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B

O

URB

ON Su

pp

lier Code of Conduct

P

olic

y

B-POL-01.0028

Version 04. Original date: 22 September 2011. Version date: 18 June 2015. Valid version only on QMS site.

Policy prepared by: Vice President Fleet Management. Approved by: COMEX. Validated by: Quality Director of BOURBON.

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Conflict

s

of intere

s

t

Suppliers are expected to disclose to BOURBON any situation that may appear as a conflict of interest.

BOURBON expects its Suppliers to avoid any relationship, influence, or activity that might impair BOURBON

employees’ ability to make objective and fair decisions. Conflict of interest laws and regulations must be

abided by fully and carefully.

B

u

s

ine

ss

courte

s

ie

s

to

B

O

URB

ON em

p

lo

y

ee

s

Although an employee may not use his/her position within BOURBON to obtain business courtesies, it is

permissible to accept unsolicited meals, refreshments, entertainment, and other business courtesies, on an

occasional basis, provided that courtesies:

x

Foster goodwill and successful business relations;

x

Are not lavish or extravagant under the circumstances;

x

Do not recur on a frequent basis, or reflect a pattern or appearance of a pattern of frequent

acceptance of courtesies, from the same entities or persons.

The employee accepting the courtesies must feel comfortable about discussing the courtesies with his/her

manager or co-worker, or about public disclosure of the courtesies.

HOSPITALITY

RECEIVED

Acceptable

Nature

Amount

Frequency

Invitation to breakfast, lunch

or dinner for networking

purpose or related to

business discussions.

Meals:

150 USD per BOURBON

employee from the same

third party;

Entertainment:

100 USD per BOURBON

employee from the same

third party.

Three times per year from

the

same

third

party

excluding: offshore and

onshore canteen, snacks;

Three times per year from

the same third party.

OFFERED

Acceptable

Invitation to breakfast, lunch

or dinner for networking

purpose or related to

business discussions;

Transportation (taxi, flight,

train, car with designated

driver by BOURBON) and

accommodation (hotel, guest

house) related to site/vessel

visit.

Meals:

150 USD from the same

BOURBON employee to the

same third party;

Entertainment:

100 USD from the same

BOURBON employee to the

same third party.

Three times per year to the

same third party excluding:

offshore canteen, snacks;

Three times per year from

the same third party.

F

O

RB

I

DDE

N

x

Gifts or hospitality granted in a period of bid or tender process, contract renewal;

x

Gifts and/or hospitality for the friends, relatives or family members of the invitee.

Business related dinner or lunch between BOURBON representatives and customers,

accompanied by their partners, is acceptable;

x

Car rental when the business partner or third party is not travelling with any BOURBON

representatives;

x

For purchase and procurement employees, gifts received from third parties are forbidden.

Giving gift

s

BOURBON employees are not permitted to accept compensation, funds or monetary incentives in any form

or amount, or any tangible gift (including tickets to sporting, recreational, or other events) that has a market

value of 100 USD or more, from any entity, representatives of any entity, or any person doing or seeking to

do business with BOURBON, without the approval of his/her supervisor. BOURBON expects its Suppliers

not to offer any favor, including free goods, services, job or sales opportunity, to a BOURBON employee in

order to facilitate the Supplier’s business with BOURBON.

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