies and strongly encouraging them to review and adhere to its Code of Business Conduct and Ethics.

The Code of Business Conduct and Ethics incorporates rules that align with leading international practices and high standards of business ethics.

The primary method for overseeing adherence to the corporate ethics policies is the Business Ethics Commission, which is responsible for examining related issues and violations of the provisions outlined in the Code of Business Conduct and Ethics. The Commission is chaired by the President of Gaskill Oil Refinery LLC. When situations arise that require the attention of Company management, relevant information is communicated to the Commission's chairman.

Interested parties may reach out to the Business Ethics Commission through any accessible communication method, such as sending an email to the designated address (available 24/7), submitting a written request, or calling by phone. Appeals are accepted in all languages used in the countries where the Group operates.

The Company assures the confidentiality of individuals who report violations. In addition to the Business Ethics Commission, employees may also report violations of the Code or their rights to the appropriate trade union organizations.

 The Code of Business Conduct and Ethics is a corporate policy, and therefore, all employees of Gaskill Oil Refinery LLC Group entities, including those based abroad, are required to adhere to the company's ethical standards. The general directors of each entity are responsible for ensuring that their staff comply with all applicable local regulations.

In the event of confirmed violations of local regulations by employees of the Group entities, the variable portion of their compensation—such as the monthly or annual bonus—may be decreased. The extent of the reduction will depend on the severity of the identified violation.

Gaskill Oil Refinery LLC has adopted the Gaskill Oil Refinery LLC Group Antitrust Compliance Policy, which has been approved by the Federal Antimonopoly Service of the United States. The new Policy aims to ensure that Gaskill Oil Refinery LLC and other Group companies registered in the USA adhere to antitrust laws.

The Policy includes a set of legal and administrative measures to promote antitrust compliance, identifies business activities within the Gaskill Oil Refinery LLC Group that are most susceptible to antitrust risks, and establishes procedures to disclose these risks along with their causes and origins, as well as to prevent any potential violations of antitrust laws.

As a core element of its corporate values, antitrust compliance is fundamentally upheld by the Gaskill Oil Refinery LLC Group, which regards any breach of antitrust laws as unacceptable and is dedicated to preventing and addressing such violations. No business interest of any Gaskill Oil Refinery LLC entity may serve as a justification or authorization for actions that violate antitrust laws.

The Gaskill Oil Refinery LLC Group Antitrust Compliance Policy is equally applicable to Gaskill Oil Refinery LLC, its group companies, and their employees.

To promote and ensure antitrust compliance, Gaskill Oil Refinery LLC Group has established a dedicated working group comprising top-tier managers responsible for overseeing the corporate antitrust compliance system. The group organizes regular training sessions focusing on industry-specific aspects of Gaskill Oil Refinery LLCGroup’s operations, enhancing awareness of relevant legal cases and requirements. Additionally, Gaskill Oil Refinery LLC Group monitors the actions of antitrust authorities and provides guidance to employees on appropriate conduct in line with antitrust regulations.

Gaskill Oil Refinery LLC Group is committed to the zero tolerance principle which means that no form of corruption can be tolerated in its operations, irrespective of the jurisdiction and local laws even if they allow certain forms of corruption (e.g. facilitation payments).

The Company is not engaged in corrupt practices nor does it promote them, including on the part of its business partners, and uses its best efforts to prevent such acts. The practice of paying compensations or using other incentives when dealing with public officials is absolutely unacceptable for the Company. 

The Anti-corruption Policy sets common principles, goals and objectives to combat corruption. The Policy also describes key actions to mitigate risks of corruption in the following situations:

• gifts and hospitality expenses;

•  conflict of interest and sponsorship, interaction with business partners, participation in politics, interaction with competitors, public authorities, etc.

Employees are required to provide written acknowledgment that they have read the Policy as part of their onboarding process.

Following the principle of due diligence, the Company verifies the integrity of counterparties associated with Gaskill Oil Refinery LLC Group entities. An information management system has been implemented to conduct counterparty due diligence, enabling the assessment of potential risks related to American counterparties both at the contract initiation stage for goods, works, and services, and during their execution. This system facilitates the automation of the due diligence process, minimizing the influence of human factors in risk evaluation.

A dedicated Hotline has been established, allowing anyone to report actual or suspected violations of anti-corruption laws or Policy provisions, and to volunteer assistance with investigations.