Zero Tolerance Statement on Corruption

Upstream conducts its business with integrity and has a zero tolerance approach to all forms of corruption. All Upstream personnel, whether employees, self-employed consultants, managers or directors, in all entities and branch offices of the Upstream group, as well as external contractors, suppliers, agents or other parties who act for Upstream and in all places where Upstream operates will comply with all laws, rules and regulations governing anti-bribery and anti-corruption law.

The Upstream group of companies (“Upstream”) insists on ethical and lawful conduct in all of its business relationships. To ensure it conducts business in an ethical and lawful manner Upstream maintains an Anti-Bribery and Corruption Policy. Upstream expects all agents, intermediaries, contractors and anyone else who performs services for any part of the Upstream Group (“Business Partners”) with whom we do business to conduct their business in an ethical and lawful manner. Upstream requires its Business Partners to comply with these Anti Bribery Principles. Failure to do so will prevent Upstream from entering, or lead to us to terminate, the business relationship.

Prohibition of Bribery

You will not make, accept or facilitate (or promise or offer to make, accept or
facilitate) any improper monetary or non-monetary payment, gift or other benefit to or from any person, either
directly or through any other person.

Prohibition of Bribery in Disguise

You prohibit any conduct that may influence the business conduct or
administrative decisions of others in an inappropriate manner, be it through inappropriate hospitality, gifts,
donations, or any other benefits to anyone, in cash or any other form. You will allow expenditure on gifts and
hospitality only where it is reasonable and proportionate, incurred in good faith and for proper business purposes.

Prohibition of Facilitation Payments

You prohibit payments to make any administrative process happen or
speed it up in any unofficial way. If you are asked for any such payments you must refuse and notify Upstream.
Under no circumstances must you make and conceal any such payments from us.

Compliance with Law

You prohibit any conduct that would violate any law or regulation applicable to your or
Upstream’s operations.


You maintain records to demonstrate your compliance with applicable laws and regulations
and these principles.

Risk Management

You identify evolving risks you face in relation to bribery and corruption and take steps to
manage those risks and prevent conduct that would breach these principles.

Communications and processes

You have communicated standards covering the above principles (as a
minimum) in your organisation and have ensured, through training and otherwise, that those working for you know
them and know how to apply them. You have in place procedures to detect and prevent any conduct that would
risk breaching these principles. You encourage employees to report any concerns they have in relation to potential
breaches of these principles without fear of reprisal.


You require equivalent standards to those set out in this document from any party to whom
you are permitted to subcontract any Upstream work.