Attock Petroleum Limited (“APL” or the “Company”) is a law-abiding company and is dedicated to conduct its operations within legal boundaries and ethical standards, ensuring its employees and directors have a clear code of conduct.

The code aims to provide a clear direction to employees and directors, outlining acceptable and unacceptable practices. This framework is designed to cultivate a culture underpinned by integrity, honesty, transparency and accountability, which all directors and employees are required to uphold.

1. Compliance with Laws, Rules and Regulations

The Company is resolutely dedicated to adhere and undertake all reasonable measures to comply, with the applicable laws, rules, and regulations. Consequently, every director and employee bears the responsibility of ensuring unwavering compliance with this code, as well as, the applicable laws, rules and regulations.

2. Role towards Shareholders / Members and other Stakeholders

APL prioritizes an ethos of transparent and open communication with its diverse range of stakeholders, encompassing employees, customers, shareholders, communities, and regulatory bodies. A fundamental expectation from our employees and directors is the proactive solicitation of feedback, engagement, and expectations from stakeholders, facilitating continuous growth.

Informed judgments, aimed at optimizing shareholder value, constitute a core imperative. All employees and directors are enjoined to uphold and safeguard the rights of shareholders/members, entailing unhindered access to pertinent information and equitable treatment.

The mandate further extends to the promotion of the Company’s enduring sustainability, thereby harmonizing the interests of present and prospective shareholders/members. A conscientious commitment to principled and sustainable business practices, in harmony with the Company’s objectives, is incumbent.

Regular evaluations and appraisals of the Company’s policies, practices, and performance concerning stakeholders are to be diligently carried out. The dedication to continuous advancement and inventive thinking is a focal point, directed towards the more effective fulfillment of stakeholder aspirations and anticipations.

3. Diversity, Equity & Inclusion

APL recognizes, values and encourages merit, diversity, equity and inclusion. All employees and directors are expected to promote a culture of respect and inclusion where all individuals are valued and treated with dignity, regardless of their race, gender, religion, age, disability, or any other characteristic protected by law. APL believes in providing equal opportunity to everyone, including its customers and suppliers, and strictly prohibits any form of harassment or discrimination, and requires all directors and employees to uphold these standards without exception.

In addition, equal opportunities must be ensured to all employees in recruitment, hiring, promotions, training, and other employment practices, and decisions should be based on merit, qualifications, and performance.

4. Environmental, Social & Corporate Governance

APL advocates and is committed to strengthen environmental, social and corporate governance areas in accordance with the best practices. APL exemplifies resolute commitment to corporate social responsibility to positively impact society through initiatives that prioritize ethical conduct, environmental conservation and community development, aligning our actions with legal and ethical standards.

Each employee and director is entrusted with the responsibility of embracing and enacting measures that promote sustainability and contribute to the preservation of natural environment.

5. Promoting Safe and Healthy Environment

The Company uses its best endeavors to provide each director and employee with a safe and healthy work environment and ensures to comply with all applicable health and safety laws. We uphold a zero-tolerance policy towards violence or threatening behavior, fostering an atmosphere of respect and productivity.

APL is dedicated to cultivating a workplace free from harassment or intimidation, fostering open discussions, and valuing honest opinions without any fear of retaliation. Employees and directors jointly share the responsibility of maintaining this commitment to a safe and respectful workplace.

6. Full and Fair Disclosure

Directors and employees are expected to help the Company in making full, fair, accurate, timely, and understandable disclosure, in compliance with all applicable laws and regulations, in all reports and documents that the Company files with, furnishes to or otherwise submits to, any governmental authorities in the applicable jurisdiction, and in all other public communications made by the Company. Employees or directors who have complaints or concerns regarding accounting, financial reporting, internal accounting control or auditing matters are expected to report such complaints or concerns.

7. Conduct in Business Dealing

The Company is committed to conduct its business activities in an ethical manner, ensuring that all competitive practices are honest and transparent. Each director and employee is expected to deal fairly with the Company’s customers, suppliers, employees and other stakeholders. No one should take unfair advantage of anyone through manipulation, abuse of privileged information, or any other unfair practice. Any form of deception, fraud, or unfair competition must be avoided at all levels.

Directors and employees will not accept gifts or favors from existing or potential customers, vendors or anyone doing or seeking to do business with the Company. However, this does not preclude giving or receiving gifts or entertainment which are generally acceptable and usual in the circumstances, provided that no obligation could be, or be perceived to be, expected in connection with the gifts or entertainment.

Furthermore, no improper payments shall be made on behalf of the Company in connection with any of its activities. Any payments made should be justified by a clear and traceable service rendered to the Company. The remuneration of third parties such as agents, distributors, and service providers should conform to normal business practices and rates. All such expenditures must be properly reported and recorded in the Company’s financial records

8. Protection against Harassment at Workplace

APL is fully committed to providing a safe and respectful working environment for all employees. We strictly prohibit any form of harassment, particularly targeting women, in the workplace. Harassment includes, but is not limited to, any unwelcome sexual advance, request for sexual favors, stalking or cyber stalking or other verbal, visual or written communication or physical conduct of a sexual nature or sexually demeaning attitudes, including any gestures or expression conveying derogatory connotation causing interference with work performance or creating an intimidating, hostile or offensive work environment, or the attempt to punish the complainant for refusal to comply to such a request or is made a condition for employment. Any instances of harassment will be promptly and thoroughly inquired, and if the accused is found guilty, penalties will be imposed in accordance with the Company’s Code of Conduct for Protection against Harassment at Workplace and applicable laws. We encourage all employees to report any incidents of harassment without fear of retaliation, and we are dedicated to fostering a culture of respect, equality, and inclusivity for everyone.

9. Prevent Conflict of Interest

Directors and employees, irrespective of their function, grade or standing, must avoid conflict of interest situations between their direct or indirect (including members of immediate family) personal interests and the interest of the Company.

Employees must notify their direct supervisor of any actual or potential conflict of interest situation and obtain a written ruling as to their individual case. In case of directors, such ruling can only be given by the Board in accordance with the Related Party Transaction policy of the Company, and will be disclosed to the shareholders in accordance with the applicable laws.

10. Protection of Privacy and Confidentiality

All directors and employees, both during and after their employment, must respect the exclusivity and trade secrets of the Company, its customers, suppliers and other colleagues and may not disclose any such information unless the individual or APL properly authorizes the release or disclosure.

All the Company’s assets (processes, data, designs, etc.) are considered as certified information of the Company. Any disclosure will be considered as grounds, not only for termination of services/employment, but also for legal action available during or after employment with the Company to recover the damages and losses sustained.

Directors and employees may become aware of information about the Company that has not been made public. The use of such non-public or “inside” information about the Company other than in the normal performance of one’s work, profession or position is unethical and may also be a violation of law.

Directors and employees becoming aware of information which might be price sensitive with respect to the Company’s shares have to make sure that such information is treated strictly confidentially and not disclosed to any colleagues or to third parties.

Potentially price sensitive information pertaining to shares must be brought promptly to the attention of the Management of the Company, who will deliberate on the need for public disclosure and decide on such disclosure. In case of doubt, employees may seek contact with the Legal & Corporate Matter Department.

11. Trading in Company shares

Participation in trading the Company shares by directors and employees is exclusively permissible within the framework outlined by comprehensive guidelines periodically issued by corporate management, in strict alignment with relevant legal stipulations.

The engagement of directors and employees in trading Company shares is a regulated practice that is subject to a meticulous set of guidelines. These guidelines, meticulously crafted and periodically updated, serve as the cornerstone for such trading activities. Spearheaded by corporate management, these guidelines are designed to ensure the utmost adherence to the legal framework governing such transactions.

12. Record Keeping

The Company is committed to compliance with all applicable laws and regulations that require the Company to maintain proper records and accounts which accurately and fairly reflect the Company’s transactions. It is essential that all transactions be recorded and described truthfully, timely and accurately on the Company’s books. No false, artificial or misleading transactions or entries shall be reflected or made in the books or records of the Company for any reason. Records must always be retained or destroyed according to the Company’s record retention policies.

13. Media Relations and Disclosures

To protect commercially sensitive information, financial details released to the media should never exceed the level of detail provided in quarterly and annual reports or official statements issued at the presentation of these figures. As regards topics such as financial performance, acquisitions, divestments, joint ventures and major investments, no information should be released to the press without prior consultation with the senior management. Employees and directors must refrain from making statements that could potentially enable third parties to engage in insider-trading on the stock market.

14. Corporate Opportunities

Directors and employees are expected not to take personal use of opportunities that are discovered through the use of the Company’s property, information or position and are expected not to use Company’s property, information, or position for personal gains in any manner.

15. Personal Conduct

Each employee and director adhere to the highest ethical standards when making decisions and should promote a culture that advocates fairness and justice. Favoritism, bias, or unfair advantage in decision-making and resource allocation must be avoided. All employees and directors must act in a way that contributes positively to society, respect for human rights, and supports community well-being.

16. Integrity and Honesty

Directors and employees are expected to exercise honesty, objectivity, integrity and due diligence in the performance of their duties and responsibilities. They are also directed to perform their work with due professionalism in their all interactions, both within the Company and with external stakeholders. A thorough and comprehensive investigation or examination must be made before decision making.

To maintain ethical standards and integrity, it is essential that employees and directors avoid accepting any undue advantage gained unfairly, improperly, or through unethical means.

17. Strictly Prohibited Activities

APL strictly prohibits all illegal activities on the Company premises or during work-related activities, including without limitation, possession or consumption of illegal substances, theft, corruption, forgery, cybercrime, vandalism, violence and fraud of any kind. Any violations may result in immediate and strict disciplinary action, up to termination from employment and legal prosecution.

18. Safeguarding Company Assets

Each director and employee is expected to be the guardian of the Company’s assets and should ensure its safe and efficient use. All the Company assets should be used for legitimate business purposes only. The use, directly or indirectly, of the Company’s property for political contributions to any organization or to any candidate for public office is strictly prohibited.

19. External Activities and Public Comments

Employees and directors are encouraged to represent themselves professionally and accurately in external activities and public comments. They should clearly state that their opinions are their own and not representative of the Company unless authorized to speak on behalf of the Company.

The employees must refrain from performing any external duties, other than their official responsibilities during office hours. Employees should also be transparent about their affiliations and avoid misleading or deceptive endorsements.

20. Employee Retention

Attracting and retaining top-tier talent is paramount for the Company’s success. APL is committed to diligently offering competitive compensation packages to deserving candidates. Moreover, APL firmly believes in nurturing personnel growth, hence, we prioritize the implementation of regular employee training programs.

21. Use of Internet / Information Technology

As a general rule, all information-technology related resources and facilities are provided to employees only for internal use and/or business-related matters of the Company. Information technology facilities which have been provided to employees should never be used for personal gain or profit, should not be misused during work time, and shall always remain the sole and absolute property of the Company. Disclosure or dissemination of confidential or proprietary information regarding the Company, its products, or its customers outside the official communication structures is strictly prohibited.

22. Compliance with Business Travel Policies

The safety of employees while on a business trip is of vital importance to the Company. The Company encourages the traveler and his/her supervisor to exercise good judgment when determining whether traveling to a high-risk area is necessary and is for the Company’s business purposes.

23. Breach of the Code of Conduct

In the event of any breach of this code of conduct by anyone to whom this code applies, then without prejudice to any other rights and remedies that may be available to APL, APL reserves the right to take strict disciplinary actions against such person, including without limitation, issuance of warning, suspension from employment, withholding of any employment benefit, demotion, termination from employment and the right to recover any direct and indirect loss or damage suffered by APL that has occurred as a result of such breach. Compliance also includes the responsibility to promptly report any apparent violation of the provisions of this code.