Hague and London Oil B.V. - Nieuwe Uitleg 24

Hague and London Oil Plc: Business Ethics 2018

HALO carefully manages exposure to corruption and bribery risks across all its operations.

All HALO Directors, employees and contractors are required to comply with relevant laws such as the UK Bribery Act and the Foreign Corrupt Practices Act. Going forward all Directors, employees and contractors will have such a compliance pledge embedded in their contracts or terms of employment.

Compliance registers should be maintained across all assets and business functions covering government hostings, per diems paid to government officials and hospitality given to or received from third parties. The relatively “low risk” environments that HALO holds its assets and the lack of operated assets has effectively made such a registry unnecessary in recent years

In addition to ongoing compliance with respect to applicable laws HALO also has tailored its due diligence performed across a range of business activities covering the supply chain, Corporate Responsibility and business development and M&A activities to enable HALO to make informed decisions about who to contract with and with whom to partner.

In the context of business development, global new ventures and M&A, there is a standalone due diligence process embedded in such agreements which applies before a final decision is taken to farm-in to a new licence and/or contract with a new partner and to make an asset or corporate acquisition.

HALO expects staff to disclose all conflicts of interest, any personal connections which staff may have to people in government and to notify the Chairman of any exposure to corruption. Where any instance of a request to make a corrupt payment arises, staff are expected to immediately report.

With effect from the re-listing of HALO, a Compliance Monitoring Plan shall be put in place to provide the Board with more clarity in relation to key corruption prevention activities. This is intended to elevate the ongoing discussion about exposure to corruption risk and to improve corruption detection. Where corrective action is taken to mitigate corruption risk identified through the Compliance Monitoring Plan, it will be done so in consultation with the Audit Committee. The objective is to understand where real corruption risk lies and to limit HALO’s exposure to it.

Andrew Cochran

Chairman and Interim Chief Executive

Hague and London Oil Plc