Policy

Mayport Oil and Gas Company Limited Company Policy

Introduction

This company policy outlines the principles, values and standards that guide the conduct and performance of Mayport Oil and Gas Company Limited (the “Company” or “Mayport”) and its employees, contractors and business partners. The policy is based on the Company’s commitment to operate in a socially and environmentally responsible manner, in compliance with applicable laws and regulations, and in alignment with the best practices of the oil and gas industry.

The company policy is consistent with the Company’s vision, mission and core values, which are:

  • Vision: To be a leading provider of oil and gas services in Nigeria and beyond, delivering customized and unrivaled solutions to our clients and partners.
  • Mission: To leverage our expertise, technology and innovation to execute oil and gas projects safely, efficiently and sustainably, while creating value for our shareholders, employees and communities.
  • Core Values: Integrity, Diversity, Excellence, Teamwork, Health and Safety, Innovation, Collaboration and Partnership.

The company policy applies to all employees, contractors and business partners of Mayport, as well as anyone else acting on behalf of the Company. The policy covers various aspects of the Company’s operations, such as:

  • Business Conduct and Ethics
  • Health, Safety, Security and Environment
  • Human Rights and Labor Standards
  • Diversity and Inclusion
  • Corporate Governance and Transparency
  • Stakeholder Engagement and Communication
  • Corporate Citizenship and Social Responsibility

The company policy is not intended to be exhaustive or to address every situation that may arise in the course of the Company’s business. Rather, it provides a framework and guidance for making ethical and responsible decisions that reflect the Company’s values and expectations. The policy is also subject to periodic review and revision to ensure its relevance and effectiveness.

Business Conduct and Ethics

Mayport is committed to conducting its business with honesty, integrity and respect for people, in accordance with the highest ethical standards and in compliance with applicable laws and regulations. The Company expects its employees, contractors and business partners to act in the same manner and to uphold the Company’s reputation and trust.

The Company has adopted a Business Conduct and Ethics Code that provides detailed information and guidance on how to conduct the Company’s day-to-day business activities in a lawful and ethical manner. The Code covers topics such as:

  • Conflicts of Interest
  • Anti-Bribery and Corruption
  • Fair Competition and Antitrust
  • Trade Compliance and Sanctions
  • Insider Trading and Confidential Information
  • Data Privacy and Protection
  • Intellectual Property and Proprietary Information
  • Gifts and Entertainment
  • Political Activities and Contributions
  • Charitable Donations and Sponsorships
  • Records Management and Reporting
  • Ethics and Compliance Program and Resources

All employees, contractors and business partners of Mayport are required to read, understand and comply with the Business Conduct and Ethics Code, as well as any other policies and procedures that are relevant to their roles and responsibilities. The Company provides regular training and communication on the Code and related topics to ensure awareness and compliance. The Company also encourages its employees, contractors and business partners to speak up and report any actual or suspected violations of the Code or any other unethical or illegal conduct, without fear of retaliation or reprisal. The Company has established various channels and mechanisms for reporting and investigating such matters, as well as for providing guidance and advice on ethical and compliance issues.

The Company will not tolerate any violation of the Business Conduct and Ethics Code or any other unethical or illegal conduct by its employees, contractors or business partners. The Company will take appropriate disciplinary and corrective actions, up to and including termination of employment or contract, against anyone who violates the Code or engages in any misconduct. The Company will also cooperate with the relevant authorities and regulators in the event of any investigation or prosecution of such violations or misconduct.

Health, Safety, Security and Environment

Mayport is committed to protecting the health, safety, security and environment (HSSE) of its employees, contractors, clients, partners and communities, as well as the quality and integrity of its assets and operations. The Company recognizes that HSSE is a core value and a critical factor for its success and sustainability. The Company strives to achieve excellence in HSSE performance and to continuously improve its HSSE management system and culture.

The Company has adopted a Health, Safety, Security and Environment Policy and Commitment that defines its HSSE objectives and expectations, as well as a Health, Safety, Security and Environment Management System that provides the framework and tools for implementing and monitoring its HSSE policy and performance. The Policy and Management System cover topics such as:

  • HSSE Leadership and Accountability
  • HSSE Risk Assessment and Control
  • HSSE Standards and Procedures
  • HSSE Training and Competence
  • HSSE Audits and Reviews
  • HSSE Performance Measurement and Reporting
  • HSSE Incident Reporting and Investigation
  • HSSE Emergency Preparedness and Response
  • HSSE Contractor and Supplier Management
  • HSSE Stakeholder Engagement and Communication

All employees, contractors and business partners of Mayport are required to comply with the Health, Safety, Security and Environment Policy and Management System, as well as any other applicable laws and regulations, standards and best practices, and client and project requirements, related to HSSE. The Company expects its employees, contractors and business partners to demonstrate personal commitment and responsibility for HSSE, to follow the Company’s HSSE rules and procedures, to intervene and stop any unsafe or environmentally harmful acts or conditions, and to report and learn from any HSSE incidents or near misses. The Company also expects its employees, contractors and business partners to support and participate in the Company’s HSSE initiatives and programs, such as:

  • HSSE Awareness and Recognition
  • HSSE Campaigns and Events
  • HSSE Suggestions and Feedback
  • HSSE Awards and Incentives

The Company will not compromise its HSSE standards and performance for any business or operational reason. The Company will recognize and reward its employees, contractors and business partners for their HSSE achievements and contributions, and will take appropriate disciplinary and corrective actions, up to and including termination of employment or contract, against anyone who violates the HSSE policy or rules, or engages in any HSSE misconduct. The Company will also cooperate with the relevant authorities and regulators in the event of any investigation or prosecution of such violations or misconduct.

Human Rights and Labor Standards

Mayport is committed to respecting and promoting human rights and labor standards in its operations and activities, in accordance with the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, and the United Nations Guiding Principles on Business and Human Rights. The Company recognizes that human rights and labor standards are essential for the dignity and well-being of its employees, contractors, clients, partners and communities, as well as for the stability and sustainability of its business and the society.

The Company has adopted a Human Rights and Labor Standards Policy and Statement that expresses its respect and support for human rights and labor standards, as well as a Human Rights and Labor Standards Due Diligence Process that provides the methodology and criteria for identifying, assessing, preventing, mitigating and addressing any actual or potential adverse impacts on human rights and labor standards that may be caused by or linked to its operations and activities. The Policy and Due Diligence Process cover topics such as:

  • Non-Discrimination and Equal Opportunity
  • Freedom of Association and Collective Bargaining
  • Forced Labor and Human Trafficking
  • Child Labor and Young Workers
  • Working Hours and Wages
  • Health and Safety
  • Harassment and Abuse
  • Grievance Mechanisms and Remediation
  • Community Engagement and Development
  • Indigenous Peoples and Cultural Heritage

All employees, contractors and business partners of Mayport are required to comply with the Human Rights and Labor Standards Policy and Due Diligence Process, as well as any other applicable laws and regulations, standards and best practices, and client and project requirements, related to human rights and labor standards. The Company expects its employees, contractors and business partners to respect and uphold the human rights and labor standards of themselves and others, to avoid any actions or omissions that may infringe or violate such rights and standards, and to report and address any actual or potential adverse impacts on such rights and standards. The Company also expects its employees, contractors and business partners to support and participate in the Company’s human rights and labor standards initiatives and programs, such as:

  • Human Rights and Labor Standards Awareness and Training
  • Human Rights and Labor Standards Risk Assessment and Management
  • Human Rights and Labor Standards Monitoring and Reporting
  • Human Rights and Labor Standards Stakeholder Dialogue and Consultation
  • Human Rights and Labor Standards Performance Improvement and Innovation

The Company will not tolerate any violation of the Human Rights and Labor Standards Policy or any other infringement or violation of human rights and labor standards by its employees, contractors or business partners. The Company will take appropriate disciplinary and corrective actions, up to and including termination of employment or contract, against anyone who violates the Policy or engages in any human rights and labor standards misconduct. The Company will also cooperate with the relevant authorities and regulators in the event of any investigation or prosecution of such violations or misconduct.

Diversity and Inclusion

Mayport is committed to fostering diversity and inclusion in its workforce and workplace, as well as in its business relationships and practices. The Company values and respects the diversity of its employees, contractors, clients, partners and communities, in terms of their backgrounds, perspectives, experiences, skills and talents. The Company also strives to create and maintain an inclusive culture and environment, where everyone is treated fairly and equitably, and where everyone can contribute and thrive.

The Company has adopted a Diversity and Inclusion Policy and Strategy that articulates its vision, goals and actions for advancing diversity and inclusion in its organization and operations. The Policy and Strategy cover topics such as:

  • Diversity and Inclusion Leadership and Accountability