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Download the Santos Code of Conduct

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APPLYING THE CODE OF CONDUCT<br />

This <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> should be viewed as a guide that helps us make<br />

sound and responsible decisions about <strong>the</strong> way we undertake our business<br />

activities. It is not possible to clearly define every situation in which we<br />

may need to make a decision as to <strong>the</strong> appropriate conduct, or to define<br />

every law to which <strong>Santos</strong> will be subject. It is likely that we will face<br />

situations that are not covered by this <strong>Code</strong> nor specifically detailed in<br />

company policy.<br />

When facing such situations, you should ask yourself <strong>the</strong> following<br />

questions:<br />

4Am I authorised to make <strong>the</strong> decision?<br />

4Is <strong>the</strong> action legal? Does it contravene local or national laws,<br />

regulations or international standards? Could I justify it in court?<br />

4Is my decision in keeping with <strong>the</strong> spirit <strong>of</strong> <strong>Santos</strong>’ values, expected<br />

conduct, policies and procedures?<br />

4How would <strong>the</strong> decision look if published in a national or international<br />

newspaper?<br />

4Would I feel comfortable explaining my decision to my family and<br />

friends?<br />

4Does it feel right?<br />

In this document, you will find examples <strong>of</strong> some situations or decisions<br />

people at <strong>Santos</strong> may face and possible responses to help you understand<br />

your responsibilities.<br />

If in doubt about any <strong>of</strong> <strong>the</strong>se questions or how to respond in a given<br />

situation, you should seek guidance or help from your leader, Human<br />

Resources representative, General Counsel or <strong>the</strong> Company Secretary.<br />

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