CASTROL REWARDS PROGRAMME - ANTI

CASTROL REWARDS PROGRAMME - ANTI-CORRUPTION, ANTI-MONEY
LAUNDERING AND ETHICAL COMPLIANCE POLICY
In relation to all activity by the DSR in respect of the Castrol Rewards Programme:
1. The DSR acknowledges that the Distributor and Castrol and the BP Affiliates are committed to comply with all applicable legal
requirements wherever Castrol/BP operate and to ensuring high ethical standards. This includes Castrol/BP having a zero
tolerance policy towards bribery and corruption, including as regards the payment of facilitation/grease payments. The DSR
shares these principles and confirms that the DSR will comply with this Anti-Corruption, Anti-Money Laundering and Ethical
Compliance Policy in all respects.
2.
The DSR agrees and undertakes that the DSR will comply with all applicable anti-money laundering, anti-bribery and anticorruption laws, rules and regulations, decrees and/or official government orders applicable to the Distributor and/or the BP Group
(the “Applicable Laws”).
3.
The DSR undertakes that the DSR nor or any other person acting on the DSR’s behalf, has or will make, offer, promise to make or
authorize, any payment or other transfer of anything of value, directly or indirectly to any person or entity, including government
officials or entities, for the purpose of obtaining or influencing official actions or decisions or securing any improper advantage in
order to obtain or retain business, if such payment or transfer would violate or be inconsistent with the principles of any Applicable
Laws.
4.
The DSR confirms that the DSR has carefully reviewed the BP Code of Conduct (a copy of which is available at www.bp.com) and
agrees and undertakes that the DSR will act consistently with the applicable principles of the BP Code of Conduct in all material
respects.
5.
If the DSR becomes aware of a breach of the BP Code or other legal requirements, the DSR will use the BP Plc confidential
helpline, OpenTalk, which can be reached on +44 (0) 800 917 3604 or www.opentalkweb.com.
6.
The DSR accepts that the Castrol Rewards Programme is not available to the following and that the DSR does not fall within one
of these categories (whether full-time, part-time, permanent, temporary, paid or unpaid):
(a) any Government Official;
(b) any Restricted Party;
(c) any director, officer, or employee of Castrol or any BP Affiliates;
(d) any political party, official of a political party, or candidate for public office;
(e) any person performing a public duty or rendering a service on behalf of a public entity; or
(f) any agent or intermediary for payment to any of the foregoing.
7.
For the purposes of condition 6 above, the term “Government Official” shall include any minister, deputy minister, manager, civil
servant, director, officer, or employee of any government or any department, agency or instrumentality of any government, and/or
of any public sector company or an enterprise in which a government owns a majority or controlling interest, and/or of any public
international organization. This term also includes any police or military personnel and any person acting in any official,
administrative or judicial capacity for or on behalf of any such government or such department, agency, instrumentality, company
or public international organization.
8.
For the purposes of condition 6 above, a “Restricted Party” is any person, entity or country:
(a) with whom trade (or supply for end use by) is prohibited under any sanctions or restricted party regime imposed by the
United Nations, the EU, the United Kingdom, the United States or under other applicable law; or
(b) to whom goods of US origin may not be supplied.
9.
The DSR agrees that Castrol/BP shall have the right to terminate or suspend any agreement with the Distributor including
participation in the Castrol Rewards Programme if any member of the BP Group reasonably believes that the DSR has breached
the Terms and Conditions and this Anti-Corruption, Anti-Money Laundering and Ethical Compliance Policy.
Issue Date: 1 APRIL 2014
© Lubricants UK Limited
Page 1 of 1
Confidential

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