(M/D)

6 6th Jan. 2024 (QHSE Mgr.) (Operations Mgr.)

Signature

Rev Date Prepared By Reviewed By Approved By

OVERHAUL ENERGY GENERAL BUSINESS ETHICS / CODE OF

CONDUCT

GENERAL BUSINESS ETHICS /

CODE OF ETHICS
 GENERAL BUSINESS ETHICS/CODE OF CONDUCT
In line with her business ethics and code of conduct, OVERHAUL ENERGY LIMITED maintains
clear understanding, mutual respect, and integrity in all its dealings with its client’s
contractors/subcontractors.

1. Obviously, contracts are awarded purely on merit. OVERHAUL ENERGY LIMITED in its
effort to discourage bribery and conflict of interest developed a policy “Conflict of interest”.
This policy forbids the staff of OVERHAUL ENERGY LIMITED to respond to goodwill
and relationship building gestures that usually follow the award / subletting of contract. Gifts
other than these widely tipped to be of small value must be politely but firmly declined by
our staff. Rather than provide staff with personal gift, charitable donations based on the
corporate relationship between OVERHAUL ENERGY LIMITED and its
contractors/subcontractors could be made. Contractor(s) discovered to be bribing through
their selection will be automatically disqualified.

 Discourage giving and/or receiving bribe,

 Prevent compromise position,
 Eliminate expectations to reciprocate favors,
 Maintain individual and company’s reputation and
 Promote good working relationships.
 2. Secondly, the terms of contract awarded must be followed with strict adherence. The process
from mobilization to delivery of contract must be as stipulated. Also, the HSE rules that go
with contract awarded must never be derailed.

3. Thirdly, on the part of the staff of OVERHAUL ENERGY LIMITED, punctuality and
diligence to work is the slogan. It is the duty of every staff to be a watch dog as well as a
brother’s keeper. This will go a long way in facilitating effective job delivery. The staff in
charge must checkmate the activities of the contractors and ensure that the HSE rules are
fully implemented, in order to save life, and that OVERHAUL ENERGY LIMITED operates
profitably.

4. Finally, contractors/subcontractors are expected to promote behavior consistent with our

code of conduct when conducting activities on our behalf. Contractors/subcontractors should
please ensure that their employees and subcontractors read and understand the code of
conduct and are aware of OVERHAUL ENERGY LIMITED requirements that they comply
with the code when conducting business on behalf of OVERHAUL ENERGY LIMITED.

OVERHAUL ENERGY LIMITED reserve the right to terminate contracts and any other
business ethics and code of conduct.

……………………………………………….
EMMANUEL IHIEKUMERE
Managing Director
 CODE OF CONDUCT DETAILS OF COMPANY’S OFFICE SITE LOCATION AND
FACILITIES

OVERHAUL ENERGY LIMITED has a well expansive land area of about 1390m2 which serves as
our office/ site location with enough facilities sufficient for the successful execution of projects.

Office / Site Location Address: -

Klm-15 Onne/ Refinery Road,
Opp. Amber Resources,
Off Eleme junction,
Port Harcourt, Rivers State,
Nigeria
Below is a list of our Equipment / Facilities.

WELDING MACHINE

EXCAVATTOR
SWAMP BUGGY
250T HDD RIG
CENTRIFUAL PUMP
SUV

4X4 PICKUP
COMPRESSOR
FLAT BED TRUCK
AMBULANCE/MEDIC
FIRE TRUCK
WATER TANKER
TOYOTA HILUX
THRUST BORING MACHINE

5 Ton OVERHEAD CRANE

Each employee and Contractor/subcontractor shall: -

1) Act in accordance with the standards of honesty, integrity and fairness and expect the same in
their relationship with others while maintaining a work and business climate fostering such
standards.
2) Adhere to the OVERHAUL ENERGY LIMITED General Business Ethics, any applicable
code of conduct on dealing with securities and any provisions for the avoidance of conflict of
interest stipulated in applicable terms and conditions of employment.
3) Excuse himself from making any decision about an issue at hand in which a conflict of
interest arises or could arise and, in such event, disclosure in writing the relevant facts and
explain the circumstances that create or could create the conflict of interest to the
Management of OVERHAUL ENERGY LIMITED.
4) Avoid having any financial interest in works or contracts awarded by OVERHAUL
ENERGY LIMITED or a company associated with her, or in supplies effected or services
rendered to or by such a company and where this is unavoidable or immediate family
member have such a financial interest; such interest shall be disclosed in writing as in (3)
above.

5) Not seek or accept from third parties to his own advantage any favor in whatsoever form or
however described in connection with the business of OVERHAUL ENERGY LIMITED or
his duties (except for the acceptance of such gifts of nominal value and working lunches,
dinners, and entertainment of reasonable value, frequency and duration appropriate under the
circumstances, and subject always to the standards of “1” above)
6) Not hold positions or jobs or engage in outside business or other interest that adversely
impact the performance of duties owed to company or interest of the same.
7) Avoid any relationship with a contractor or supplier that could compromise the ability to
transact business on a professional, impartial and comprehensive basis or influence decisions
to be made by OVERHAUL ENERGY LIMITED.
8) Be consistent with the scope of his job responsibilities; ensure full, fair, accurate, timely, and
understandable disclosure in regulatory filings and other public communications made by the
Management.
REPORTING

Each staff and Contractor/Subcontractor shall report any breach thereof in writing to the
Management of OVERHAUL ENERGY LIMITED.

No person reporting in good faith a suspected breach of conflict of interest should be concerned
about retaliation by OVERHAUL ENERGY LIMITED. Any job holder or person involved in
retaliation will be subject to the sanctions referred to below.

ACCOUNTABILITY

Each staff and contractor/subcontractor is held accountable for the compromise with this code with
respect to any issues within his control. Sanctions for breach of this code shall be determined the
Management. Sanctions may include disciplinary actions, removal from office and dismissal as well
as other remedies, all to the extent permitted by law and as appropriate under the circumstances.

MISCELLENOUS AND WAVERS

No wavers of any provision of this code shall be valid unless provided in writing by the
Management.
In this code, word importing masculine shall include the feminine and words importing the same
code shall include the plural or verse versa.

The provision of this code can be reviewed from time to time by the Management.

……………………………………………….
EMMANUEL IHIEKUMERE
Managing Director.