REDACTED -IC Petrojam Investigation - Donations October 2019 final

Page 176 of 215 Petrojam Limited Integrity Commission October 2019 Assessment of the Relationship(s) and/or Association(s) between/among Certain Persons and Entities In accordance with the terms of reference for the Investigation, the Director of Investigation (DI) sought to examine whether there were any issues of conflict of interest, nepotism, cronyism and favoritism in relation to donations to certain companies and institutions and the employment of certain persons to Petrojam Limited. The issue of conflict of interest is highlighted in Clause 3 of Petrojam Limited’s Ethics & Conflict of Interest policy which was made effective October 2003 and updated March 2006, which states, inter alia , as follows: “ CONFLICTS OF INTEREST The policy of Petrojam with respect to conflicts of interest requires that officers and employees avoid any conflict between their own interests and the interests of the Company, in dealing with suppliers, contractors, customers, and all other organizations or individuals doing or seeking to do business with Petrojam . All such individuals or companies should avoid any conflict between their own interests and the interests of Petrojam… While it is not practical to enumerate all situations, which might be in conflict with this policy, the examples given below indicate some of the relationships, which should be avoided. Thus, it is considered to be in conflict with the Company’s interest, or a violation of trust: