Statement of Ethics and Business Practices

Introduction

 Attock Petroleum Limited has committed itself to conduct its business in an honest, ethical and legal manner. The company wants to be seen as a role model in the community by its conduct and business practices. All this depends on the company’s personnel, as they are the ones who are at the forefront of company’s affairs with the outside world. Every member of the company has to be familiar with his / her obligations in this regard and has to conduct himself / herself accordingly.

 This statement in general is in accordance with company goals and principles that must be interpreted and applied within the framework of laws and customs in which the Company operates. This statement will be referred to as the "Statement of Ethics and Business Practices” and obligatory for each employee / director to adhere to.

 1.                 Integrity

 Employees are expected to exercise honesty, objectivity and due diligence in the performance of their duties and responsibilities. They are also directed to perform their work with due professionalism.

2.                 Confidentiality

All employees, both during and after their employment, must respect the exclusivity and trade secrets of the Company, its customers and suppliers and may not disclose any such information unless the individual or firm owning the information properly authorizes the release or disclosure.

All the company’s assets (processes, data, designs, etc) are considered as certified information of the company. Any disclosure will be considered as grounds, not only for termination of employment, but also for criminal prosecution, legal action or other legal remedies available during or after employment with the company to recover the damages and losses sustained.

3.                 Work Environment

All employees are to be treated with respect. The Company is highly committed to providing its employees with a safe, healthy and open work environment, free from harassment, intimidation, or personal behavior not conducive to a productive work climate. In response the company expects consummate employee allegiance to the company and due diligence in his job.

The company also encourages constructive reasonable criticism by the employees of the management and its policies. Such an atmosphere can only be encouraged in an environment free from any prospects of retaliation due to the expression of honest opinion.

4.                 Communication

All communications, whether internal or external, should be accurate, forthright and where ever required, confidential. The Company is committed to conduct business in an open and honest manner and provide open communication channels that encourage candid dialogue relative to employee concerns. The company strongly believes in a clean desk policy, and expects its employees to adhere to it not only for neatness but also security purposes.

5.                 Conflicts of Interest

Each employee is expected to conduct him/her self in an honest and ethical manner to avoid actual or apparent conflict of interest. A conflict of interest occurs when an individual's private interest interferes in any way with the interests of the Company as a whole. Also no employee will perform any kind of work (involving monetary benefit directly or otherwise) for a third party without proper approval of CEO. Conflicts of interest also arise when an employee, or a member of his or her family, receives improper personal benefits as a result of his or her position in the Company.

Every person should disclose any existing or potential conflict of interest with which he is directly or indirectly involved by presenting a written report to his departmental head.

6.                 Corporate Opportunities

Employees are expected not to:

a)                 Take personal use of opportunities that are discovered through the use of Company property, information or position.

b)                 Use Company property, information, or position for personal gains.

Employees are expected to put aside their personal interests in favor of the company interests.

7.                 Equal Employment Opportunity

APL believes in providing equal opportunity to everyone around. The company laws in this regard have to be complied with and no discrimination upon race, religion, age, national origin, gender, or disability is acceptable.

8.                 Business Controls and Responsibilities

Each employee is expected to deal fairly with Company's customers, suppliers, competitors, and other employees. No one is to take unfair advantage of anyone through manipulation, abuse of privileged information, or any other unfair practice.

We are committed to selling our products and services honestly and will not pursue any activity that requires us to act unlawfully or in violation of this Code.

Bribes, kickbacks, and other improper payments shall not be made on behalf of the Company in connection with any of its businesses. However, tip, gratuity or hospitality may be offered if such act is customary and is not illegal under applicable law. All such expenses should be reported and recorded in the company’s book of accounts.

9.                 Compliance with Laws

The Company is committed to comply, and take all reasonable actions for compliance, with all applicable laws, rules and regulations of state or local jurisdiction in which the Company conducts business. Every employee, no matter what position he or she holds, is responsible for ensuring compliance with applicable laws.

10.            Employee Retention

High quality employee’s attraction and retention is very important. The company will offer competitive wages and benefits to the deserving candidates. The company strongly believes in personnel development and employee-training programs are arranged regularly.

11.            Protection and Proper use of Company Assets / Data

Each employee is expected to be the guardian of the Company's assets and should ensure its efficient use. Theft, carelessness and waste have a direct and negative impact on the Company's profitability. All the Company assets should be used for legitimate business purposes only.

12.            Gift Receiving

Employees will not accept gifts or favors from existing or potential customers, vendors or anyone doing or seeking to do business with the Company.

However, this does not preclude giving or receiving gifts or entertainment which are customary and proper in the circumstances, provided that no obligation could be, or be perceived to be, expected in connection with the gifts or entertainment.

13.            Compliance

It is the responsibility of each employee to comply with this policy. Failure to do so will result in appropriate disciplinary action, including possible warning issuance, suspension, termination of employment, legal action and reimbursement of the company for any losses or damages resulting from such violation. Compliance also includes, the responsibility to promptly report any apparent violation of the provisions of this policy.

Any person meeting with difficulties in the application of this policy should refer to the management.