# Code of conduct

> This code sets out the standards Yorkwell Petroleum applies to its own conduct and expects from the people and companies it works with.

URL: https://yorkwellpetroleum.com/governance/code-of-conduct/

## Our standards

- **Honesty**: We describe our company, our role and our products accurately. We do not claim assets, volumes or relationships we do not have.
- **Compliance with the law**: We follow the laws that apply to our business, including sanctions, anti-money-laundering and anti-bribery laws.
- **Fair dealing**: We compete fairly and keep to the terms we agree.
- **Confidentiality**: We protect our counterparties' confidential information and use it only for the trade it was given for.

## Bribery and gifts

We do not offer, pay or accept bribes or other improper payments, directly or through agents. As a U.S. company, Yorkwell Petroleum is subject to the [Foreign Corrupt Practices Act](https://www.law.cornell.edu/uscode/text/15/78dd-2). Gifts and hospitality must be modest, infrequent and never linked to a decision.

## Sanctions and money laundering

We do not deal with sanctioned persons or in sanctioned trades. We check counterparties before we trade, as set out in our [compliance policy](https://yorkwellpetroleum.com/governance/compliance-policy/).

## Conflicts of interest

Anyone acting for Yorkwell Petroleum must declare any personal interest in a counterparty or a trade, and step aside from the decision where needed.

## Safety and the environment

Where we arrange storage, transfer or transport, we work with operators who are responsible for the safety and environmental rules of their facilities, and we expect them to keep to those rules.

## What we expect from partners

- Accurate information about who they are and who owns them
- Compliance with the laws that apply to them
- No bribes, facilitation payments or improper inducements
- Prompt notice of anything that could affect whether a trade is lawful

## Raising a concern

Concerns about conduct by or toward Yorkwell Petroleum can be sent to [info@yorkwellpetroleum.com](mailto:info@yorkwellpetroleum.com). We do not penalize anyone for raising a concern in good faith.

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Yorkwell Petroleum · 440 Louisiana St, Ste 900, Houston, TX 77002 · info@yorkwellpetroleum.com · +1 (713) 239-3396