CONTENTS. 1 Message from the Managing Director. 2 The Code of Conduct. 4 Our Vision. 5 Our Values. 6 Our Behaviours

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1 Our Code of CONDUCT

2 CONTENTS 1 Message from the Managing Director 2 The Code of Conduct 4 Our Vision 5 Our Values 6 Our Behaviours 7 The Principles of our Code of Conduct 10 Principle: We act in an ethical manner and operate safely and with integrity 26 Principle: We treat all people with respect 30 Principle: We communicate consistently and respect Confidentiality, Privacy and Property 37 Principle: We procure and engage with Suppliers responsibly 38 Monitoring the Code 39 How to speak up 41 Glossary

3 MESSAGE FROM the Managing Director At Oil Search we are committed to delivering growth for shareholders while developing our employees and partnering with our host communities. We take pride in our reputation for enhancing shareholder value in a socially responsible way. As an employee or partner in the Oil Search business, you belong to an organisation with strong values that underpin the way we work and that guide us in securing a successful, sustainable future. The Oil Search Code of Conduct contains the Company s expectations of everyone who is conducting work for Oil Search. A workplace moral compass, it is a vitally important document, and adhering to it helps protect our reputation, makes our Company a better place to work and contributes to our ongoing success. The Code is based on principles that guide the way we work as outlined in our Company s Vision, our Values, our Behaviours and our Board approved Policies. Oil Search believes that as our Company grows, so do our responsibilities. We strive to provide employees with an enjoyable, safe, and productive work environment; to be a trusted partner of choice; and to ensure we retain our social license with stakeholders. By following the Code of Conduct you are playing an important role in achieving all of this. I encourage you to read this document carefully and refer to it regularly. It should guide your daily decisions, your actions and your treatment of stakeholders and colleagues. Peter Botten Managing Director 1

4 The CODE OF CONDUCT The Oil Search Code of Conduct (the Code ) is a statement of our required standards of behaviour and our expectations for all interactions with others, for the decisions we make and the way in which we carry out our responsibilities at work. The Code draws from and reinforces Oil Search s Management System Our Way - which details the mandatory Policies, Standard and Procedures at Oil Search. The Code defines the commitment that each of us makes when engaging in Oil Search business, to act in an ethical and responsible manner. To this end, the Oil Search Board and senior management aim to promote a culture of fair and ethical behaviour by endorsing and enforcing the Code. 2

5 Who must follow the Code? The Code applies to all Directors, employees, contractors, consultants, agents, advisors and representatives engaged by Oil Search Limited and its related companies. Our non-operated joint venture partners and suppliers are expected to adopt similar standards, principles and policies. We can also use the Code to guide us if we are uncomfortable with the behaviour of others, or if we are unsure whether or not behaviour is appropriate, and whether or not we should take further action. You are expected to attend and participate in awareness and training sessions of the Code. All of your Oil Search responsibilities and business activities must be conducted in accordance with the Code. The Code does not describe every law, regulation or minimum performance requirement that may apply to you. Make sure you know the rules that do apply to you, and comply with them. Review the Our Way Policies, Standard and Procedures relevant to your work and, if in doubt, talk to your supervisor or manager. 3

6 OUR Vision To generate top quartile returns for shareholders through excellence in socially responsible oil and gas exploration and production 4

7 OUR Values Integrity Respect Caring Passion Responsible Diversity Excellence 5

8 OUR Behaviours Our goal is to foster a culture at Oil Search where everyone is: ACCOUNTABLE Taking ownership and holding yourself and others to account for delivery of actions and outcomes. CULTURALLY AWARE Be approachable, aware and sensitive to cultural differences; adapts to people and environments. FORWARD THINKING Analyse and integrate information to determine the best course of action; prioritise and plan. RESOURCEFUL Identify and act on opportunities to improve the business and deliver results. WORKING TOGETHER Work cooperatively; build relationships with others to achieve goals. LEADING OTHERS Inspire and develop people to perform effectively and reach their potential. 6

9 The principles of our CODE OF CONDUCT The Code should be read in conjunction with Our Way, and together, they should be used to govern the way we work. Our Way defines our vision, values, company culture and the behaviours expected of all Oil Search personnel. The Code reinforces Oil Search s Management System Our Way, which details the mandatory Policies, Standard and Procedures at Oil Search and reinforces principles to: Act in an ethical manner and operate with integrity Treat all people with respect Actively manage communications and respect confidentiality, privacy and property Procure and engage with suppliers responsibly 7

10 The Company has a number of Board-approved Policies which define how the principles of The Code will be applied: CODE OF CONDUCT The Code of Conduct applies to all directors, employees, contractors, consultants, agents, advisors and representatives engaged by Oil Search Limited and its related companies. We must all conduct the business of Oil Search in accordance with this Code. DIVERSITY AND INCLUSION The Diversity and Inclusion Policy details the Company s commitment to promoting diversity across the Company, in recognition that an engaged and diverse workforce will contribute to improved operating performance and achievement of strategic objectives. CORRUPTION PREVENTION The Corruption Prevention Policy details the Company s aim to conduct business ethically at all times as well as adopting and advocating for principles, practices and standards which contribute toward combating corruption. DRUG AND ALCOHOL The Drug and Alcohol Policy details the Company s commitment to protecting the health and safety of all individuals affected by its activities. The Company recognises that the use of illicit drugs, alcohol and medication can potentially have an adverse effect on job performance, the work environment and the safety and health of the workplace. 8

11 HEALTH, SAFETY, ENVIRONMENT AND SECURITY The Health, Safety, Environment and Security Policy details the Company s commitment to achieving incident free operations through the provision of effective Health, Safety, Environmental and Security (HSES) Management across all of its operations and worksites that benefit employees, contractors and the community. SHARE TRADING The Share Trading Policy details the Company s commitment, to fair, open and transparent trading in the Company s securities by directors, employees and related parties and the procedures implemented to support that commitment. PUBLIC DISCLOSURE The Public Disclosure Policy details the Company s commitment to ensuring that its external communications activities are a key mechanism for building trust and engagement between the Company and its stakeholders, by promoting the principles of good corporate governance in its communications with shareholders and other stakeholders. SOCIAL RESPONSIBILITY The Social Responsibility Policy details the Company s commitment to social responsibility and stems from a culture that strives for the highest ethical, social and moral values and a desire to contribute positively and creatively to the growth and development of communities in which we operate. 9

12 Principle: We act in an ethical manner and operate safely and with integrity Oil Search s vision includes a commitment to excellence in socially responsible oil and gas exploration and production. This means you are expected to conduct Oil Search s operations in keeping with the highest legal and ethical standards by complying with all laws, regulations and obligations. In some locations where these may be inadequate or do not exist, we adopt and apply standards that are in alignment with the intent of this Code and Our Way as well as internationally accepted norms of behaviour. It means you must perform your duties, make decisions and engage in activities in a manner that will uphold Oil Search s Values and standing as a good corporate citizen, complying with the Social Responsibility Policy and Procedure. It also means you are expected to operate with integrity at all times, adopting and advocating principles, practices and standards that respect diversity, local culture, human rights, labour rights, women s empowerment and the environment, and which contribute towards combatting corruption. Policies and Procedures to be aware of: HSES Policy and Procedure Social Responsibility Policy and Procedure Corruption Prevention Policy and Procedure Share Trading Policy and Procedure Community Partnerships and Sponsorships Procedure Human Resources Procedure 10

13 11

14 Our Way is to: Identify, assess and take steps to minimise environmental impacts associated with your work Report evidence of any human rights breaches to your line manager, human resources and/or the senior security or community affairs manager on site Investigate human rights concerns and complaints and report outcomes to relevant stakeholders Our Way is NOT to: Employ public or private agencies to provide security to an Oil Search site without first confirming their compliance with the requirements and intent of the Voluntary Principles and Human Rights. 12

15 Principle: We act in an ethical manner and operate safely and with integrity (Continued) SOCIAL IMPACT Our relationships with stakeholders whether government, communities, partners, NGO s or investors are vitally important to the success of our business. We monitor their needs and expectations and we respond with this Code in mind. We plan and manage our activities so that they are carried out in a manner which is sensitive to the culture and expectations of the people they may affect and to ensure minimum environmental impact. We uphold the principles of the UN Global Compact and the Voluntary Principles for Security & Human Rights, including the Universal Declaration of Human Rights and related international laws. You must comply with our policies and procedures on Social Responsibility, Health, Safety, Environment & Security (HSES), Stakeholder Engagement and Social Impact Management, which reflect this commitment. 13

16 Principle: We act in an ethical manner and operate safely and with integrity (Continued) HEALTH, SAFETY, ENVIRONMENT & SECURITY We are committed to achieving a safe workplace, with incident free operations, through the provision of effective HSES management systems across all of our operations and work sites. You must comply with the HSES Policy and promote a culture under which your actions and those of your colleagues are consistent with Oil Search s commitments under this policy. In particular, you must report HSES incidents and minimise any risks to your own safety and/or the safety of your colleagues or the community. Oil Search has a set of 10 Life Saving Rules that recognise high risk activities specific to Oil Search operations. The 10 Life Saving Rules must be followed by all Oil Search employees and contractors conducting work at any Oil Search location. 14

17 Our Way is to: Report to work fit and ready to carry out your assigned works Use personal protective equipment appropriate to the task you are performing Immediately stop a job if it appears unsafe Make sure you know what to do in the case of an emergency and ensure that visitors are familiar with emergency procedures Our Way is NOT to: Undertake work unless you are trained, competent, fit and sufficiently rested and alert to do so Bring weapons onto Oil Search premises, unless specifically and lawfully authorised to do so 15

18 Our Way is to: Excuse yourself from a situation where a potential conflict of interest may arise and/or where we may not be able to be objective 16

19 Principle: We act in an ethical manner and operate safely and with integrity (Continued) FRAUD Oil Search does not tolerate fraud. Oil Search will take disciplinary action against you for fraudulent behaviour and may report the matter to the authorities. CONFLICT OF INTEREST You must not use your position for personal gain or to inappropriately benefit any business or person other than Oil Search. You must avoid entering into any situation in which an actual or apparent conflict of interest may arise. You must consult with your Line Manager if you know or think you have a conflict of interest. Line Managers must determine whether a conflict of interest exists and if so, report the conflict of interest to the Compliance Manager using the Conflict of Interest Form. If unsure, the Compliance Manager must escalate to the responsible EGM to resolve. You must obtain prior written approval from your line EGM (or Managing Director in the case of EGMs) before: acquiring an interest in a competitor, supplier or customer of Oil Search (other than interests held in publicly listed companies); or hiring or supervising a relative, regardless of whether that person is an Oil Search employee or employed by an Oil Search contractor. 17

20 Principle: We act in an ethical manner and operate safely and with integrity (Continued) DIRECTORSHIPS You must not consent to be a director of a company which is a customer of, or supplier to Oil Search, or which is or may become a competitor of Oil Search, without the prior written consent of the Managing Director. You must obtain prior written approval from your line EGM (or Managing Director in the case of EGMs) before accepting a position as a board member (including not-for-profit organisations). OUTSIDE EMPLOYMENT Employees must not pursue any forms of employment or outside interest where a conflict of interest with your obligations to Oil Search may arise, without obtaining prior management approval. Further information can be found in the Human Resources Procedure. 18

21 Our Way is NOT to: Accept outside engagements or employment that conflicts with role at Oil Search 19

22 Our Way is to: Act honestly and transparently with all stakeholders Consider potential corruption risks when dealing with government officials Our Way is NOT to: Tolerate any corruption, fraud, theft or unauthorised use of the Oil Search s property Pay bribes 20

23 Principle: We act in an ethical manner and operate safely and with integrity (Continued) GIFTS AND ENTERTAINMENT You must not give, seek or accept, in connection with Oil Search activities, any gift, entertainment or other personal favour or assistance which goes beyond common courtesies associated with general commercial practice. The Corruption Prevention Procedure requires preapproval and reporting of certain gifts and entertainment to ensure that the offer or acceptance of a gift or entertainment does not create an obligation or be construed or used by others to allege favouritism, discrimination, collusion or similarly unacceptable practices by Oil Search. BRIBERY AND CORRUPTION Bribery of government officials is a crime. You must not authorise, offer, give or promise any benefit directly or indirectly to a Government Official or other parties to induce them to perform their work duties disloyally or otherwise improperly to gain an advantage for Oil Search. This prohibition extends to payments made in any form, either directly, or indirectly through agents, representatives, consultants or other intermediaries. Laws in Papua New Guinea, Australia and elsewhere make it a criminal offence to bribe a foreign public official and some laws extend to citizens, residents and companies who commit offences overseas. Oil Search has made commitments to comply with applicable international anti-corruption laws, including the US Foreign Corrupt Practices Act (FCPA). 21

24 Principle: We act in an ethical manner and operate safely and with integrity (Continued) FACILITATION PAYMENTS Facilitation Payments are prohibited by Oil Search in line with the anticorruption laws of most countries. Requests for Facilitation Payments must be reported to your supervisor or manager and Legal or Compliance immediately. The health and safety of our employees is our highest priority. If a payment has to be made as a result of a direct or associated imminent threat to the health or safety of any Oil Search employee, contractor or officer, or any accompanying person, it must be reported to your supervisor or manager and Legal or Compliance immediately. SHARE TRADING You must not deal in Oil Search securities while in possession of price sensitive information that is not generally available ( inside information ) about Oil Search s business. Further, you must not deal in the securities of other companies when you have inside information about those companies through your role with Oil Search. Consult the Share Trading Policy and Procedure for direction on what conduct is prohibited and what is permitted when dealing in securities; in particular the trading prohibition during a closed period and the trading restrictions that apply to prescribed and restricted employees. INTEGRITY OF FINANCIAL REPORTING Employees must not undertake any actions that could result in Oil Search s accounting records failing to accurately and fairly reflect, in reasonable detail, the underlying transactions and all Oil Search s assets and liabilities. Accounting records must be maintained in accordance with Generally Accepted Accounting Principles and the financial and accounting policies adopted by Oil Search. 22

25 Our Way is to: Keep accurate, complete and true Company books, records, accounts and reports in accordance with applicable laws, regulations and procedures Our Way is NOT to: Misuse your position, privilege, status or any information or knowledge that you have obtained as a result of these for your own gain or the gain of close personal associates or family members 23

26 Our Way is NOT to: Collude with competitors such as by fixing, raising or lowering price of goods sold or purchased; limiting production or agreeing to reduce or limit production capacity; or boycotting the use of a customer or supplier 24

27 Principle: We act in an ethical manner and operate safely and with integrity (Continued) COMPETITION LAW You must comply with all applicable competition laws. Depending on the situation, the Independent Consumer and Competition Commission Act 2002 (PNG), the Competition and Consumer Act 2010 (Australia) or the laws of other jurisdictions could apply to business activities, depending on which market is affected by the action or agreement in question. Competition law is mainly applicable when Oil Search is selling products or acquiring goods and services. In particular, arrangements with competitor companies require review by the Legal Department. POLITICAL CONTRIBUTIONS, SPONSORSHIPS AND ACTIVITIES Oil Search does not make cash or in-kind contributions to any government official, political party, political party official, election committee or political candidate. Oil Search is committed to making a positive social impact and improving the health, wellbeing, training and education outcomes within the communities in which it operates. Our community partnerships and sponsorships are aligned to our values and based on a clear mutual understanding of the purpose and ultimate objectives of both parties. We ensure that all partnerships and sponsorships are transparent and documented in advance in accordance with the Community Partnerships and Sponsorships Procedure. 25

28 Principle: We treat all people with respect RESPECT FOR COLLEAGUES In the course of undertaking Oil Search business, you must treat all people with respect. Harassment, discrimination, bullying and violence are not acceptable in our workplace. Oil Search values diversity. We employ people who are different from each other in many ways. We aspire to recognise and benefit from the differences in experience and perspective that our employees bring to the business. We believe all employees should be treated with respect, fairly and in a reasonable way. Oil Search therefore is committed to ensuring that all complaints relating to harassment, discrimination, bullying and workplace violence are: Treated seriously; Attended to promptly and confidentially; and Investigated impartially and thoroughly. Policies and Procedures to be aware of: Human Resources Procedure Drug and Alcohol Policy and Procedure 26

29 Our Way is to: Be respectful and work cooperatively Inspire and develop people to reach their potential Be sensitive to cultural differences Build relationships to achieve Company goals Understand the value of diversity Our Way is NOT to: Make assumptions on someone s capability because of their gender or background. Discriminate in any way based on race, colour, religion, age, gender, sexual orientation, gender identity, marital status, disability, ethnic origin or nationality. Use or tolerate threats, intimidation, harassment, bullying or violence at work Promote material or jokes that others may find offensive Ask someone to take action against the Code of Conduct or not speak up about a breach 27

30 Our Way is NOT to: Take illicit drugs, alcohol or betel nut on Oil Search premises or while performing duties for Oil Search Smoke at an Oil Search site or office, except as permitted in a designated smoking area. 28

31 Principle: We treat all people with respect (Continued) DRUGS AND ALCOHOL The Company recognises that the use of illicit drugs, alcohol, betel nut, tobacco and medication can potentially have an adverse effect on job performance, the work environment and safety and health in the workplace. The use of illicit drugs, the unauthorised use of alcohol, betel nut and tobacco and the misuse of medication is prohibited on Oil Search premises, work sites and while driving a Company vehicle. Details are provided in the Drug and Alcohol Policy and Procedure, which you must comply with. Disciplinary action up to and including termination will be taken for breach of the Drug and Alcohol Policy. 29

32 Principle: We communicate consistently and respect Confidentiality, Privacy and Property EXTERNAL COMMUNICATIONS You must not make any direct or indirect statement or comment to media, nor place posts about the company or its activities on social media unless you have the proper authority to do so. You must not make any public comment on behalf of Oil Search without authority. Details of those who are authorised to respond to the media or analysts and to issue media statements are contained in the Public Disclosure Policy and Procedure. Policies and Procedures to be aware of: Acceptable use of ICT Procedure Public Disclosure Policy and Procedure 30

33 Our Way is to: Forward media and investment inquiries promptly to the Investor Relations and Communications function Our Way is NOT to: Post Company-related information on social media without prior authorisation Deliberately access, store, send, post or publish inappropriate material, or ignore others who do so 31

34 Our Way is to: Only collect, use, disclose and retain personal information that is necessary for legitimate reasons Our Way is NOT to: Share the Company s confidential information or another person s personal information 32

35 Principle: We communicate consistently and respect Confidentiality, Privacy and Property (Continued) CONFIDENTIALITY & PRIVACY You may, due to your work responsibilities, have access to private, confidential or sensitive information about individuals (including private communications, medical records, financial information and payroll and personal information) or Oil Search s business activities (including business affairs, transactions, accounts, operations, work investigations, discoveries, reserves, products, designs, processes, financing, management, trade secrets, technical system design or research data). Accessing, using or disclosing that information for any reason other than the legitimate pursuit of Oil Search duties constitutes misuse of the information. Any misuse or unauthorised release of information, either during your time with Oil Search or subsequently, may be grounds for disciplinary and/or legal action against you. You must comply with relevant legislation regarding the use of personal information in order to protect the privacy of individuals. If you are unsure of your legal obligations, consult Oil Search Legal. 33

36 Principle: We communicate consistently and respect Confidentiality, Privacy and Property (Continued) COMPANY PROPERTY You must take all prudent steps to ensure the protection of Oil Search property. You must minimise the possibility of theft of Oil Search property including laptop computers and mobile devices and use reasonable measures to protect Company information on laptops and other mobile devices. You must also comply with the Company s Acceptable Use of ICT Procedure. Among other things, the Procedure prohibits the use of the Oil Search network to access or store pornographic or other offensive material. Use of the network to access gambling sites is also prohibited. INFORMATION DISCLOSURE You must not disclose confidential Oil Search data or information to any third party without prior senior management approval and without the third party agreeing in writing to suitable confidentiality restrictions in respect of the information. The Public Disclosure Policy and Procedure provides more detail on these restrictions and outlines Oil Search s continuous disclosure obligations as a listed entity. You must not use Oil Search information, directly or indirectly, for the purpose of personal gain. 34

37 Our Way is to: Prevent unauthorised access to Oil Search information, particularly materially sensitive data Protect Company assets, including mobile phones and computers, from theft and damage Our Way is NOT to: Share your network password with anyone Leave information technology or mobile devices unattended in public places Use Company assets for personal gain 35

38 Our Way is to: Inform external parties of their responsibilities under the Code of Conduct Act honestly and transparently with all stakeholders Verify that invoices clearly and fairly represent the goods and services provided Help suppliers understand Oil Search s compliance and business conduct requirements Keep accurate books and record of transactions Consult Legal if a breach of contract is suspected Expect suppliers and contractors to meet Company standards and the Code of Conduct Undertake due diligence on our partners and contractors to assess their alignment with human rights Our Way is NOT to: Pay or accept bribes or inducements to or from Oil Search s suppliers or contractors Use suppliers who provide unsafe or environmentally irresponsible products or services, breach laws or regulations, or use child or forced labour 36

39 Principle: We procure and engage with Suppliers responsibly All contractors, suppliers and business partners providing products or services to Oil Search must be selected, engaged and managed on the basis that they are expected to follow policies and procedures that are consistent with Oil Search s Values and Policies; including our Corruption Prevention Policy and Procedure and Social Responsibility Policy and Procedure. You must not: pay bribes or inducements to or accept bribes or inducements from Oil Search s suppliers or contractors; or offer gifts, hospitality or entertainment to or accept them from an organisation or individual involved in a bid or tender with Oil Search. The business conduct and performance of our suppliers can have a direct impact on the sustainability of our business. You should ensure our suppliers are given and understand the Code. Where we have assessed a supplier to either provide or be involved in higher risk business activities, we require that they will: ensure that the Code is communicated to all their sub-contractors, in the local language and in a manner that can be understood; hold their sub-contractors to the supplier expectations contained in the Code; and work with their own suppliers to ensure their supply chain meets the principles of the Code. Policies and Procedures to be aware of: Corruption Prevention Policy and Procedure Social Responsibility Policy and Procedure 37

40 MONITORING the Code The Company has an Integrity Committee, comprising the Managing Director, Executive General Managers and selected senior managers. The Integrity Committee will report to the Board and its Committees on material breaches of the Code and corrective action taken. The Assurance and Compliance Function also provides monitoring and testing of controls to ensure compliance with policies, procedures and legislative and regulatory requirements. 38

41 How to speak up SUSPECTED BREACHES OF THE CODE You must report all suspected breaches of the Code. OIL SEARCH HOTLINE By reporting misconduct or non-compliance with the Code you can help ensure our people enjoy their work and are safe and secure in our workplace, the impact on communities and the environment is minimised, as well as help us to maintain our reputation in the eyes of stakeholders. You must report activity that you suspect conflicts with the Code such as: Theft Fraud Dishonesty Harassment Workplace safety & environmental hazards Human rights abuses Unethical or improper behaviour Corruption Misconduct If you do not feel comfortable making a report to your supervisor, HR, Legal or Compliance, you can make an anonymous written report to call the appropriate number below: AU: PNG: UAE: or visit 39

42 How to speak up (Continued) DISCIPLINARY ACTION Depending on the severity of the breach, appropriate disciplinary or corrective action will be determined in consultation with HR, Legal and/or Compliance. Disciplinary outcomes may include formal warnings, suspensions or termination of employment or contract. Breaches of applicable laws may also result in prosecution by the appropriate authorities. In addition to leading by example, supervisors and managers are responsible for taking, or recommending appropriate action to address business conduct issues. Oil Search does not tolerate retaliation, payback or detriment where a genuine concern has been raised or a possible contravention of the Code is reported in good faith. Retaliation is grounds for discipline, including dismissal. If you have been retaliated against for raising a concern, you should report it immediately to your supervisor, HR, Legal or Compliance. 40

43 GLOSSARY Bullying Workplace bullying means a repeated, unreasonable pattern of behaviour directed towards a staff member or group of staff members by another person or group of people, which may be considered to be unreasonable or inappropriate workplace behaviour, or which may create a risk to health and safety. Bullying does not include reasonable management action carried out in a reasonable manner. Business Partner means: Joint venture partners or co-investors. Third parties that interact with others on behalf of Oil Search or any Oil Search owned or controlled entities, such as agents, brokers, intermediaries, advisors, consultants, representatives, travel agents, freight forwarders, customs or visa agents, tax advisors, law firms, finders, lobbyists and accountants. A vendor that is known or believed to be owned in whole or in part by a Government Official or close relative of a Government Official. A vendor that is recommended, suggested or mandated by a Government Official. Discrimination Unlawful Discrimination means when someone, or a group of people, is treated less favourably, intentionally or unintentionally, than another person or group because of their race, colour, national or ethnic origin; sex, pregnancy or marital status; age; disability; religion; sexual preference; trade union activity; or some other characteristic specified under applicable anti-discrimination or human rights legislation Facilitation Payment means a payment made to secure or expedite the performance of a routine or ordinary action to which the payer of the facilitation payment has legal or other entitlement. Typical examples would be providing nominal payments to custom agents for issuing minor licenses or permits, or clearing goods through customs. Government Official means any officer or employee of any level of government or any ministry, body, department, agency, state-owned or state controlled companies, statutory corporations or public international organisation, any person acting in an official capacity for or on behalf of any government or government entity, or of a public international organisation, any political party or party official. Harassment means any unwelcome, unsolicited, offensive, abusive, belittling or threatening behaviour directed at an individual or group because of some real or perceived attribute such as a person s sex, sexuality, ethnicity or disability in circumstances which a reasonable person, having regard to all the circumstances, would have anticipated that the person harassed would be offended, humiliated or intimidated. Retaliation means to do something in response to an action done to oneself or an associate, especially to attack or injure someone as a response to a hurtful action. Workplace Violence means an incident where a person is abused, threatened or assaulted in circumstances related to their work, involving an explicit or implicit challenge to their safety, well-being and health. 41

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