ANTI-BRIBERY & CORRUPTION (ABC)

POLICY
Context · NLNG has a zero tolerance policy towards fraud and is committed to the promotion of an anti-
· Enforcement of anti-bribery and corruption laws has stepped up significantly in the last decade in Nigeria fraud culture in the Company. Management and staff are responsible for preventing, detecting and
and across the world. Aside from the penalties, the taint of bribery and corruption could significantly tarnish reporting fraud and promoting this policy with third parties.
an organization's reputation. · It is NLNG's policy that there will be a thorough investigation of all allegations or suspicions of fraud
· Our reputation and success as a company is built upon a foundation of integrity – a commitment to act and necessary actions will be taken where fraud is proven in line with the ABC policy.
within the highest ethical standards and to conduct business honestly and legally. Our Code of Conduct
reflects this commitment. Human Resources
· NLNG's human resources practices including recruitment, promotion, training, performance
Purpose evaluation, remuneration and recognition will reflect the Company's commitment to the ABC
· The purpose of this policy is to reinforce NLNG's business principle of zero tolerance to bribery and policy.
corruption by providing a framework to guard and promote the Company's reputation for integrity and
responsibility. The policy will support the implementation of the NLNG Anti Bribery and Corruption Training & Certification
programme underpinned by robust policies and transparent processes. · Directors, Managers, employees and agents of the Company shall receive appropriate
training and guidance on the ABC programme. Every Director, Manager, Employee and agent
Scope shall be required to produce an annual certificate of compliance with the NLNG ABC Policy
· It is NLNG's policy to comply with all Nigerian laws, rules and regulations governing anti bribery and and Manual.
corruption. As a global company, NLNG and its employees and officers are also bound by the anti-
corruption laws of countries where we do business. Communication
· This Policy applies to directors, employees, subsidiaries, agents, intermediaries, consultants, joint venture · NLNG will ensure effective internal and external communication of the ABC Policy
or other business partners and any other persons, organisations or bodies doing business with NLNG or
any of its subsidiaries and employees. Documentation & Record Keeping
· NLNG's books and records must be kept with reasonable detail and accuracy so that they fairly
Bribery and correctly reflect all transactions in accordance with established procedures and be
· The direct or indirect offer, payment, soliciting, authorisation or acceptance of bribes in any form (including subjected to audit.
favours) is not allowed. No bribes of any sort may be solicited from, paid to or accepted from customers, · All controls and approval procedures must be followed.
suppliers, agents, consultants, intermediaries, joint ventures or other business partners, stakeholders, · NLNG books and records must not contain any false, misleading or other artificial entries.
politicians, and/or government officials.
· It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or Internal Control & Assurance
influencing transactions or decisions. · NLNG shall maintain an effective system of internal controls to counter bribery and corruption
· NLNG will promote its policy on bribery and corruption amongst its directors, employees, business and subject these controls to regular reviews and audits to provide assurance on their design
partners, stakeholders, contractors, vendors and suppliers. implementation and effectiveness.

Facilitation Payments Monitoring & Review

· Recognizing that facilitation payments are bribes, NLNG expressly prohibits such payments. Thus, · NLNG shall establish feedback mechanisms and other internal processes supporting the
directors, officers, employees, agents, customers, contractors, suppliers, vendors, joint venture or other continuous improvement of the Anti-Bribery and Corruption programme.
business partners and stakeholders are not allowed to solicit, make or receive facilitation payments on · Management shall undertake periodic reviews of the ABC compliance programme and
behalf of NLNG. They are also not allowed to solicit, make or receive such payments for themselves or any measures, designed to evaluate and improve their effectiveness in preventing and detecting
other person whomsoever in the course of NLNG business. bribery and corruption, taking into account relevant developments in the field and evolving
international and industry standards. Such reviews may be undertaken internally or by an
Gifts, Hospitality & Expenses independent third party.
· NLNG prohibits the solicitation, offer or receipt of gifts and hospitality whenever they could affect or be · Management will report the results of the programme reviews to the Business Risk Assurance
perceived to affect the outcome of business transactions or decisions and are not reasonable and bonafide Committee, Corporate Audit Committee and the Board.
or consistent with the NLNG Statement of Business Principles, Code of Conduct and the Anti-Bribery and · The Governance, Risk and Compliance Department shall prepare and present an annual
Corruption (ABC) Manual. report on ABC compliance program to the Business Risk Assurance Committee, Corporate
· Seasonal Gifts shall be NLNG branded corporate items of nominal value (no hampers or live animals). Audit Committee and the Board.
· Gifts and Hospitality must be disclosed, declared and recorded fairly and accurately in NLNG's books and
records. Raising concerns & seeking guidance
· No expenditure of gifts, travel, lodging or entertainment for any Government Official or business partner or · NLNG will provide secure and accessible channels through which directors, officers,
third party may be for the purpose of influencing any official action or to procure any improper advantage. employees, subsidiaries, agents, consultants, suppliers, contractors, joint ventures partners or
other business partners should feel able to raise concerns and report violations in confidence
Donations & Sponsorships and without risk of reprisal.
· Charitable donations and sponsorships must not be used as a subterfuge for bribery and must be · These or other channels should be available for employees and other stakeholders to seek
consistent with NLNG Business Principles and Code of Conduct. advice on the application of the ABC programme.
· Charitable donations and sponsorships shall not be provided to any organization upon the suggestion or
request of a public (government) official or for the purpose of influencing a public official. Responsibilities
· NLNG shall not make payments and/or donations to political parties, organizations or their · It is the responsibility of the Board to demonstrate visible commitment to this policy and the
representatives. ABC programme based on the NLNG Business Principles and provides leadership, resources
and active support for management's implementation of the programme.
Agents & Intermediaries · The MD/CEO is responsible for ensuring that the ABC Policy and programme is implemented
· When retaining, paying or working with an agent or intermediary, it is mandatory to: consistently across the Company.
· Undertake properly documented due diligence. · It is the responsibility of management to lead by example, to ensure that all employees are
· Have a solid, documented basis for trusting the intermediary. aware of the ABC policy and programme, and behave in accordance with the spirit as well as
· Take reasonable steps to monitor for and prevent misconduct the letter of the Policy.
· Ensure compliance with the NLNG ABC Policy & Manual · Management is responsible for establishing effective measures for providing guidance and
advice to directors, officers, employees and business partners on compliance with the ABC
Contractors & Suppliers programme and measures.
NLNG shall: · It is the responsibility of employees of NLNG and those who work for and with NLNG to adhere
· Conduct its contract and procurement practices in a fair and transparent manner. to the requirements of this Policy.
· Avoid dealing with contractors and suppliers known or reasonably suspected to be paying bribes. · Compliance with the ABC Policy is mandatory for directors, employees and all who work for or
· Undertake due diligence in evaluating prospective contractors and suppliers to ensure that they have conduct business with NLNG.
effective anti-bribery & corruption programmes. · Every director, officer, employee or business partner of NLNG is required to report to NLNG
· Make known its ABC Policy and Business Principles to contractors, agents, intermediaries, suppliers, joint violation of the ABC Policy.
venture partners and other business partners and expect compliance from them.
· Ensure compliance with the NLNG ABC Policy & Manual. Sanctions
· Take reasonable steps to monitor for and prevent misconduct. · Breach of the provision of the ABC Policy and Manual constitutes serious misconduct and will be
subject to appropriate disciplinary measures including, but not limited to, termination of
Fraud employment or appointment of the affected officer or employee.
· Fraud is described as the willful or dishonest misuse of NLNG resources, including intentional, · Breach of the ABC Policy and Manual by agents, contractors, intermediaries, suppliers, vendors,
false representation or concealment of a material fact for the purpose of inducing another to act upon it. It consultants, joint venture or other business partners may lead to the termination of such
also includes acts of dishonesty, deception, or of omission, the Improper use of influence or position and/or business relationships.
the improper use of information. · Breach of the ABC policy or manual may also result in civil or criminal proceedings against
defaulters.

Tony Attah
Managing Director / Chief Executive Officer
September 2016