GULF OIL Corporation Limited

CODE OF CONDUCT FOR EXECUTIVES  AND  SENIOR MANAGEMENT PERSONNEL

Members of the Board and the Senior Management, shall

a)      Always act in the best interests of the Company and its stakeholders.

b)      Adopt the highest standards of personal ethics, integrity, confidentiality and discipline in dealing with all matters relating to the Company.

c)      Apply themselves diligently and objectively in discharging their responsibilities and contribute to the conduct of the business and the progress of the Company, and not be associated simultaneously with competing organisations either as a Director or in any managerial or advisory capacity, without the prior approval of the Board.

d)      Always adhere and conform to the various statutory and mandatory regulations/guidelines applicable to the operations of the Company avoiding violations or non-conformities.

e)      Not  derive personal benefit or undue advantages (financial or otherwise) by virtue of their position or relationship with the Company,  and for this purpose

                                I.      shall adopt total transparency in their dealings with the Company

                             II.    shall disclose full details of  any direct or indirect personal interests in    dealings/transactions with the Company.

                           III.   shall not be party to transactions or decisions involving conflict  between their personal interest and the Company’s interest.

f)        Conduct themselves and their activities outside the Company in such manner as not to adversely affect the image or reputation of the Company.

g)      Inform the Company immediately if there is any personal development (relating to his/her business/professional activities) which could be incompatible with the level and stature of his position and responsibility with the Company.

h)      Bring to the attention of the Board, Chairman or the  Managing Director as appropriate, any information or development either within the Company (relating to its employees or other stakeholders) or external, which could impact the Company’s operations, and which in the normal course may not have come to the knowledge of the Board/Chairman or Managing Director.

      i)   The Directors and Senior Management personnel shall not accept lavish gifts or gratuities or any offer, payment, promise to pay, or authorisation to pay any money, or anything of value that could be interpreted to adversely affect business decisions or likely to compromise their personal or professional integrity.