BPWM

Mr.
Jason Leopold
1569 Benedict Canyon Drive
Beverly Hills, Calf 90210
EPA-HQ-2013-1876
Dear Mr. Leopold
I am responding to your FOIA request regarding the ARM and exhibits related to the BP
complaint. I am enclosing all but 2 exhibits of the 36 exhibits. The remaining two will need to
be reviewed for CBI once BP releases them to us to see if they are determined to be CBI by
EPAs Office of General Counsel.
If you consider this response to be a denial, you may appeal it by addressing your appeal to the
Freedom of Information Officer (1105A), United States Environmental Protection Agency, 1200
Pennsylvania Avenue, Room 2315, Washington, D.C. 20460. FAX: (202) 566-2147, E-mail:
hqfoia@epa.gov. The appeal must be made in writing, and it must be submitted no later than 30
calendar days from the date of this letter. Your appeal should refer to the RIN number listed
above, the date of this determination, and my name, title and address. The Agency will not
consider appeals received after the 30 calendar day limit. For quickest possible handling, the
appeal letter and its envelope should be marked Freedom of Information Act Appeal.
You may reach me 202-564-5326 if you have any questions or need additional information.
Sincerely,
Ellen P. OBoyle
National Policy, Training and Compliance Division
Environmental Protection Agency
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o Will continue to review
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o Contactor injury rate 60/o higher compared to employees.
o 80o/o of spend
o Over 60o/o of the hours worked
o 113,000 contractors
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o Common tools and processes for use across Refining and Marketing
o Exploration & Production Segment Defined Practice
o BP Group Recommended Practice
o Group-wide Operating Management System
o Group Anti Bribery and Corruption Standard
o Code of Conduct
BP01953
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Airlines
Mining
Construction
Pharmaceuticals & Chemicals
Nuclear
Space (NASA)
1.
2.
3.
4.
5.
6.
Learnings from within BP and 21 major organisations across 6 sectors:
Understand how organisations manage contractors involved in high impact activities
Phase I of the contractor management project is complete
. . . . . . What we learn from this review will inform our overall approach to contractor management
throughout the group. "
" ...... .review of the way we work with contractors for all onshore and offshore rig activities with
a particular emphasis on managing safety and operational risk.
2010 Sustainability Review;
BP01954
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implement a structure that drives predictable outcomes
focus on the operational activities needed to make the relationship work
We have been, and are in action on each of these 6 themes
6. Assurance that contractor personnel are competent
5. Intensive oversight and verification
4. Clear and specific contracts
3. Detailed and systematic selection of contractors
2. Fewer contractors to enable deeper, longer-term relationships
1. Consistent standards and priorities
BP leadership has identified six key themes:
value fewer, deeper, and longer relationships with contractors
Leading organisations
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BP01955
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BP01956
Dynamically positioned rigs contracted by BP must now have no fewer than two blind shear rams
and a casing shear ram
For example:
o Continuing to improve our Standards
o Executive Team members review of potential high

consequence risks
o Our priorities are clear
o Consistent standards & priorities delivered though

Divisional structure
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Approximately 50% of overall global project spend over the next

three years will be with 11 strategic contractors.
For example:
o Executive sponsorship and regular performance reviews
o Strategic contractors identified based on risk and spend
o Focus on potential high consequence activity
o long-term integrated relationships
o Fewer contractors
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BP01957
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BP01958
For example:
31 audits of potential contractors for our global projects have taken place to date- evaluating their
HSSE, anti-bribery and corruption & quality processes, together yvith their financial health.
o Audit
o Approved Vendor Lists
o Due diligence
o Contracts governance boards established in our Developments and

Production Divisions
- Contract briefs
- Schedules of responsibilities
- Standard contract terms and conditions
- Safety enhancements
o Potential high consequence activity contracts:
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For example:
Third-party certification of subsea BOPs has been undertaken byDNVand West Engineering
o Operations shutdown, paused or delayed
o Targeted interventions
o Operational inspections of Wells activities
o Rig audit
o Safety and Operational Risk Committees established
o New metrics
10
BP01960
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For example:
14 capability assessments of cementing contractors have been completed.
- Capability assessments
- Critical positions
o Contractor Capability
- A recruitment programme is underway
- PSCM standard structure in place
o BP Capability
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BP01961
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- Commence Phase II, across the BP Group
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- Linking our systems and processes together
- Updates to our systems and processes
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- Implement Phase I, starting with drilling rigs.
o In action - more to do:
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BP01962
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Rec:ommend::tt1on completion estimate
Recommend01t1on complete
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BP01963
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The process for 1mplementmg the Bly Recommendations is f1rmly 1n place. The timelines are estimates based on existing facts, Circumstances and planning status. While these
estimates reflect the team's best judgment, they can change depending on circumstantial factors such as complexity, resource availability and evolving regulatory requirements.
We continue to make progress against

the 26 recommendations
15
14 t 9t ab Irs h Kl-' I s t I) r \lt/e II Integ r rty.
13 Strengtt1en BP's rig audtt prooessto imprave closure and verification
12 F: e Cl'Jest lAD
11 Estab lis h BP i C> house expet1 ise io r subsea BOP and BOP rorrt ro I systems
10 Develop advanoeci deepwater well control training
e Strengthen the technicill authority's role in cementing and zonal isolation

9 Enhan:e D& c
p rograms for key opmtion al and leaders hip posit ions
7 As:sess risK management and MOC processe:s for liie cycle of D&C aaivities
6 Propose recommended practioe:forfoam cement testir,gtoAPI
5 Strengthen 1n:ident reporting standards fonvell contro I and well integrity
4 Update praai:e on
3 Update- n:-quitenll?
2 Updutc rcquircmc nt for BOP oonfigur.ltion
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BP's requirements for BOP testing by drilling contr.octors
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14
BP01964
Tne pcocess for Implementing the Bly Recommendations is firmly in place. The timelines are estimates based on existing facts, mcumstances and planning status. While these
estimatesreflect the team's best judgment, they can change depending on circumstantial factors such as complexity, resource availability and evolv1ng regulatory requirements.
Recommendations 17, 20, 21, 22,23

and 25 will be worked on and rolled out
together as they require contractual
changes.
26 Include testing .:.nd verification of revised BOP standard:; in rig audit
25 Require drilling contractors to verify BSR sf1ea ring perio rman ce capabil
24 De\elop a clear plan for ROV intervention for each of BP's operating regions
23 Set minimum requirements for drilling contractors' MOCfor subsea ,BOPs
22 Strengthen BP's requirements for BOP rn.aintenance by drilling contractors
21
20 E stab I ish minimum levels of redurrd.ancy and reliability for BOP systems
19 Include study of all swface system hydrocarbon vents in all HAZOPs
18 Require hazard and
17 Confirm vvell cor,trol olnd monitoring practices are defined and applied
16 Assess cemerrting service provider capabilities
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BP Code of Conduct
Wesay
what is true .
.We do
what is right.
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BP02050
BP Code of Conduct
To be a trusted
company, year after
year, we need to work
to a consistent and
higher set of standards
and follow them in
everything we do
and say, every day,.
everywhere we work
0
6
BP02055
BP Code of Conduct
Welcome to our Code of Conduct. This book sets out the basic rules we must
all follow in BP and explains how our values should guide all of our decisions.
The Code provides information on where to find more detailed standards
and guidance on particular subjects. in other words, it helps us do the right thing
when we're faoed with difficult decisions. This builds trust and has a positive
effectonthosewetouch.
Laws vary from country to country and we must always com ply with them,
but as a global company, we need to go further. To be a trusted company, year
after year, we need to work to a consistent and higher set of standards and
follow them in everything we do and say, every day, everywhere we work.
All of us at BP, without exception, are duty bound to follow and uphold our
Code of Conduct -and we must all remember that failure to do so can
put BP and ourselves at risk.
If you are ever concerned that our Code is not being followed, or simply feel
unsure about any situation, it is vital that you speak up and ask a question or
share your concern straightaway. Inside you will find details of the different
ways to do this, including our confidential help! ine, OpenTalk.
Our reputation, and our future success, rests on each of us taking personal
responsibility for putting our Code into practice. Together we can show the
world that BP is a company united by strong values -a companyofwhich
we are proud to be a part.
We say what is true. We do what is right.
Bob Dudley,
Group Chief Executive
0
7
BP02056
BP Code of Conduct
c
What our Code
is all about
Our Code gives us the guidance and support we need to
conduct our business ethically and to comply with the law.
These two things are vital to our success.
Our Code represents our commitment to do the right thing,
including respecting the rights of others. By being part of BP
you are agreeing to uphold this commitment. If you do not, you
could put yourself, your colleagues and BP at risk. Put simply,
failure to follow this Code is misconduct, which could result in
disciplinary action and even dismissal.
No part of our Code can be waived without prior approval
which reflects our wholehearted commitment to it. This will
be coordinated by the Group Ethics & Compliance Officer,
who will obtain approvals and make sure all appropriate reports
and representations are made. This includes those required by
law. Waivers will only be granted in exceptional circumstances.
Who must follow our Code?

The shortanswertothis is everyone.
The longer answer is every employee
and officer in every BP wholly owned
entity, and in joint ventures (JVs) to the
extent possible and reasonable given
BP's level of participation. In situations
where BP does not have overall control
of a JV, we will do everything we
reasonably can to make sure JVs and
JV partners follow similar principles.
We also seek to work with third parties

who operate under principles that
are similar to this Code. This includes
making a contractual commitment
where it is feasible to comply with the
applicable laws and work in line with
our Code. We expect all our contractors
and their employees to act in a way
that is consistent with our Code, and
follow its principles. We will consider
terminating contracts where we believe
they have not met our standards or their
contractual obligations.
0
8
BP02057
BP Code of Conduct
If you
others ...
You have additional responsibilities
under our Code:
Being a role model for ethical

leadership.
Being a role model for safety
leadership and creating the right
environment for people to be
comfortable living our value of safety.
Supporting ethics and compliance
activities in BP.
Making sure all your team members
understand the requirements of our
Code and local legal requirements,
and have the resources to adhere
to them.
Holding your team members
accountable to behave ethically
and follow our Code and legal
requirements.
Enforcing our Code consistently.
Making sure appropriate compliance
controls are implemented in your
organization.
Supporting your people to ask
questions and raise any ethical
concerns by:
-Encouraging them to speak up.
-Dealing with concerns when they
are raised.
-Making sure that no one who speaks
up suffers any retaliation.
Following the law, setting

the standard
With BP doing business in more than
80 countries, our Code cannot cover all
the different laws, applicable regulations
and other legal requirements. It is
important for you to be familiar with
any that apply where you work.
First and foremost, we must comply

with legal requirements. Where
there is a difference between a legal
requirement and our Code, always
apply the most stringent standard.
If you have any questions about this,
talk to your line manager, HR, Legal,
or Ethics & Compliance.
A highly regulated environment exists
around BP's trading activities which
sometime!; interact with other BP
businesses. it is essential that all our
trading and any associated business
activities are conducted within the
trading control and compliance
framework. The Global Trading
Guidelines build on our Code in this
area. They set out the standards of
behaviour and integrity that apply to
everyone who engages in activities in
the trading environment at BP.Ifyou
need help with this, contact Ethics &
Compliance.
Above all, please remember that our
Code is only a starting point. It cannot
address every situation and is no
substitute for using good judgement
and doing the right thing.
Getting the information

you need...
To point you in the direction of more
detailed information on various
topics, there are additional resources
highlighted throughout the Codemarked with the symbol.
Links to specific documents/Websites

are also provided in the Appendix.
. .. And the answers to your
questions
Our Code does not alter the terms

and conditions of your employment.
It details what is expected of everyone
at BP and supports us in being
responsible and respectful.
In this document words or phrases
such as 'BP', 'our company' and
'company' are used typically to mean
the BP group companies.
0
9
BP02058
BP Code of Conduct
Our Code is based on

four foundations
...
...
...
What we do
....... ._........
....... .........
....................... ....
............................... ._ .................................................... ._ .........................................
We deliver energy to the world. We find,

develop and produce essential sources of
energy. We turn these sources into products
that people need everywhere.
The world needs energy and this need is
growing. This energy will be in many forms.
It is, and will always be, vital for people and
progress everywhere.
We expect to be held to high standards in what
we do. We strive to be a safety leader in our
industry, a world-class operator, a good corporate
citizen and a great employer. We are BP
0
10
BP02059
BPCodeofConduct
We care deeply about how we deliver energy

to the world. Above everything, that starts
with safety and excellence in our operations.
This is fundamental to our success.
What we stand for
Our approach is built on respect, being consistent

and having the courage to do the right thing.
We believe success comes from the energy
of our people. We have a determination to learn
and to do things better. We depend upon
developing and deploying the best technology,
and building long-lasting relationships.
We are committed to making a real difference
in providing the energy the world needs today,
and in the changing world of tomorrow. We work
as one team. We are BP
0
11
BP02060
BP Code of Conduct
::....................... .
Safety
Safety is good business. Everything we do relies upon the safety of our workforce and
the communities around us. We care about the safe management ofthe environment.
We are committed to safely delivering energy to the world.
What we value
Respect
We respect the world in which we operate. It begins with compliance with laws and
regulations. We hold ourselves to the highest ethical standards and behave in ways
that earn the trust of others. We depend on the relationships we have and respect
each other and those we work with. We value diversity of people and thought. We
care about the consequences of our decisions, large and small, on those around us.
Excellence
We are in a hazardous business and are committed to excellence through the
systematic and disciplined management of our operations. We follow and uphold
the rules and standards we set for our company. We commit to quality outcomes,
have a thirst to learn and to improve.lf something is not right, we correct it.
Courage
What we do is rarely easy. Achieving the best outcomes often requires the courage
to face difficulty, to speak up and stand by what we believe. We alw;ys strive to
do the right thing. We explore new ways of thinking and are unafraid'to ask for help.
We are honest with ourselves and actively seek feedback from others. We aim for
an enduring legacy, despite the short-term priorities of our world.
One Team
Whatever the strength of the individual, we will accomplish more together.
We put the team ahead of our personal success and commit to building its
capability. We trust each other to deliver on our respective obligations.
0
12
BP02061
BP Code of Conduct
We all share a responsibility to speak

up whenever we have a question
about our Code or think that it may
have been violated.
Speaking up
What we do is rarely easy. We need

to have the courage to speak up and
always strive to do the right thing. This
means you must always ask for help
when you have a question about our
Code or believe it is not being followed.
If you become aware of a breach or
potential breach of our Code or other
legal requirements, you must report
it straightaway- whether it relates to
you, your manager, or anyone else.
Our Fraud and Misconduct Reporting
Standard provides further information
on incident reporting- see the
Appendix for the link. Report urgent
problems like safety hazards locally if
you can to get the fastest response.
OpenTalk offers a confidential way to

answer your questions and respond
to your concerns in relation to ethics,
compliance or any other requirements
in our Code. The helpline, operated by
an independent corn pany, is available
for you anytime day or night. every day
of the week. The OpenTalk helpline
can accommodate calls in more than
751anguages.
When you contact OpenTalk, which
you may do anonymously inmost
jurisdictions, the operator will listen
to your concern or enquiry, ask you
clarifying questions if necessary, and
then write a sum mary report of the call.
The summary will then be provided to
BP's OpenTalk Team for assessment
and further action, as appropriate.
We are committed to consistently

looking into all potential breaches or
questions that are raised, and we will
deal with them fairly and responsibly.
To prevent an issue or concern from
turning into a crisis, seek advice or
support as soon as you can. You have
the choice of:
Talking it through with your line
manager-usuallythe best option.
Taking it to your Ethics and Compliance
Leader (ECU.
Getting in touch with Legal, HR or
Ethics & Compliance.
Contacting OpenTalk if you are not
comfortable contacting any of the
people identified above.
0
13
BP02062
BP Code of Conduct
c
Zero tolerance
on retaliation
Our zero tolerance policy
on retaliation goes hand in
hand with our belief that
speaking up is always the
right thing to do.
If you voice a concern or
report misconduct in good
faith- or take part in an
investigation of an ethics and
compliance matter-you are
following our Code. Under no
circumstances will BP tolerate
retaliation against you. We
consider acts of retaliation
to be acts of misconduct
which, if substantiated, could
result in disciplinary action
and even dismissal.
Retaliation can take many forms

from being ignored to being unfairly
dismissed. It might also involve being
bullied with the aim of stopping you
from reporting a potential breach
of our Code. We take all claims of
retaliation seriously, investigating
each one thoroughly and taking
appropriate action.
If you think that you or someone
you know has suffered retaliation,
contact OpenTalk or the Group Ethics
& Compliance Officer, a Human
Resources Representative or Legal
without delay.
0
14
BP02063
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BP Code bf Conduct
Operating
safely,
responsibly
and reliably
0
BP02069
reliably
("\
\
Everything we do relies upon the safety of our

workforce and the communities around us.
We make it a top priority to protect our own safety,
as well as that of our colleagues and everyone
else we come into contact with. We are also
committed to protecting the environment and
respecting the rights and dignity of communities
around the world where we do business.
We operate in hazardous environments, and we
are committed to excellence and to the disciplined
management of our operations. Our leaders have
the responsibility of being role models for safety
leadership and creating the right environment for
people to be comfortable living the value of safety.
Our health, safety, security and environment
(HSSE) goals are no accidents, no harm to people
and no damage to the environment.
0
21
BP02070
BP Code of Conduct
Protecting health, safety,

security and
the environment
We all share responsibility for protecting people's health,
safety, security and the environment (HSSE). This includes
everyone at BP and everyone touched by our activities.
This is essential to respecting their rights and to our success.
We work hard to improve our impact on the environment
and health by:
Basic rules you must follow

Always
Act first to protect the safety and
well-being of everyone around you.
Comply with the applicable laws and
follow the requirements set out in your
local Operating Management System
(OMS} or in Office Safety.
Stop work that you believe is unsafe,
may harm health, or is likely to result in
a loss of containment that will damage
the environment.
We also set measurable HSSE performance targets in our

business plans, which we are all committed to meeting.
Personal and process safety is about more than following
rules. We all need to be alert to safety risks as we go about
our jobs. Nothing is so important that we cannot take the
time to do it safely.
Only undertake work if you are

competent, medically fit, and
sufficiently rested and alert to
carry it out.
Make sure you know the emergency
procedures that apply Where you work.
Help make sure that those who work
with you- employees, contractors and
third parties -act consistently with our
HSSE and operating commitments.
Respectthecapabilitiesofthose in
safety-critical roles.
Report any accident, injury, illness,
unsafe or unhealthy condition,
incident, sp1ll, unplanned release
of material to the environment,
or apparent breach of law or BP
requirements to local BP management
so that immediate action can be taken.
Never assume that someone else will
report a risk or concern.
Ask for help and advice if you are
unclear about your HSSE and
operating responsibilities, or if you
are concerned about a possible
or actual breach of a law or BP
requirement at work.
22
BP02071
Operating safely, responsibly and reliably

Never
Work while your performance is
impaired by alcohol or any prescription/
over-the-counter drug, whether it is
legal or illegal.
Threaten, intimidate or act violently
towards anyone at work or in the
communities where we operate.
Bring weapons- including those
carried for sporting purposes-onto BP
premises, or use weapons anywhere
to advance BP business unless you
have obtained approval to do so. These
prohibitions, and the need for approval,
do not apply at any location where their
application or enforcement would be
inconsistent with the applicable law
at that location. The approval process
is initiated by written request to the
Regional Security Adviser. It requires
the approval of the Vice President,
Group Security, and the President,
BP America for US locations or the
Strategic Performance Unit Leader
or equivalent outside the US.
We aim to manage our operating and

HSSE risks systematically, and improve
performance through the Operating
operating entities and Office Safety for
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Safety are provided in the Appendix.
To find out more about HSSE in BP,
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apply), visit our Safety and Operational

Risk website -see Appendix for details.
You will find more on digital security
requirements under 'Using our digital
systems responsibly and securely'
in this Code.
If you have any questions or concerns
about safety and operations, there are
many different ways to raise them.
For example, you can talk to your
line manager or another colleague.
If you would rather speak to someone
independently and in confidence, you
can contact OpenTalk.
andexter
iQ\ie$1igate the
similar incidents h,;,n<m ii1n in:
:.:the future.
0
23
BP02072
BP Code of Conduct
Treating people fairly,

with dignity and giving
everyone equal opportunity
Our people are one of our greatest strengths. We value diversity of
people and thought. and we value every employee as an important
member of one BP team.
We aim to make sure that everyone at BP-and everyone we
come into contact with- is treated with fairness. respect and
dignity, and never unfairly discriminated against.
Our aim is that as a BP employee you:

Alwa'(s
Base your decisions about

recruitment, selection, development
and advancement of employees on
merit. Base your decisions on their
qualifications, demonstrated skills
and achievements.
Expect other parties you work with
(contractors, agents, joint ventures)to
act in a way that is consistent with our
fair treatment and equel opportunity
standards.
Complywithalltheapplicablelabour
and employment laws.
Report any breaches of law or this
Code of which you become aware, and
cooperate with company investigations.
Seekedvice if you have a concernwhether it concerns yourself, direct
reports or others.

Never
Allowrece, colour, religion, gender,
age, national origin, sexual orientation,
gender identity, marital status, disability
or any other characteristic protected
by any applicable law to influence
your judgement when it comes to the
recruitment, selection, development
and advancement of employees.
0
30
BP02079
Our people
Child and forced labour
We are committed to the elimination of all

forms of forced and compulsory labour, and
to the effective abolition of child labour.
Always
Be alert to any evidence of child labour

or forced labour abuse in our own
operations or the operations of others
working on our behalf. Report them
to BP management, HR or Legal.
Ensure our contractors and other
third parties working on our behalf
understand our expectation that no
child or forced labour will be used in
their work for BP.
To find out more about our diversity and

inclusion policies and programmes, visit
your locai'People' website.
If you have any questions about equal
opportunity or diversity, get in touch with
an HR representative.
If you are concerned about a conflict
between our Code and the laws,
customs and practices of the place where
you work, contact your line manager, HR,
Legal or Ethics & Compliance. To talk to
someone independent in confidence,
contact OpenTalk.

Never
Hire child or forced labour.
0
31
BP Code of Conduct
c
Creating a respectful,
harassment-free workplace
Everyone at BP is entitled to fair treatment, courtesy and respect.
We will not tolerate any form of abuse or harassment of employees,
contractors, suppliers, customers or anyone else we deal with.
Using abusive or inappropriate language during performance
conversations and reviews is prohibited. However, holding
performance conversations and reviews which raise the need
for performance improvement or changes in behaviour do not
generally constitute harassment or abuse.

Never
Behave in a way that could reasonably
be considered offensive, intimidating,
malicious, discriminatory or insulting.
Sexually harass a colleague by making
unwanted sexual advances, requesting
sexual favours and/or physical contact,
or behaving in any other sexually
offensive way. Harassment does not
have to take place at work or involve a
BP employee to violate our Code or
even the law.
()
Engage in any form of harassment with

the intent or effect of:
-Creating a hostile or intimidating work
environment, including one in which
employees may be driven to engage in
inappropriate work practices to 'fit in'.
-Interfering with an individual's work
performance in an unreasonable way.
-Affecting an individual's employment
opportunity.
Humiliate, denigrate or injure another
person.
Make insults or tell jokes of a racial,
ethnic, religious, disability-related,
age-related or sexual nature.
Make derogatory remarks about sexual
orientation.
Remove or deface any sanctioned
posting of BP-recognized affinity groups
or business resource groups.
0
32
BP02081
Our people
I
I
iliilJ
Distribute or display offensive material,

including inappropriate pictures,
cartoons and symbols of hatred.
Misuse anyone's personal information.
Make untruestatementsaboutanother
person or BP.
Spread malicious rumours or share
offensive, derogatory or discriminatory
information through any means.
These are just examples. Whatever the
form of abuse or harassment, put simply
it has no place in BP.
You will find more information about our

policies on harassment at the HR website
-see Appendix for link details.
Please see 'Operating safely, responsibly
and reliably' in this Code for guidance on
dealing with violence at work.
If you experience or witness any form of
abuse or harassment, report it to your line
manager or HR, or contact OpenTalk.
We rely on you reporting such serious
issues promptly so that we can intervene
without delay. Our zero tolerance policy
on retahatton protects anyone who makes
a report in good faith about an actual or
potential violation of our Code or the law.
1111111
0
33
BP02082
BP Code of Conduct
c
Protecting privacy
and confidentiality
We are committed to respecting people's privacy and the
confidentiality of personal information. We will only acquire
and keep personal information that we need to operate BP
effectively or to comply with the law.
Because we respect an individual's right to privacy, we do not
usually take an interest in what anyone does outside of work
-unless it impairs their work performance, or threatens BP's
reputation or legitimate business interests.

Always
Classify personal information
as confidential. Limit access to
appropriately authorized individuals
who have a clear business need for
that information.
Use personal information that you
are authorized to access only for the
purposes known to, or expected by,
the individuals concerned-that is,
fairly and with absolute integrity.
Keep personal information no longer

than necessary to accomplish the
legitimate purpose for which it was
collected or to satisfy a legal, regulatory
or legitimate business need.
Be aware of the existence of local
privacy laws, specifically when
transferring personal information
outside its country of origin. Consult
your privacy adviser or data protection
co-ordinator to identify any legal
requirements that must be observed.
Be objective when making written
comments about individuals and
remember that documents containing
comments may be disclosed. All
personal
including
your opinions, should be relevant,
appropriate, accurate and justifiable.
Exercise care and. discretion when
you use electronic media. Remember,
information created or stored on
computers or other electronic devices
may not be secure or private. It may also
be accessed, monitored or audited at
any time without notice, subject to local
laws and regulations.
0
34
BP02083
Our people
Process personal information in

accordance with the BP data privacy
rules which govern how the BP group
of companies collectively manages
personal information. You will find these
at the Legal website- see Appendix
for link details.

Never.
Seek access to personal information

that you are not authorized to have
or when there is not a valid business
reason to have it.
Provide personal data to anyone inside
or outside of BPwrthout ensuring that
it is appropriate to do so. Make sure ,
you take appropriate security measures.
B
To find out more about protecting
personal information, see' Protecting
BP's assets' and 'Using our digital
systems responsibly and securely'
in this Code.
You will find more information on privacy
under 'Preventing conflicts of interest'
and 'Our stance on political activity'.
For more guidance on the personal use
of digital systems, see 'Using our digital
systems responsibly and securely'.
To find out more about data retention
periods, see 'Accurate and complete
information, records, reporting and
accounting.'
You will find full details and frequently
asked questions on privacy compliance
at the Legal
see Appendix for
link details.
If you would like further details on privacy

requirements, your privacy adviser or
data protection co-ordinator can help.
0
35
BP Code of Conduct
c
Appropriately exchanging
gifts and entertainment
At a glance
In detail
We only give or accept gifts and entertainment that are for business
purposes and are not material or frequent.
Exchanging gifts and sharing entertainment in connection with a
legitimate business purpose can foster constructive relationships with
third parties. However, gifts and entertainment should never affect,
or appear to affect, impartial decision-making by BP employees or
any third party. They should never be offered or received in exchange
for preferential treatment in any business dealing.
Certain gifts and entertainment can erode others' trust in BP and
must be avoided. These include any gifts or entertainment that appear
to be bribes, raise questions about conflicts of interest for you or BP. or
would damage BP's reputation.
It is never appropriate to attempt to bias a decision by offering personal
benefits to a government official or anyone else. We support laws
prohibiting bribery and corruption, which often include stringent rules
concerning gifts and entertainment involving government officials
and other third parties.
'Hosting' is another strictly regulated activity which involves paying
for a third party's (such as a government official or an employee of a
commercial entity) travel, accommodation or daily living expenses
in conjunction with their visit to a BP office, site or other location for
the purposes of promoting, demonstrating or explaining the benefits
of BP products or technology. We always follow laws or rules
concerning the hosting of government officials and any other of
our business partners.
'Gifts and entertainment' include anything

of value offered to or received by an
individual or members of their family.
'Gifts' include cash and non-cash items,
some examples of which are:
Artwork
Watches
Jewellery
Equipment
Preferential discounts
Loans.
Favourable terms on a product/service
Services
Prizes
Donations to charities
Transportation
Use of another company's vehicles
Use of vacation facilities
Stocks or other securities
Participation in stock offerings
Home improvements
Tickets and gift certif1cates
'Entertainment' is where you accompany
a third party to an event and includes,
for example, business meals, invitations
or tickets to recreational, cultural or
sports events and venues, as well as any
associated travel, accommodation, meals
and refreshment. Entertainment should be
treated as a gift if the party who made the
offer does not plan on attending.
4Z
BP02091
Our business partners

Always
Comply with the most stringent
requirements for giving and receiving
gifts and entertainment, whether they
are the rules set out in this Code, any
applicable local internal policies, third
party rules, contract terms or applicable
legal requirements.
Where required, accurately record gifts

and entertainment you offer, give or
receive in the BP Gifts and Entertainment
Register or your approved local gifts
and entertainment register. You must
com ply with the most stringent recording
requirements, whether they are the rules
set out in the chart below or an applicable
local internal policy.
Obtain appropriate management

and where necessary Legal approvals
before offering or accepting any gift
or entertainment to/from a third party.
You must comply with the most
stringent approval requirements,
whether they are the rules set out in
the chart below or an applicable local
internal policy.
Immediately return any gift of cash or

cash equivalent that you receive from
a third party and notify Legal that this
has happened.
If you believe it would be insulting
to decline a gift, report it to your line
manager who will decide whether it
can be retained by you or BP, donated to
charity (either itself or the money from its
sale), or returned. Return any indecent or
improper gift.
Obtain Legal approval before paying
for the 'hosting expenses'- including
transportation, lodging or related travel
expenses -of a government official,
including state company delegations.
Obtain Legal advice before offering or
exchanging any gift or entertainment
with a government official, and record
all gifts and entertainment offered/
given to or received from government
officials in the BP Gifts and Entertainment
Register or your approved local gifts and
entertainment register.
. . . .
..-..:
1:
... ..
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,1ig1ht:s.t'
...c \ ........................
........
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) ... . ...... ..... ............

..
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.........
,
... . . . . . ..
I...
:
ate single
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event;
is 1liEitotalai-nQunty6Usp$rjdforthe'.
enterfaihment, . ... . . . .
.. . .. .. .... .. .
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1!i
from
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43
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>/
.. .
BP Code of Conduct
c
Appropriately exchanging
gifts and entertainment (cont.)
Never
Offer, give or receive any gift or
entertainment that:
-Could be construed as a kickback, bribe,
payoff or violation of any law or other
BP standard.
-Is cash or a cash equivalent, such as a
bank cheque, money order, investment
securities, gift certificate/card or
negotiable instrument.
-Was solicited or offered in return for
something else.

about gifts and entertainment, contact
your line rnanager, Ethics and Compliance
Leader, Legal or Ethics & Compliance.
You'll find more information under
'Eliminating bribery and corruption',
'Preventing conflicts of interest', and
'Dealing with governments' in this Code.
You can also access the BP Gifts and
Entertainment Register and the Approval
Form for Hosting Government Officials
at the links provided in the Appendix.
-Is indecent, sexually oriented, does

notcomplywith ourcommitrnentto
mutual respect or could adversely
affect our reputation.
Offer, give or receive any gifts or
entertainment with third parties when
you are involved in or could influence a
tender or competitive bidding process
with them, unless approved by Ethics
& Compliance.
Personally pay for any gift or
entertainment to avoid having to report
or seek approval for it.
Conceal, or assist in the concealment of.
the offering, giving or receiving of gifts
and entertainment.
Offer, give or receive gifts and
entertainment with the same third party
more than twice per year without prior
approval from your line manager.
0
44
BP02093
0
45
BP Code of Conduct
c
Preventing conflicts
of interest
Ataglance
We respect the privacy of everyone who works for BP and do not
normally take an interest in what people do outside of work.
But conflicts of interest can happen if an employee's personal,

social, financial or political activities interfere, or potentially interfere,
with their loyalty to BP.
Wherever possible, conflicts of interest should be avoided. If and
when they do happen, they must always be carefully managed.
Even the appearance of a conflict of interest can be harmful and
needs to be addressed.
In detail
There are many different ways conflicts

of interest can arise.
Outside jobs and affiliations
These situations can create an actual

or apparent conflict of interest if they involve
you:
Having a second job.
Performtng services.
Serving as a director or consultant.
Holding a financial interest with an
existing or potential competitor,
customer or supplier of B P.
Jobs and affiliations of close relatives
These can also create conflicts of interest.

In general, a close relative should not have
any business dealings with you, anyone
who reports to you, or anyone working in
your business unit. Close relatives who are
government officials could present unique
issues and should always be disclosed.
'Close relative' means a spouse, partner,
parent, step-parent, child, step-child,
sibling, step-sibling, nephew, niece, aunt,
uncle, grandparent, grandchild and in-law
-or anyone else you have a close personal
relationship with.
0
46
BP02095
(\
\
Board directorships
Our employees are occasionally asked to
become directors on other organizations'
boards. Sometimes this can raise conflicts
of interest or legal issues. Before you
accept a board directorship, you need to
follow the non-executive director approval
process- see Appendix for details.
Investments
All employees should make sure that their
investments and their close relatives'
investments do not create conflicts of
interest that could affect their objectivity
when making work decisions.
Deciding whether or not you have a conflict

of interest is down to good judgement.
Ask yourself:
Would this situation affect any decisions
I make for BP?
How would it look to my co-workers?
Would they think it could affect how
I do my job?
How would it look to someone outside
the company, such as a customer or
shareholder?
How would it be perceived it it were
reported in a newspaper?
For exam pie, conflicts can arise if you or

a close relative invests in a competitor,
supplier, or customer of BP. For any
substantial interest of this kind, you
would need prior written approval from
your line manager.
'Substantial interest' means an interest
that might influence or appear to influence
your judgement. As a guide, if you were to
own less than 1o/o of the shares of a publicly
quoted company- or earn less than 1Oo/o
of your net worth from an investmentthis would not normally cause a conflict.
If you are in any doubt, check with your
line manager or Legal.
0
47
BP02096
BP Code of Conduct
c
Preventing conflicts
of interest (cont.)
Always
Disclose any outside jobs and affiliations
with competitors, customers or suppliers
to your line manager and obtain written
approval. If your role with BP involves
evaluating potential suppliers or selling
to potential customers, you may have
to disclose any relationships of this kind
to them also.
Notify your line manager if you leam
that a 'close relative' works or performs
services for a BP competitor, customer
or supplier.
Get written approval before accepting
any board position (including for notfor-profit organizations) in accordance
with the non-executive director
approval process.
Notify your line manager if you have any
other relationships that could create or
appear to create a conflict of interest.

Never
Hire, supervise, affect the terms and
conditions of employment, or influence
the management of any close relative
unless it has been approved by your line
manager. Thisapplieswhethertheyare
a BP employee or contractor.
Work for, or provide services for, anyone
that you must deal with as part of your
jobforBP.
Invest in a current or prospective supplier
if you have any involvement in their
selection, assessment or negotiations.
This applies equally if you supervise
anyone who has such responsibility.
If you think you might have a conflict

of interest, or that other people might
think you do, talk it through with your
line manager straightaway.
Conflicts of interest can usually be
resolved to everyone's satisfaction, but
they always need careful consideration.
Not disclosing a conflict could mean
disciplinary action.
(!
You will find more information on conflicts

of interest in our Global Guidelines on
Handling Relationships in the Workplace.
Invest in a customer if you are

responsiblefordealingswiththat
customer or supervise anyone who
is responsible for them.
0
48
BP02097
(\
\.
0
49
BP Code of Conduct
c
Complying with competition
and antitrust laws
Ataglance
Everyone at BP must comply with competition laws- known in
the US and some other countries as antitrust laws. These are laws
that protect competition by prohibiting anti-competitive behaviour.
This behaviour may include:
including price fixing, bid rigging, market allocation and agreements

to restrict supply.
Even where some behaviours may be lawful (for example, in a

country that has not adopted competition laws), we will not enter into
any arrangements with competitors that could harm BP's reputation.
In detail
Most countries in which we do business

have competition laws. Some of these
apply beyond national boundaries- for
example, the rules in the European Union
and the US.
The penalties for breaking competition
laws are severe. Fines for anti-competitive
behaviour can be up to 10% ofthe BP
group's annual global turnover. As well as
being fined personally, individuals convicted
of the most serious offences can face
imprisonment.
Agreements with competitors
Certain agreements with competitorsprice fixing, bid rigging, market allocation
and agreements to restrict supply- are
aim ost always illegal. You must never enter
into these kinds of agreements, regardless
of where you are based, without getting
advice from Legal.
Under competition law, 'agreement'

has wide meaning and includes informal
understandings with competitors.
Arry action that appears compromising
could trigger an investigation and be used
as evidence of anti-competitive behaviour.
For exam pie, regular get-togethers with a
competitor over coffee could be seen by
an authority as providing an opportunity
to collude.
0
50
BP02099
Information sharing
Dealing with customers and suppliers
Market power
We must be very careful about sharing

competitively sensitive information with
third parties. This includes current and
future prices, marketing and operational
strategies, costs, customers and suppliers.
You should not share BP's competitively
sensitive information with third parties,
especially competitors. Nor should you
receive such information directly or
indirectly from competitors without first
obtaining advice from Legal. We must
avoid illegal exchanges of information,
and we also must avoid the appearance
of such activities.
Depending on the jurisdiction in which you

operate, placing certain kinds of restrictions
on your customers or suppliers may be
illegal. These include agreements that
Activities that are legal for many companies

may be illegal for businesses with a large
market share. For example, in many
countries it is illegal to use certain pricing
or contracting strategies to maintain a
monopoly or dominant market position.
If your business has a large market share,
you must consult Legal to understand
how the law may apply to you
Trade associations
Trade associations and other industry

bodies are a useful way of helping us to
achieve business goals- improved safety,
for example. Since they bring us together
with our competitors, however, we need
to take particular care with all our trade
association participation.
Restrict your customer's freedom to

set the resale price.
Lim it your customer to buying only
from you.
Restrict where, or to whom, your
customer can sell.
Require your supplier to sell only to you.
Always check with Legal before putting
any restrictions on distributors, customers,
or suppliers.
Price discrimination
Charging customers different prices can

be illegal in some jurisdictions under certain
circumstances.lf you have the authority
to set prices, check with Legal to make
sure you know the legal requirements.
Joint ventures
Agreements made between joint venture

(JV) members about the operations of
the JVare considered to be partner rather
than competitor agreements -even if the
partners are competitors outside the JV.
But anti-competitive agreements between
competing JV partners beyond the scope
of the JV are prohibited. Also, the exchange
of competitively sensitive information
between BP. its JVs or JV partners may
be problematic; therefore, prior to the
exchange of such information, you should
consult Legal.
0
51
Merger control
Mergers, joint ventures, and acquisitions/

disposals of assets or shares may require
approval from competition authorities
before they can proceed. Notification
requirements vary throughout the
world, and sanctions can include fines,
transactions being declared void and
divestments being required. Businesses
should always seek competition law
advice from Legal before entering into
such transactions.
BP Code ot Conduct
c
Complying with competition
and antitrust laws (cont.)
Always
Take care when dealing with competitors
not to participate in any arrangement that
could be construed as anti-competitive
collusion. If you find yourself in a meeting,
including trade association meetings,
where a questionable discussion is taking
place, you must make it clear that you
believe the discussion is inappropriate,
break away from the discussion, and
promptly inform Legal.
Ensure you are familiar with how
com petition law impacts on your
qusiness in your jurisdiction, and
consult Legal as appropriate.

Never
Unless you receive advice to the contrary

from Legal, never:
Agree with competitors to fix prices to
third parties (including agreeing on the
amount or timing of a price increase or
level of discount or rebate) or agree on
other terms related to prices (pricing
formulae, credit terms, etc.).
Intentionally signal future prices to
competitors through customers,
industry articles or other means.
Agree with competitors to divide up
customers, territories or markets.
Discuss competitive bids with
competitors or agree on who will win
a competitive bid.
Agree with competing producers to
limit or restrict production or capacity
(including making agreements to shut
down capacity).
Exchange or discuss competitively

sensitive information with competitors.
This includes:
-Current or future prices or price-related
terms to third parties.
-Costs.
-Individual customer details.
-Production or capacity data.
-Future expansion or capital expenditure
plans.
-Future commercial strategy.
Agree with your customer (inc! uding

your distributors) the price it will charge
its customers or minimum resale prices.
Restrict to whom your customers
can sell or the territories in which your
customers can sell.
Enter into joint ventures, mergers,
acquisitions, divestrn ants, or jointmarketing, joint-purchasing or similar
collaborative arrangements with any third
partywithout seeking legal advice first.
Agree with a competitor to refuse to

deal with another competitor, a supplier
or a customer.
0
52
BP02101
If you have questions or concerns

about com petition laws, talk to your line
manager, Legal or Ethics & Compliance.
For additional information, see the
BP Group Com petition and Antitrust
Standard and other related guidelineslinks provided in the Appendix.
0
53
BP02102
BP Code of Conduct
Complying with trade

restrictions, export controls
and anti-boycott laws
At a glance
BP is aUK-based company
with significant business in
the US and the EU. We always
comply with the applicable laws
governing trade restrictions of the
countries in which we operate
unless those laws conflict with
the laws of the US, the UK or
other EU countries. Consult Legal
in the case of a conflict or if you
are not sure if there is a conflict. .
We also comply with all legally
mandated controls on the export
and the end use of certain
products, technology, software
and services.
In detail
From time to time some countries
impose trade restrictions covering specified
countries, entities and individuals. This may
include the US, UK and other EU countries.
They also periodically impose controls on the
export and the end use of certain products,
technology, software and services.
The penalties for breaking these laws, which
sometimes apply outside the legislating
country, can be very serious. Penalties
include fines, debarment from working on
government contracts, revocation of permits
to export, and imprisonment.
Trade restrictions typically cover:
Exports or re-exports to a prohibited or
sanctioned country, entity or individual
without the appropriate licence or
authorization.
Imports or property dealings from,
or originating in, a sanctioned country.
Imports or property dealings with
a sanctioned entity or individual.
Business dealings with a sanctioned
country, entity or individual.
The transfer of restricted software,
technical data or technology without a
licence- by email, download or disclosure
to people in or from sanctioned countries.
Product classifications, export controls

and lists of restricted individuals, entities
and countries change regularly. If you
are involved in the sale or shipment of
products, technologies or services across
country borders, make sure you know the
relevant rules, and check with Legal for
any updates or advice you might need.
Always
Follow the Group Trade Sanctions
Standard and any additional requirements
that apply to your specific business
activities.
Consult with Legal immediately if you
are asked to deal with a sanctioned or
restricted country, entity or individual.
Make sure that products and technology
for import or export are classified in
advance. Use the relevant country control
list to determine licensing requirements.
Make sure that all required labelling,
documentation, licences and approvals
are in place. Contact Legal for assistance
and legal advice.
Ensure that all transaction parties are
screened against the relevant restricted
party lists.
The provision of defence-related

services or export of articles or services
designed or adapted for military or other
restricted end use, without a licence or
authorization.
The prohibition of certain boycott activities
-for example, US anti-boycott laws.
0
54
BP02103
Breaching trade restrictions and export

controls can have serious consequences.
If you have any questions about these
laws, contact Legal.
For more guidance, please see the
'Preventing money laundering' section
of this Code.
For more information, the BPGroup
Standard on Trade Sanctions and
associated frequently asked questions
are available- see link in the Appendix.
. ::
A.
.
be
shipped from the ljS, y()Liwill need
. tiif()llow US export jaws. Youmust
check with
US cpunterparts to
.find out whi:ither y()il.pe$d e1<port
licences forshippingthe products
1r6m the UStoctilila: Even it you had
usoriginprooucts in stock in your
local country you wouldstill have to
follaw us export laws they apply
in countries beyorid the US.
0
55
BP Code of Conduct
c
Preventing money
laundering
them look as though they are legitimate. This includes concealing

the criminal origin of money or other property- sometimes called
the proceeds of crime- within legitimate business activities. It also
covers the use of legitimate funds to support crime or terrorism.
We never condone, facilitate or support money laundering,
which means:
and regulations.
Always
FollowtheBPGroupAnti-Money
Laundering Standard and any additional
requirements that apply to your specific
business activities.
Conduct appropriate risk-based
due diligence enquiries about both
counterparties and the property
(e.g. funds, goods, etc.) that BP receives.
Take reasonable and appropriate actions
to assess the integrity of counterparties.
laundering policies and practices. These are designed to avoid

receiving, or being involved in an arrangement or transaction
that relates to, funds that may be the proceeds of crime.
assess the integrity of our business counterparties.
Counterparty means any party that BP does business with nON
or intends to do business with in the future, either on a regular
or one-off basis. Counterparties include customers, contractors,
suppliers, agents, professional advisers, JV partners and any
other business partners.
Monitorcounterparties' dealings and

activities with BPfor suspicion of money
laundering or financial crime.
Watch out for.
-Any situation where the counterpartywill
not provide details of its ownership, or
where you cannot identify its ownership.
-Irregularities in the way payments
are made.
-Counterparties whose behaviour raises
questions over their integrity.
0
56
BP02105
Be wary of either attempts to make,

or request, payments:
-In currencies other than those
specified in the invoice or contract.
-To or from other countries with no
apparent connection to the business.
-In cash or cash equivalents.
-By or to someone not party to the
transaction.
-To or from an account other than the
normal business relationship account.
-With multiple cheques or drafts.
-Where you recognize that there are
overpayments.
-Involving unknown or unnecessary
intermediaries unless you are clear
about their role.
-With unnecessary complexity or no
obvious legitimate business purpose.
-Involving high-risk countries or
counterparties.
Report concerns about transactions or
activities by anycounterpartytoyour line
manager and Legal.
Contact Legal if a potential counterparty
refuses to provide information about its
identity, ownership or transaction details
when they are asked.
Contact Legal or Ethics & Compliance if
you have any concerns about or possible
involvement in the types of activities
described under 'never' in this section
of our Code. Equally, contact Legal or
Ethics & Compliance if you have any other
questions about money laundering.

Never
Do business with anyone known or
suspected of wrongdoing relating to
dealings with BPorthird parties, unless
those suspicions are appropriately
reviewed and resolved.
Discuss suspicions of money laundering
with a counterparty unless you are
authorized by Legal to do so. You could
impede a proper investigation and/or
commit an offence of 'tipping off' in
some jurisdictions if you fail to get prior
approval from Legal.
Conceal or disguise monies that may
be the proceeds of crime.
Become involved in an arrangement
that may involve criminal property or
the proceeds of crime.
The above rules are not a substitute for
using good judgement and common
sense when assessing the integrity of
counterparties.
For further guidance, see the BP Group

is provided in the Appendix.
0
57
BP Code of Conduct
c
Working with suppliers
Our suppliers are important to us, underpinning our ability to do

business and meet our customers' expectations.
That is why we choose them carefully, using a transparent selection
process based on objective criteria and evidence.
Fundamental to our relationships with suppliers is that they operate
according to principles that are similar to those in this Code. This
includes making a contractual commitment where it is feasible
to follow the principles of our Code, as well as our ethics and
compliance requirements.

Always
o
Use an objective process to source and

select suppliers.
Avoid conflicts of interest, inappropriate

gifts and entertainment, or any kind of
favouritism that might compromise
supplier selection.
Work only v0th suppliers who comply

with all legal requirements. They must
willingly make a contractual commitment
where it is feasible to operate in line with
the principles of this Code and our ethics
and compliance requirements.
Conduct due diligence on new suppliers

and agents acting on behalf of BP.
Screen suppliers against restricted party

lists, in line with the 'Preventing money
laundering' and 'Complying with trade
restrictions, export controls and antiboycott laws' sections of this Code.
Help suppliers understand our

expectation that they will provide the
BP Code and details of OpenTalk to all of
their employees working on BP business.
Be alert and report to your line manager

any activity- or any suspicion of activity
by suppliers that are inconsistent with
BP's expectations concerning our Code.
0
58
BP02107

Never
Accept gifts and entertainment
from parties engaged in a tender or
competitive bidding process that you
are engaged in, unless you receive prior
approval from Ethics & Compliance.
Share one supplier's confidential business
information (for example, proposed rates,
winning bid information or qualification
criteria) with any other supplier.
Note: There may be further rules covering
the way you work with suppliers -for
example, laws or regulations, government
contract requirements or JV polides.
Please make sure you know the rules
that apply in your business and country.
Sections in this Code that are also

relevant are: 'Appropriately exchanging
gifts and entertainment', 'Preventing
conflicts of interest', 'Eliminating bribery
and corruption', 'Preventing money
laundering', and 'Complying with trade
restrictions, export controls and antiboycott laws'.
To help keep our standards high and
our supply chain strong, always tell
your local procurement manager if
any supplier fails to respect our Code.
Code breaches should be reported in
the breach database- see Appendix
for the link.
0
59
BP02108
0_
BP Code of Conduct
c
Eliminating bribery
and corruption
At a glance
We do not engage in bribery or corruption in any form, whether
in the private or public sector. This means:
promise, give or accept a bribe, kickback or any other improper

payment- including 'facilitation' payments.
lndetail
The definition of bribery is offering, promising,
giving, receiving or soliciting anything of value
in order to influence how someone carries
out a public, commercial or legal duty. This
includes attempts to do any of the above.
and corruption, and we do everything we can to make sure our

suppliers, contractors and joint venture partners do the same.
Breaching anti-bribery and anti-corruption

laws is a serious offence. Companies and
individuals breaching these laws may be
punished by fines, and individuals also
face imprisonment.
be asked to comply with applicable bribery and corruption laws.

Where appropriate, they must show that they have appropriate
programmes to prevent bribery in place.
Most countries have laws prohibiting

bribery and corruption. These often cover
actions carried out beyond the country's
borders- such as bribes paid to someone
in another country.
,. '/\!';)never allow 'facilitation' or 'grease' payments to government

officials by anyone who works for BP or anyone acting for us.
This applies no matter how small the amounts are. Facilitation
payments are payments made to a government official to secure
or speed up routine, non-discretionary, legal government actions,
such as issuing permits or releasing goods held in customs.
Everyone at BP must comply with these

laws. Even something that can be perceived
to breach anti-bribery or anti-corruption laws
can damage our reputation.
regardless of whether the recipient is a government official

or a private business person.
0
66
BP02115
The governments and oommunhies we work with
Anti-bribery and anti-corruption laws:

Prohibit offering or providing payments,
services, gifts, entertainment or 'anything
of value' to government officials and
private individuals to improperly influence
them, to obtain or retain business, or to
gain a business advantage.
Forbid making improper payments
through third parties.
Require companies to keep accurate
books and records- and maintain
adequate internal controls-sothat
payments are honestly described and
company funds are not used for
unlawful purposes.
Mean that BP may have committed
an offence if it fails to prevent bribery
by someone acting on its behalf.
'Anything of value' includes any type of
benefit to the recipient. This includes cash,
loans, gifts, jobs, tuition, scholarships,
entertainment. travel and contributions.lt
also covers intangible benefits-for exam pie,
hiring someone's relative or donating to their
favourite charity with an improper intent.
The 'Appropriately exchanging gifts and
entertainment'
section of this Code of Conduct aims to
reduce the risk that gifts or entertainment
could be perceived as a bribe.
'Someone acting on BP's behalf could

include employees, contractors, agents,
joint ventures, suppliers or subsidiaries.
'Government Officials' includes any minister,
elected or appointed official, director, officer
or employee of any government (whether
at a national, state/provincial or local level)
or any department, agency or instrument
of it, and/or of any enterprise in which a
government owns an interest, and/or of any
public international organization. This term
also includes any person acting in any official,
administrative, legislative or judicial capacity
for or on behalf of any such government
or department, agency, instrument of it,
company, or public international organization.
Also included are political party officials and
candidates for public office. Any officer or
employee of a national oil company, national
airline, national railway or national shipping
company is deemed to be a government
official, as are members of customs, military
or police organizations.
0
67
BP02116
BP Code of Conduct
c
Eliminating bribery
and corruption (cont.)
Never
Always
o
Follow the Group Anti-Bribery and

Corruption Standard and all anti-bribery
and corruption procedures operating in
your business or function.
Use due diligence when you are selecting

and monitoring agents, consultants,
contractors, suppliers, joint venture
partners, other business partners or
service providers.
Consider whether the above are suitable

counterparties for BP and include
appropriate contractual terms in
agreements to prevent bribery.
Obtain approval from Legal before
agreeing to pay for or reimburse travel
expenses (transportation, lodging,
meals, and incidental travel costs)
of government officials or agreeing
to pay a per diem in connection with
a government official's travel.
Offer, authorize, condone, promise,

solicit, accept or make an unauthorized or
improper payment (in cash or otherwise).
Attempt to induce a government official

or private person to do something illegal.
Intentionally overlook or fail to report any
indication of an improper payment.
Offer or receive money, gifts, kickbacks,
commissions or anything else of value
to improperly win business or secure a
contract.
Establish an unrecorded 'slush' fund for
any purpose.
Induce or help coerce someone else to
break these rules.
You can get more detailed information by

referring to the Group Anti-Bribery and
Corruption Standard and our Anti-bribery
and corruption website- or by talking with
members of Legal or Ethics & Compliance.
If you are involved in a business where
there is a risk of bribery or corruption, you
need to contact Legal to make sure you
understand the requirements that apply
to your business activities.
C)
You will also find more information under

'Accurate and complete information, records,
reporting and accounting', 'Appropriately
exchanging gifts and entertainment',
'Dealing with governments' and' Preventing
money laundering' in this Code.
Permit an agent, representative or other

third party acting forB Pto take questionable
actions or bribe anyone. That is, you should
never 'look the other way'.
Use BP's influence to encourage our

agents, consultants, contractors, suppliers,
joint venture partners, other business
partners and service providers to adopt a
similar approach to bribery and corruption
as is set out in this Code.
0
68
BP02117
The governments and communities we work with
0
69
BP02118
BP Code of Conduct
c
Dealing with governments
Being open and transparent about

our business and performancegood and bad -builds trust in BP
and encourages people to do
business with us.
As a BP employee you must
make sure that any information
you give to government or
regulatory officials is true and
accurate, and that our legitimate
business interests are protected.
This applies whenever you
have contact with government
officials during your work. It also
applies if you are asked to provide
information in connection with
a government or regulatory
agency enquiry or investigation.

Always
Co-operate courteously with officials
conducting a government or regulatory
agency enquiry or investigation.
Notify and obtain advice from your
line manager, Legal and your local
Communications and External Affairs
team before responding to any nonroutine request for information from a
government or regulatory agency. This
includes any request other than those
required by normal government processes
such as standard bid award processes and
proceedings that are on the public record.
Make sure that records and information
relevant to any government or regulatory
agency enquiry or any litigation are
preserved. Ensure that any automatic
systems, including electronic systems,
for record disposal are stopped to avoid
the destruction of the relevant records and
information relating to such circumstances.

Never
Mislead an investigator ora government
or regulatory official.
Attempt to obstruct the collection of
information, data, testimony or records
by properly authorized government or
regulatory officials. When in doubt,
consult Legal.
Conceal, alter or destroy documents,
information or records that are subject to
litigation or an investigation, enquiry or
official proceeding. When in doubt,
consult Legal.
Attempt to hinder any employee from
providing accurate information.
Retaliate against anyone who
co-operates with the government
or regulatory agencies.
Find out more under 'Accurate and

complete information, records, reporting
and accounting' in this Code.
0
70
BP02119
Engaging with communities

and respecting their
rights and dignity
We want to make a positive
difference wherever we do
business.
We hold ourselves to the highest
ethical standards and behave
in ways which earn the trust
of communities in which we
operate. We work hard to create
open and sincere relationships
with local communities, as well
as with bodies such as nongovernmental organizations
(NGOs) who have a legitimate
interest in what we do as a
company. We respect the rights
and dignity of communities,
NGOs and other organizations
with whom we interact.
Always
Comply with local laws and regulations
wherever you work.
Work in a way that is consistent with local
cultures and business customs, as long
as they do not conflict with this Code and
legal requirements.
Treat community members with dignity
and respect their rights. Be sensitive to
the unique situation and vulnerability of
indigenous peoples.
Recruit qualified local personnel where
it is pr actica I.
Notify your line manager and your local
team before you engage in dialogue or
contact with NGOs.
We encourage local community
development initiatives and civic causes
which create mutual advantage for BP
and the community or country. We
support employee participation in them,
if appropriate. If you are involved in any
way, avoid any real or perceived conflicts
of interest.
For further information, see the 'Preventing
conflicts of interest' section of this Code.
0
71
BP02120
BP Code of Conduct
Communicating with
investors, analysts
and the media
Communications with investors, analysts and the media require
care and a good understanding of legal and media issues.
Anyone contravening regulations- such as those governing the
selective disclosure of non-public information- makes themselves
and BP liable to prosecution.
Only authorized employees should respond to enquiries from
members of the investment community- for example, shareholders,
brokers and analysts -or the media.

Always
Take advice from the Press Office or
Investor Relations before talking about
company matters with a reporter or
analyst, either on or off the record.
o
Report enquiries promptly to the Press

Office or Investor Relations as appropriate,
and take their advice before you naspond.
Obtain clearance from senior

management, in consultation with your
local Communications and External Affairs
team, before undertaking any non-financial
formal speaking engagements on behalf
of the company.
Ensure your line manager reviews
external presentations, even when the
venue seems informal'- such as a trade
association event.
o
Take care notto cause any harm to the

reputation of the BP group in any external
communication.
Include a simple and visible disclaimer

stating, 'These are my personal views and
not those of BP', on any personal blog or
other website that clearly identifies that
you work for BP.
0
72
BP02121

Never
Make any statement of BP's existing
financial results and forward-looking
financial statements unless you are a
properly authorized officer of the company.
It is the job of our Press Office and Investor

Relations to make sure we communicate
with all our key external audiences in a
consistent and co-ordinated way.
about communications and external
affairs, talk them through with your line
manager or local Communications and
External Affairs team.
0
73
BP02122
BP Code of Conduct
c
Our stance on
political activity
Wherever we do business, our approach to corporate political
activity is clear and uncompromising:
* FP v/d nottake part directly in party political activity.

., UP v,dl r::::;ke no political contributions- either in cash or in kind.
We recognize our employees' right totake part as individuals in
the political process. in ways that are appropriate to each country.
Employees who do this must make it clear that they do not
represent BP.
Although we do not directly take part in party politics, we do engage
in policy debate on subjects of legitimate concern to our company,
our staff and the communities in which we operate in various ways,
including lobbying. Lobbying activity on behalf of BP's interests is
highly regulated and should only be done by authorized people.

Always
Make it clear that your individual political
views and actions are personal and
notBP's.
Inform your line manager if your political
activities or a close relative's activities
might create a conflict of interest, or the
appearance of impropriety.
Notify your line manager in advance if
you plan to seek or accept a public office.
Discuss how any official duties might
affectyourworkwith BP, and work
constructively with your manager to
minimize any adverse impact on your job.
Consult your line manager before any nonroutine contact is made with government
officials or employees by you or others
representing BP's interests. This includes
contacts relating to government policy or
legal/regulatory changes. This requirement
does not apply to contacts required by
normal government processes such
as standard bid award processes and
proceedings that are on the public record.
0
74
BP02123
("I
Basic rules youmustfollow

Never
Use company time, property or equipment
to carry out or support your personal
political activities. Ensure that you only
engage in the political process in your own
time and with your own resources.
().
Undertake lobbying activities without

authorization.
Contact your line manager or local

team if you are not sure whether an activity
is appropriate or might be misinterpreted.
Or if you would rathertalktosomeone
independent in confidence, get in touch
with OpenTalk.
See also 'Preventing conflicts of interest'
and 'Dealing with governments' in this Code.
0
75
BP02124
c.
BP Code of Conduct
Accurate and complete

information, records,
reporting and accounting
Ataglance
We record and report company information honestly, accurately
and objectively. This includes financial and non-financial information.
Any information we create will accurately reflect transactions and

events. This includes financial data and other information such as
HSSE performance information or HR records.
Our books, records and accounts conform to IFRS (for group
financial reporting), and other relevant GAAP and BP accounting
and reporting policies.
We create, retain, and destroy paper and electronic information
in line with the applicable laws and BP requirements.
Falsifying records or misrepresenting facts can never be justified
or excused. BP does not tolerate any kind of fraud.
In detail
Recording and reporting any financial or

non-financial company information honestly,
accurately and objectively is essential to:
Protecting our credibility and reputation.
Meeting our legal and regulatory obligations.
Meeting our responsibility to shareholders
and other external stakeholders.
Informing and supporting our business
decisions and actions.
Q_
Any information you create for BP must

accurately reflect transactions and events.
This information may be in the form of paper
or electronic documents, em ails or other
media. It includes:
Financial data such as books, records and
accounts. These must always conform
to IFRS (for group financial reporting), and
other relevant GAAP and BP accounting
and reporting policies.
Other information such as HSSE
performance information, HR records,
quality data, regulatory filings and other
essential company information. This must
also be accurate and complete.
Any information you create or receive while
working for BP belongs to the company.
It must be managed and protected properly.
0
62.
BP02131
Our assets and financial integrity
Paper and electronic information must be

created, retained and destroyed in line with:
Always
Applicable law.
BP's data privacy rules.
BP's policies on document management,
including e-documents and email.
The Security of Information Handling
Standard and Instructions.
The Digital Systems Acceptable Use

Instruction.
The Operating Management System.
t is against BP policy to fail to keep accurate
and complete records, falsify information,
or create misleading information. It could
constitute fraud or an infringement of human
rights which could mean civil and criminal
liability for individual employees and BP.
Ensure all transactions are properly

authorized and recorded accurately
and completely.
Ensure all counterparties are appropriately
authorized and set up in the company's
systems. This includes customers,
suppliers, agents, professional advisers,
JV partners and any other business
partners. Be alert to unauthorized payments
or invoices as described in the 'Preventing
money laundering' section of this Code.
. Senior financial officers and others

responsible for financial and management
reports have additional responsibilities to:
Establish and maintain proper controls to
ensure financial and management reports
are truthful, accurate, complete, objective,
consistent, timely and understandable.
Ensure that the applicable external and
internal reporting standards in BP's Group
Reporting Manual (GRM) are followed at
all times.
Understand and follow applicable
standards for creating, retaining and
destroying BPinformation.
Ensure that no undisclosed or unrecorded

amount, fund or asset is established or
maintained.
Co-operate fully with Internal Audit, Group
Control and external auditors providing them
with accurate information. If requested
allow them unrestricted access to staff and
documents (subject to legal constraints).
Complete and approve expense claims
accurately, and in accordance with the BP
Travel and Entertainment Expense Policy.
Report any concerns or irregularities in
respect of accounting, auditing or internal
controls matters.
0
83
BP021
Accurate and complete

information, records,
reporting and accounting (cont.)
Never
Make a deliberately false or misleading
entry in a report, document, record or
expense claim.
Falsify any document or record, whether
it is finandal or non-financial.
Sell, transfer or dispose of company
assets without the proper documentation
and authorization.
Try to influence others to do anything that
would compromise the integrity of BP's
financial records or reports.
Commit BP to contractual obligations
unless you are authorized to do so.
Conceal, alter, destroy or otherwise tamper
with BP information or property relating to
actual, pending or threatened litigation or
government/regulatory investigations.
This requirement also applies in situations
where litigation or an investigation is
reasonably likely to occur in the future.
If you are ever concerned about the validity

of any information, entry or financial process,
or think you might have been asked to create
false or misleading information, you need to
raise your concern immediately. Talk to your
line manager or contact your Chief Financial
Officer (CFO) if you are not sure how to
recorda transaction properly.lftheycannot
resolve your concern, take it to a subject
matter expert in Finance.
lfyou are worried that a transaction is
being, or has been, improperly recorded,
you need to tell your CFO without delay so
that management can intervene as soon
as possible.
If you ever feel the need to talk to someone
in confidence who is independent, contact
OpenTalk or any alternative local resource
you may have.
..,....,,::1 j
G f:):.:p
ti\':
Obstruct or influence the proper

administration of any matter within the
jurisdiction of any regulator. This might
include concealing, altering, destroying
or tampering with BP information.
Remove or destroy records before the
specified date without first obtaining
permission.
0
84
BP02133
0
85
BP021
BPCodeofConduct
Protecting BP's assets
Ataglance
Everyone at BP is responsible
for making sure our assets are
not misused or wasted. Our
assets include property, time,
proprietary information, corporate
opportunities, company funds,
and company equipment.
As a BP employee, this means

you must always:
you use, or have contact with,
is not damaged, misused or
wasted.
Other confidential business information

that also comes under intellectual property
includes:
In detail
Company property
You are personally responsible for making
sure that any BP property you use, or have
contact with, is not damaged, misused or
wasted. This includes portable or homeworking equipment that BP might issue to
you -for example, laptops, personal digital
assistants (PDAs) and mobile phones.
You can have limited, occasional or incidental
personal use of certain company equipment
issued to you. For example, this might include
a phone call to check in with a child care
provider, or to let your family know you are
working late. You must follow any specific
rules at your work location as these may
include further requirements.
and proprietary information

and intellectual property.
business interests when
the opportunities arise.
Marketing strategies and plans.

Research and technical data.
Business ideas, processes, proposals
or strategies.
New product and/or package design
and development.
Software bought or developed by the
company.
Information used in trading activities
including pricing, marketing and
customer strategies.
Corporate opportunities
Company time
work to fulfil your responsibilities.
Sales, marketing and other corporate

databases.
As a BP employee you are expected to give

the time needed to your work to fulfil your job
responsibilities.
Everyone at BP shares a responsibility to

advance our legitimate business interests
when opportunities come up.
Intellectual property and other protected

information
From inventions to trademarks, our intellectual
property is valuable to us. Various laws enable
us to protect it from abuse by people outside
the company.
Intellectual property includes:
Patented inventions.
Designs.
Copyright materials.
Trademarks and service marks.
Trade secrets and know-how.
0
86
BP02135

Always

Never
Take reasonable care of BPproperty at

all times, making sure it is not lost or put
at risk of theft.
Use any company equipment or facilities

for your personal activities except as
noted above.
Report lost or stolen computer or

telecommunications equipment to
Digital Security.
Share confidential or proprietary information

with people outside BP unless you have
obtained your manager's prior approval
to do so. Even then, you must only share
information under a written confidentiality
agreement approved by Legal.
Engage fully in BP business while at work

and not undertake personal activities.
. - - Report the time you work truthfully and

accurately, if you are required to report
your time.
Protect and never disclose any confidential

or proprietary BP information. This
obligation applies during and after your
employment with BP.
Understand and follow the BP instructions
for the classification and protection of
information, which are given in the
Security of Information Handling Standard
and Instructions.
Protect personal information -see also
the 'Protecting privacy and confidentiality'
section of this Code.
Take the same care of BPfunds as you
would your own. This includes money
advanced to you and any procurement or
credit cards. Protect them from misuse.
loss. fraud or theft.
Submit accurate claims, vouchers, bills and
invoices within the established times.
Use BP property, information or position

for personal gain.
Compete with BP.
If you have any questions about protecting

BP assets, talk to your line manager or Legal.
You can find out more about our Security
of Information Handling Standard and
Instructions by talking to your regional
security adviser, or visiting the BP Digital
security section of the website- see
Appendix for detai Is.
You will find details on personal use of
BP networks and computers under
'Using our digital systems responsibly
and securely' in this Code.
busines? onlY, notpersonal.activitias.. .
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rriav
be valiC!if it is Gsed
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0
87
BP021
BPCode of Conduct
Respecting intellectual property

and protected information
We are committed to respecting
the intellectual property and
protected information of others.
Always
Consult Legal when assigning work to a
new employee if there is a risk that the
employee might use protected information
from a prior employer.
Consult Legal to determine whether
local copyright law may allow you to copy
brief excerpts of documents or materials
(including audio, video, software or
internet extracts).
Seek advice from Legal before adopting
new names for our products or services.
Consult Legal for:
-Significant new or modified products
or processes.
Basic ruies you must follow

Never
Bring confidential information, including
computer records, from prior employers
into the BPworkplace.
Load unlicensed software on to a
BP computer.
Acceptor use anyone else's confidential
information without an agreement approved
by legal.
Copy documents or materials (including
audio, video, software or internet extracts)
for which we do not hold the copyright,
unless you received permission to do so.
Knowingly act in disregard of the valid
intellectual property rights of another party.
-Interpretation of patents.
- Patent applications or other intellectual
property rights.
0
88
BP02137
If you have any questions, discuss

them with your line manager or Legal.
0
89
BP021
BPCode of Conduct
Avoiding insider dealing
Ataglance
We are committed to supporting fair, open securities markets
around the world. This means that
securities of BP or any other publicly traded company while having

'inside information'.
or engaging in other activities designed to manipulate the price of
publicly traded securities.
Our Global Trading Guidelines include specific requirements to
protect against market abuse. These apply to anyone involved in
trading activities in BP
In detail
'Inside information' means any information

that is not generally available to the public,
and is material. This applies to any information
that relates directly or indirectly to BP or its
securities or to any other publicly traded
company or its securities.
Material information includes information
that may have or is likely to have a significant
effect on the price of securities. A matter is
also material if there is a substantial likelihood
that a reasonable person would consider it
important in making an investment decision.
Securities include shares (including American
Depository Receipts), options, debt, bonds,
notes and other investments whose value is
determined by the price of such securitiesfor example, futures or other derivatives,
or spread bets.
Here are some examples of what might
constitute inside information:
Group results and dividends.
Actual or potential material acquisitions,
divestments, mergers or joint ventures.
Major developments in material litigation.
Actual or potential material discoveries of,
or adjustments to, oil and gas reserves.
Anticipated significant action by
governments.
0
90
BP02139
In countries such as the UK, even knowing

a rumour is false can mean you have inside
information if that rum our would be material
if it were true. Always check with your
line manager or Legal before trading with
knowledge ofthe accuracy of market rumours.
Insider dealing laws are enforced around
the world. Breaches are taken very seriously
and the penalties are severe, ranging from
substantial fines to imprisonment.
Market abuse is also illegal. This means

spreading false information or engaging
in other activities designed to manipulate
the price of publicly traded securities. Our
31obal Trading Guidelines include specific
requirements to protect against market
abuse, which apply to anyone engaged in
trading activities in BP.
BP is legally required to keep a list of all
employees who have access to inside
information about BP or our securities,
and we may be required to disclose this
list to the regulatory authorities.
0
91
BP0214
BPCodeofConduct
Avoiding insider dealing (cont.)

Always
Be careful and protect inside information
from accidental disclosure.
Note: Certain BP employees who have
access to inside information need approval
from the Company Secretary before they
engage in any transactions in BP securities.
See the Appendix for the link to 'Restrictions
on dealing in BP shares and securities'.

Never
BuyorseiiBPsharesorengageinany
other dealings in BP shares while you are
in possession of inside information. That is
either directly or through family members,
or by encouraging others to do so. This
applies even if you 'think' you are not relying
on it or if you are no longer a BP employee.
Buy or sell shares of any other publicly
traded company, or engage in any other
dealings in that company's shares while
you are in possession of inside information.
That is either directly or through family
members, or by encouraging others to do
so. This applies even if you 'think' you are
not relying on it.
Disclose inside information to anyone

outside BP. including family members,
without prior approval. Within BP, disclose
inside information only on a need to know
basis and with prior approval. If you disclose
inside information to another person who
then deals in securities on that basis, you
will both beguiltyof an offence.
Spread false information or engage in other
activities to manipulate the price of publicly
listed securities.
Leak inside information or tip someone off.
This can be a violation of insider dealing laws.
o_
Encourage anyone else to deal publicly listed

securities while you have inside information.
This can constitute a criminal offence.
Buy or sell securities until inside information

concerning the company or its securities
becomes generally available and investors
have had an opportunity to evaluate the
information.ln some cases, you will need
to obtain approval from the Company
Secretary (see the note under 'always').
0
92
BP02141

about insider dealing, contact Legal for
more guidance.
Answers to frequently asked questions
on insider dealing are available on the
BPwebsite- see Appendix for link.
A.
.
. .... . . ...
wish to deal for a reason uncoririeCted
with the information you have;
0
93
BP02142
BP Code of Conduct
Using our digital systems

responsibly and securely
Ataglance
The security of our information and digital systems is essential to
our success.
Anyone who uses BP digital assets must know how to keep

them secure by following the requirements in BP's Digital Security
Acceptable Use Instruction and the Security of Information Handling
Standard and Instructions- see Appendix for links.
In detail
At BPwe keep our information and digital

assets secure by incorporating security
controls into how we manage our people,
business processes and technology.
These controls ensure that:
We can protect the confidentiality, integrity
and availability of important information
and digital assets.
Only authorized users are able to access
BP's computers and network services
such as the internet, email applications
and network file directories.
Authorized users can only access the
digital assets they need to fulfil their job
responsibilities.
Access to BP's digital assets can be
monitored to prevent misuse of an asset,
or unauthorized access to it.
We comply with all applicable legal,
regulatory and contractual requirements
relevant to keeping our information and
digital assets secure.
0
94
BP02143

Always
Keep computer equipment safe and secure
at all.times. This includes laptops, smart
phones and storage devices. This also
applies when you are working away from BP
premises, for example at home or 1n a hotel.
Protect your user IDs and passwords. Make

sure your passwords are difficult to guess
and change them regularly. Never share
your passwords or personal identification
numbers (PINs), or allow anyone else to
use your user account.
Keep information secure during storage,
distribution and disposal. Follow the
Security of Information Handling Standard
and Instructions to ensure that you know
how to classify information correctly.
Use email, internet services and BP-issued
computer equipment in line with the Digital
Security Acceptable Use Instruction.
Use BP-issued computer equipment and

technology services such as email or the
internet primarily for business purposes.
You can have limited personal use of our
digital systems and services. For example,
you can use them:
-To access internet news, weather, holiday
planning or travel information sites.
-To access your personal web-based email
account, as long as the email service is
approved by BP- see the Digital Security
website for a list of approved email
providers who have sufficient levels
of security.
-To access social media sites. However,
your usage must conform to BP's Digital
Security Acceptable Use Instruction,
and the content you post must represent
your own personal views only and not
those of BP.
Report incidents immediately. If you
suspect an incident has happened or is
aboutto happen (e.g. suspected virus,
suspicious phone call, lost laptop or
information), contact the BP helpdesk
or Digital Security.
0
95
BP02144
BP Code of Conduct
c
Using our digital systems
responsibly and securely (cont.)
Never
Copy or transfer BP confidential or secret
information onto a portable storage device
such as a memory stick, unless that device
is approved and you have the permission
of the business process owner. If you do
have the required approvals and permission,
the storage device must be encrypted
and handled in line with the Security
Instructions.
Use your personal email address to
distribute BP information, or use it in place
of your BP email account.
Discuss BP confidential or secret business
information in public places where you
might be overheard.
Leave BP confidential or secret business
documents or storage devices unattended.
Install or use unauthorized or banned
software.
Use BP computers for personal use that:

-Prevents or displaces our business
activities.
-Adversely affects the availability of any
BP resources, including networks.
-Interferes with your productivity, or that
of your colleagues.
-Involves any non-BP enterprise, including
soliciting business from other employees.
-Damages BP's reputation or puts the
company in an unflattering light.
Deliberately access, store, post or publish
any ofthe following through our digital
systems or on our premises:
Please make sure you know the

requirements in our Digital Security
Acceptable Use Instruction, and the Security
Instructions- see the Appendix for the link.
If you need more infonnnation about digital
systems use and security, talk to your line
manager or BP Digital Security.
See also the 'Protecting privacy and
confidentiality' and 'Protecting BP's assets'
and 'Creating a respectful, harassment-free
workplace' sections of this Code.
-Pornographic, sexually explicit or sexually

exploitative images or text.
-Materials promoting violence, hatred,
terrorism or intolerance of others based
on their age, race, colour, religion,
gender, national origin, sexual orientation
or disabilities, or other characteristics
protected by applicable law.
-Material that is harassing, obscene,
abusive or inconsistent with our nonharassment and equal opportunities
policies- see 'Creating a respectful,
harassment-free workplace' in this Code.
0
96
BP02145
0
97
BP021
Appendix
Section
Topic
Link
1. Operating safely,
responsibly and reliably
Safety and Operational Risk
http://safetyandoperations.bpweb.bp.com/
Office Safety
http://officesafety.bpweb.bp.com/
, ....,..,,.....,,
.....
2. Our people
3. Our business partners
0
4. The governments
and communities
we work with
5. Our assets and

financial integrity
General
.,.,.,., . ,u,....,.,.,u.,,,.,.n,'''"'''''''".,'''N.,,.,., ..,.,.,.,.N,''N.'o',C'.''N,,,,.,,,..vu.'''"''NN.'.'.',''N''''''''''"''.......... ,. ......,.,.,., ._.,.,.,.,., N ............ , . _.,.,..'.' ......,,,.o..o
.v..o,,,..,,,...o...,,..,,
N....-nu.,,.o,,,,,,.ou,
One HR Global Information

(Human Resources)
http://onehr.bpweb.BP.com/CYP/en/homepage/homepage.aspx
BP Data Privacy Rules- General

Privacy Rules
http://legal.bpweb.BP.com/Data_Privacy/DataPrivacy_BPStandardsPolicies_
BCRRules.aspx
Privacy compliance
http://legal.bpweb.BP.com/Data_Privacy/OataPrivacy.aspx
BP Gifts and Entertainment

Register website
http://gifts.bpweb.BP.com/Home.aspx
Hosting Government Officials

Approval Form
http://gifts.bpweb.BP.com/GOH/govthosting.aspx
Non-executive Director
Roles -Approval process
http://cosec.bpweb.BP..corrv'en/corpgov/neds.aspx
Global Guidelines on Handling

Relationships in the Workplace
http://onehr.bpweb.BP.com/CYP/en/onehr_relations_relationshipatwork.aspx
BP Group Competition and

Antitrust Standard
http://ethicsandcompliance.bpweb.BPcomien/local_assets/documents/Risks/
CAT_Group_Standard-Final. pdf
Global Competition and Antitrust

Guidelines
http://legal.bpweb.bp.com/competition_and_antitrust/guidelines_global.aspx
EU Competition and Antitrust

Guidelines
http://legal.bpweb.bp.com/competition_and_antitrust/guidelines_eu.aspx
US Competition and Antitrust

Guidelines
http://legal.bpweb.bp.com/competition_and_antitrust/guidelines_us.aspx
Trade Sanctions
http://ethicsandcompliance.bpweb.BP.com/en/Risks{rrade_Sanctions.aspx
BP Group Anti-Money Laundering

Standard
http://ethicsandoompliance.bpweb.BP.com/en/local_assets/documents/Risks/
BP Group Anti-Bribery and

Corruption Standard
http://ethicsandcompliance.bpweb.BP.com/en/Risks/ABC_Standard.aspx
BP Bribery and Corruption Website
http://ethicsandcompliance.bpweb.BP.com/en/Bribery_oorruption.aspx
UK Bribery Act
http://ethicsandcompliance.bpweb.BP.com/en/Risks/UK_Bribery_Act.aspx
Group Reporting Manual (GRM)
http://grm.bpweb.BP.com/
Dealing in BP Securities
http://ethicsandcompliance.bpweb.BP.com/en/Risks/dealing_with_bp_
securities.aspx
Security at BP website
http://securityatBP.bpweb.BP.com/
Security of Information Handling

Standard and Instructions
http://securityatBP.bpweb.BP.com/en/Securipedia/Securipedia_DS/Policies_
Standards/Security_of_lnformation_Standard.aspx
Digital Securi:tv Acceptable

Use Instruction
http://securityatBP.bpweb.BP.com/en/securipedia/securipedia_ds/policies_
standards/digital_security_acceptable_use_instructions.aspx
Ethics & Compliance website
http://ethicsandcompliance.bpweb.BP.com/en/homepage.aspx
Breach Reporting System
https://codeofconductcertification.bpweb.BP.com/Home.aspx
OpenTalk website
http://ethicsandcompliance.bpweb.BP.com/en/opentalk.aspx
Fraud and Misconduct Reponing

Standard
http://finance.bpweb.bp.com/en/local_assets/documents/sp/standards/fraud/
fraud-rs.pdf
99
BP02148
0-,
Code index
Actual conflict of interest
47
Corporate opportunities
86
Agents
30
Counterparties
83
Agreements with competitors
50
Courage
12
Anti-bribery or corruption
66
Anything of value
67
Dealing with governments
Apparent conflict of interest
47
Decide what's RIGHT
108
43
Derogatory remarks
32
Board directorships
46
Digital assets
94
Digital Systems Acceptable Use Instruction
83
87
Disclosing conflicts
48
Boycott activities
54
Discriminatory behaviour
31
BP International Services Company
55
Distributing trade publications
89
Diversity
30
Breaches
of code
of insider trading laws
of internet security
of record keeping
13,32,89
91
95
82
Bullying
32
Business relationships
41
Candidates for public office
67
Cash gifts or equivalent
42
Cash refunds
57
Chief Financial Officer
84
Child labour
31
Combination payment
57
Community development initiatives
71
Company assets
86
Company property
86
Companytime
86
Competing with BP
87
Competition laws
50
Competitive bids
52
Competitive information
51
Competitor pricing
52
Compliance
Doing the right thing
74
Due diligence of suppliers
58
95
Email account
Entertainment
42
Equal Opportunity
30
Ethics and Compliance Leader

Ethics&Compliance
12
Expatriates
55
Expert witness
73
Export laws
54
Exports
54
Facilitation payments
66
Fair treatment
32
Financial data
82
Foundations of our Code
10
Fundraising events
75
Generally Accepted Accounting Principles (GAAP)
Government officials
54,58,59
50
54,58,59
54,58,59
13
9,13,15
Excenence
Gifts and entertainment
Donations
Global Trading Guidelines

Complying with
anti-boycott laws
competition and antitrust laws
export controls
trade restrictions
82
42
42
42,67, 74
Governments and communities we work with
64
Grease payments
66
86
Group Anti-Bribery and Corruption Standard
68
Confidential records
34
Group
Conflicts of Interest
41,46,47
Confidential and proprietary information
43, 68, 70, 74
Declining a gift
Borrowing company equipment
51
43
Bob Dudley
Dealing with customers and suppliers
Approval limits for gifts and entertainment
Applicability of our Code
Laundering Standard
Group Competition and Antitrust Standard
Contractors
30
Group Ethics & Compliance Officer
Copyright materials
86
Group Trade Sanctions Standard
56
53
8, 15
54
101
BP02150
BPCodeofConduct
32
Hosting Approval Form
44
Offensive material
Hosting
42
One Team
12,29
OpenTalk
7,13
Health, Safety, Security and Environment (HSSE)

If not sure
21,22,23.82
108
Imports
54
Inappropriate language
32
Information sharing
51
In-kind contributions
74

Our Code
Outside jobs and affiliations
46
30
Political party officials
67
32
Preferential treatment
42
Investments
and conflicts of interest
and insider trading
Press Office
72
47
92
Preventing money laundering
72
Price discrimination
51
46
Price fixing
50
Price manipulation
90
Joint Ventures
30, 51, 52,69
Know the rules
108
55. 56, 59, 68, 83
Privacy laws
34
34
Labour and employment law
30
Privacy
Laws in conflict
55
Prohibited websites
96
Property use
86
Protected information
87
Leadership responsibilities
Lobbying
40
32
Jobs and affiliations of close relatives
108
74
Protecting privacy and confidentiality
34,87,96
Malicious behaviour
32
Malicious rumours
33
Ratione lization meeting
53
Market dominance
51
Recording gifts and entertainment
43
Market power
51
Regulatory officials
70
Marketing strategies
86
Respect
22
Material information
90
Merger control
51
Memory sticks
96
Merit
30
Mergers and acquisrtions
50
Money laundering
56
Network access
94
Non-executive Director Approval Process
47
Retainer payment
69
Non-governmental organizations
71
Retaliation
14
Raffle prize
Reporting
accident
accurate company reporting
breaches of code
digital securrty breaches
enquiries for the Press Office
harassment
lost or stolen property
transaction concerns
22,23
Intimidating work environment
Living our code
Performance conversations
33
Intimidating behaviour
Investor Relations
Offensive behaviour
Operating Management System
32
Harassment
42
22
82
13,30
95
72
32
87
57
------:..........................
0
102
BP02151
Code index
Safety
12
Sanctioned country
54
Securities
90
Security of lnfonnnation Handling StandarcJ and Instructions
87
Senior financial officers
83
Sensitive infonnnatbn
51
Sexual orientation
32
Single parents
31
Software
86
Speak up
13.108
Stock purchases
93
Stopwork
22
Trade
associations
restrictions
54
51
Trade association meeting
53
Trade secrets
86
Trademarks and service marks
86
Trading activities
86
Transactions
82
Travel Policy
83
UseriDsandpasswords
95
Waivers
108
What we do
10,12
What we stand for
What is right
11
What we value
12
Women
31
Working with suppliers
58
Zero tolerance
14
0
103
BP02152
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, , , Displays valves position

history
Displays BOP elements

health history
Emergency systems
Presents 'Traffic light' status

on the availability of key
functions:
Key Features
Simplifies and broadens the

reach of BOP diagnostics to
aid operational decisions.
Aim
:@
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, \, BP's first
in late 2012
BP02160
'' \, , Piloting on the DS-dl (w/ NOV & Ensco)
iili iii mm:
!J
:::;.;;-
nt
.- :. .,. .....
l
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;c:;<,:U.':><;:::::<::::VW;: .....,n ..
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.::.;
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1 -
'' Extend the capability to casing pressure testing in

2013
Pilot final system using BOP data on DS4 in 2012
Demonstrated early version on West Sirius (April)
Current Status
Minimizes human factors in conducting and

test.
, ... . . . . .
Senses positions of BOP elements and confirms

the actual pressure path
:, Digitally interprets the pressure test using data

at the BOP cavity
Key Features
:: Provides an independent means of witnessing

the BOP pressure tests from onshore.
.:.
10
C.):m:Hl
t.;k,..,.
.... ,
....................................... .
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,,_._,.,., .. .--,.,,,,,,,., u.,,,,,,
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Utilizes standardized processes,

procedures, and protocols
;, Monitors real-time data including pits,

flow rates, pressures, mud weight
Provides constant communication

with offshore rig teams
' Staffs 30 specialists supporting eight

ngs
Key Features
.; Enables 24/7 monitoring of well

parameters from onshore.
Aim
Extend capability to monitor other

critical activities like pressure testing
, , HMC went online in July 2011
Current Status
BP02162
bp
'
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BP's Houston Monitoring Center (HMC), enables 24/7 monitoring of

well parameters from onshore.
Remote BOP Pressure Testing provides an independent means of

witnessing the BOP pressure tests from onshore.
Real Time BOP Monitoring simplifies and broadens the reach of

BOP health diagnostics to aid operational decisions.
BP02163
.bp
BP02223
Contents
1
2
3
4
9
Introduction
The BP Goal
The role of the Board
The Board and its processes
The Board's relationship with
Executive Management
12 Appendix: Main tasks and requirements
for the Board Committees
BP02224
BP p.l.c.
Board Governance Principles
Introduction
The BP Board is responsible for the direction and oversight of BP pic (BP) on behalf of
the shareholders and is accountable to them, as owners, for all aspects of BP's business.
The Board recognises that in conducting its business, BP should be responsive to other
relevant constituencies.
The BP Board believes that good governance involves the clarity of roles and responsibilities,
and the proper utilisation of distinct skills and processes. The Board therefore focuses on
activities that enable it to promote shareholders' interests, such as the active consideration
of long-term strategy, the monitoring of executive action, and ongoing Board and executive
management succession.
that the governance of BP is best achieved by the delegation of
The Board
its authority for the executive management of BP to the Group Chief Executive (GCE)
subject to defined limits and monitoring by the Board.
To reflect this approach, these Board Governance Principles (the Board Principles)
are designed to enable the Board and the executive management to operate within
a clear governance framework.
BP 1
BP02225
BP p.l.c.
1 The BP Goal
The purpose of the Group is to maximise long-term shareholder value through

the allocation of its resources to activities in the oil, natural gas, petrochemicals
and energy businesses.
BP 2
BP02226
BP p.l.c.
2 The role of the Board
2.1 The Board's Role

The Board is collectively responsible for pursuing the BP Goal and is accountable to
shareholders for all the actions of BP
The Board's role is to govern BP by discharging its unique responsibilities. which include
those responsibilities set out in paragraphs 2.2 to 2.4 below.
In carrying out its responsibilities the Board will:
(a) focus primarily on strategic issues;
(b) have regard to economic, political and social issues and any other relevant external
matters which may influence or affect the development of BP's business; and
(c) seek to exemplify through these Board Principles (including the Executive
Limitations). its expectations for the conduct of the BP business and its employees.
2.2 Strategy
The Board will review and where appropriate determine the long term strategy
(the Strategy) and the annual plan (the P!an) for BP based on proposals made by
the GCE for achieving the BP Goal.
2.3 Monitoring
The Board will monitor the decisions and actions of the GCE and the performance
of BP including:
(a) the implementation of, and performance against, the Strategy and the Plan; and
(b) the exercise of authority delegated to the GCE.
The Board will satisfy itself that:
(a) the material risks to BP are identified and understood and that systems of
risk management. compliance and control are in place to mitigate such risks; and
(b) its expectations for the conduct of BP's business and its employees are
reflected in a set of values established by the GCE.
2.4 Succession
The Board will ensure that systems and processes are in place for the succession,
evaluation and compensation of the GCE, the Executive directors and other key
members of senior management
BP 3
BP02227
BP p.l.c.
3 The Board and its processes
3.1 Shareholders
The Board is committed to promoting the success of BP. It represents the interests
of all shareholders and seeks to act fairly between them. The Board will engage in an
appropriate dialogue with shareholders and seek to obtain the view of the shareholders
as a whole.
3.2 Board Meetings

The Board will determine the key items for its consideration for the com:ng financial
year. The agenda will be set by the Chairman in consultation with tho GCE and with
the support of the Company Secretary A similar process will be used for meetings
of Board Committees.
Dtscussion at Board meetings will be open and constructive. All discussions of the Board
and their record will be maintained in confidence unless there is a specific decision or
legal requirement to make disclosure.
In participating in Board discussions, Executive directors are expected to dtscharge their
responsibtlities as directors of BP and not to act solely as the representative of that
activity for which they bear executive responsibility.
3.3 Independent Advice

Any director is entitled to obtain independent professional advice relating to such director's
own responsibilities and the affairs of BP. Each director should obtain independent advice
where the director is required to consider any matter in which he or she may have an
interest which may conflict with the interests of the Company
Where advice is to be sought, the director will first discuss it with the Chairman or
Deputy Chairman as appropriate and, having done so, shall be free to proceed. The
director will use the Company Secretary's office to facilitate the obtaining of such advice.
s:o 4
BP02228
BP p.l.c.
3.4 Board Composition and Compensation

3.4.1 Composition, Size, Independence andTenure
The Board will comprise a mix of individuals that ensures an appropriate range of
knowledge, views and experience. The Nomination Committee will keep under review
this mix of skills and make recommendations as appropriate.
Generally, Board members will be expected to have:
(a) experience in dealing with strategic issues and long-term perspectives;
(b) leadership experience, a superior knowledge of business principles and capacity
for independent thought;
(c) an ability to participate constructively in deliberations; and
(d) a willingness to exercise authority in a collective manner.
Tenure will be determined on the basis of contribution and continued evidence of the
exercise of independent judgement. Given the annual re-election of all directors by
shareholders, the Board believes that arbitrary term limits on a director's service are
not appropriate.
Over half of the directors, excluding the Chairman, will comprise Non-Executive directors
who are determined by the Board to be independent in character and judgement and free
from any business or other relationship which could materially interfere with the exercise
of their judgement.
The Board should be of a size which enables the full engagement of all the directors.
The number of directors will not normally exceed 16.
The Board will maintain plans for the succession of the Executive and Non-Executive
directors.
3.4.2 Elections
All directors will stand for re-election by shareholders each year.
3.4.3 Terms of Engagement and Compensation
The Board wil: determine the terms of engagement and the 'evel of remu"leration paid
to its members within the limitations approved by the shareholders.
The ChairrY'an wi!l be paid a fee inclusive of all services and will receive other support
from BP appropriate
his office.
Non-Executive directors wi!l be paid a fcc determined by the Board fro'!l time to tmc.
Executive directors will not receive a fee for their service as direc:ors of BP
BP 5
BP02229
BP p.l.c.
3.4.4 Board and Director Evaluation

The Board will evaluate its own processes and performance including the work
of its committees, to ensure its on-going effectiveness as a high performing board.
This evaluation process will take place annually, in accordance with the procedures
adopted by the Board from time to time.
The performance and contribution of individual directors as members of the Board will
be reviewed periodically, with the Chairman's performance being reviewed annually.
The performance of the GCE will be monitored solely by the Non-Executive directors.
The performance of the Executive directors will be monitored by the GCE and the
Non-Executive directors.
3.4.5 Board Induction and Education
An induction programme and continuing training and education will be available to all
directors to enable them to fulfil their responsibilities as directors.
3.4.6 Other Directorships
Membership of the Board represents a significant time commitment and
Non-Executive directors must be prepared to give sufficient time for the discharge
of their BP responsibilities.
All directors should regularly inform the Board through the Company Secretary,
of other directorships they hold. The Nomination Committee will keep under review
the commitments of Non-Executive directors and make recommendations to the Board
if the Committee concludes that a director's other commitments are inconsistent
with those required by BP
All appointments of Executive directors to other boards shall be subject to the approval
of the Chairman and reported to the Board.
BP 6
BP02230
BP p.l.c.
3.5 The Chairman and Deputy Chairman

3.5.1 Appointment
The Board will appoint from among their number a Chairman and a Deputy Chairman
neither of whom will be employed executives of the Group.
The Board will develop and maintain a plan for the succession of both the Chairman
and the Deputy Chairman.
3.5.2 Role of the Chairman

The Chairman will provide leadership of the Board and will act as facilitator for meetings.
The Chairman has authority to act and speak for the Board between meetings on all
matters relating to the Board Principles and will engage with the GCE on behalf of the
Board as required. The Chairman is empowered to make any decision, establish any
policy, take any action or enter into any obligation which is consistent with the Board
Principles and, in so doing, may interpret the Board Principles in any reasonable manner.
The Chairman will report to the next meeting of the Board on any material or sensitive
exercise of this authority.
The Chairman will ensure that systems are in place to provide directors with
accurate, timely and clear information to enable the Board to consider properly all matters
before it. The Chairman is responsible for ensuring the integrity and effectiveness of the
Board Principles.
3.5.3 Role of the Deputy Chairman

The Deputy Chairman shall act for the Chairman in his absence or at his reouest.
The Deputy Chairman will normally serve as the Board's Senior Independent Director and
will be available to shareholders who have concerns that cannot be addressed through
normal channels.
BP 7
BP02231
_______
BP p.l.c.
3.6 Board Committees

The Board may at any time establish Committees of the Board to assist it in carrying out
its responsibilities. Any Committee will be subject to the Board Principles and will speak
or act for the Board only when and to the extent so authorised.
The permanent Committees of the Board include the Chairman's Committee, the Safety,
Ethics and Environment Assurance Committee (SEEAC). the Remuneration Committee,
the Audit Committee, the Results Committee and the Nomination Committee Regular
meetings of the permanent Committees will be scheduled annually.
Each permanent Committee will be comprised of those directors the Board considers
best suited to serve on that Committee. With the exception of the Results Committee, all
Committee members. including the chairman of each Committee, shall be Non-Executive
directors. The main responsibilities and requirements for the composition of the
permanent Committees are set out in the Appendix.
Any Committee may establish more detailed processes and procedures for carrying out
its responsibilities which are consistent with the Board Principles.
3.7 The Company Secretary

All Board members will have access to the advice and services of the Company
Secretary.
The Company Secretary reports to the Chairman and is responsible to the Board.
His or her appointment and removal is a matter for the Board as a whole. The Nomination
Committee will be responsible for recommending candidates for appointment as Company
Secretary and the Remuneration Committee will determine the Company Secretary's
terms of engagement and remuneration.
The Company Secretary is responsible for advising the Board and the Committees on
all governance matters, ensuring that Board procedures are followed, that the applicable
laws and regulations for the conduct of the affairs of the Board are complied with and
for all
associated with the maintenance o the Board or otherwise required for
its efiic;ent operation.
The Company Secretary will advise on and be responsible for the engagement and
retention of all independent monitoring and advisory services required by the Board
or its Committees or by individual directors.
(
BP 8
BP02232
BP p.l.c.
4 The Board's relationship with Executive

Management
4.1 Delegation to the GCE

The Board is responsible for reviewing and, where appropriate, determining the Strategy
and the monitoring of risk and performance. It delegates to the GCE authority for the
executive management of BP consistent with the BP Goal and the Executive Limitations.
The Board will hold the GCE accountable for the discharge of this authority.
The GCE will propose for Board consideration, the GCE's Strategy for achieving the
BP Goal. Annually theGCE will propose the Plan together with specific results to be
achieved during the financial year in pursuit of the BP Goal.
Through the Executive Limitations, the Board will place limits on the practices, methods,
conduct and other means by which the GCE may carry out his delegated authority for
the executive management of BP The Board will monitor the GCE's observance of the
Executive Limitations.
The GCE is authorised to establish any policy, make any decision, enter into any
obligation, take any action and develop any activity that will achieve the BP Goal
and which is within a reasonable interpretation of the Executive Limitations.
The Board may at any time change the authority of the GCE and in particular, may change
the BP Goal and the Executive Limitations. However, so long as any particulardelegation
of authority is in place, the Board will respect and support the GCE's decisions and
judgement within the proper exercise of such authority.
Decisions or instructions of individual directors or Committees of the Board do not carry
the authority of the Board, except in those instances where specific authorisation is given
by the Board (such as to the Chairman between meetings or to the Remuneration
Committee).
BP 9
BP02233
BP p.l.c.
4.2 The Executive Limitations

4.2.1 Limits on Executive Action
All GCE actions and decisions will be carried out in accordance with commonly
accepted business practice and professional ethics and within the Executive Limitations
set out below
4.2.2 General Limitations
The GCE will not engage in or cause or permit any practice, activity or decision to be
taken:
(a) without having regard to:
the health, safety and environmental consequences;
the interests of BP's employees or those of other parties doing work for BP and,
in particular, the need both to endeavour to treat them in an equitable and dignified
manner and to maintain a safe working environment;
the political consequences;
the need to foster SF's business relationships with suppliers, customers and
others; or
its effect on the reputation of BP;
(b) which represe1ts a material deviation from the Strategy and/or the Plan; and
(c) without ensuring that a system of control is in place for the prevention of conduct
which is dishonest. illegal or involves coercion.
4.2.3 Risk and Internal Control
The GCE will not cause or permit BP to operate without a comprehensive system
of controls and internal audit to identify and manage the risks that are material to BP,
to protect BP's assets and to monitor the application of BP's resources in a manner
which meets the standards of external auditors.
4.2.4 Financial Limitations
The GCE wi'l not cause or permit BP to operate in a manner wh1ch would or would be
likely, to result in BP becoming financially distressed and in particular, the GCE will not
cause or permit any of the following
(a) BP to operate outside the financia limits, authorities or ratios determined by the
Board from time to time;
(b) the allocation of capital and resources of BP unless for the purpose of meeting
the BP Goa.; or
(c) the assets of BP to be inadequately maintained, unnecessarily risked or unprotected
BP '0
BP02234
BP p.l.c.
4.3 Accountability and Monitoring

The Board will carry out its many mon1toring responsibilities through whatever means
it considers appropriate, using such internal or external sources as it deems relevant.
The GCE will report to the Board at each meeting and advise the Board (or the relevant
Board Committee) in a timely manner of all material matters currently or prospectively
affecting BP and its performance including, among others:
(a) any potential strategically or politically significant development prospects;
(b) progress on the development and implementation of the Strategy and the Plan;
(c) BP's business and financial performance including any materially under-performing
business activities and proposals to remedy the situation;
(d) any action or project that represents a material deviation from the Strategy or the Plan;
(e) any action or project (otherwise than permitted by the Strategy or the Plan) that takes
BP into a new country;
(f) any action or project (otherwise than permitted by the Plan) that will involve capital
investment or revenue commitments exceeding the amounts determined by the Board
from time to time;
(g) any failure to observe the Executive Limitations;
(h) the identification of the material risks to BP and an assessment of the effectiveness
of the controls in place to assess and manage such risks;
(i) any material political, economic or other developments in the markets where
BP operates;
(j) any material developments or issues concerning the skills and capability of the
BP business;
(k) all material matters currently or prospectively affecting the sloareholders and
the markets in which the shareholders' interests are traded;
(I) anything which may have a material adverse impact on BP's reputation; and
(m) the outcome of any agreed actions or significant developments relating to
any material agenda items considered at previous Board meetings
Between Board meetings the GCE will engage with the Chairman as the representative
of the Board as and when required 1r1 respect of those 'llallers referred to above.
(
BP 11
BP02235
BP p.l.c.
Appendix
Main Tasks and Requirements for the Board Committees
(a) Chairman's Committee (The Chairman and all Non-Executive Directors)

Evaluate the performance and the effectiveness of the GCE
Review tho structure and effectiveness of the business organisation of BP
Review the systems for senior executive development and determine the
succession plan for the GCE, the Executive directors and other senior members
of executive management
Determine any other matter which is appropriate to be considered by all of the
Non-Executive directors
Opine on any matter referred to it by the chairman of any Committee comprised
solely of Non-Executive directors
(b) Safety, Ethics and Environment Assurance Committee (Four to six

Non-Executive Directors)
Monitor and obtain assurance that the GCE's internal control system for operations
is designed and implemented effectively in support of his observance of the relevant
Executive Limitations
Monitor and obtain assurance that the management or mitigation of significant
BP risks of a non-financial nature is appropriately addressed by the GCE
Receive and review regular reports from the GCE or his delegate, the Group Internal
Auditor and the Group Compliance and Ethics Officer regarding the GCE's adherence
to the relevant Executive Limitations and his management in responding to risk
Review material to be placed before shareholders which addresses environmental,
safety and ethical performance and make recommendations to the Board about
their adoption and publication
Review reports on the Group's compliance with its Code of Conduct and on the
employee concerns programme (OpenTalk) as it relates to non-financial issues
Recommend to the Board any changes or further delineation of the Executive
Limitations in relation to non-financial matters
(c) Remuneration Committee (At least three Non-Executive Directors)
Determine on behalf of the Board the terms of engagement and remu'leration
of the GCE and the Executive directors and to report on t'lose to shareholders
Determine on behalf of the Board matters of policy over which BP has authority
re'ating to the establishment or operation of BP's pe'lsion scheme of which the
Executive directors are members
Nomina:e on behalf of the Board any trustees (or di-ectors of corporate trustees)
of such pension scheme
Rev;ew the policies being applied by the GCE in remunerating senior executives
other than Executive directors to ensure a1ignmer"J: and proportionality
BP '2
BP02236
(d) Audit Committee (Four to six Non-Executive Directors)

Monitor and obtain assurance that the GCE's internal control system is designed and
implemented effectively in support of his observance of the relevant Executive Limitations
Monitor and obtain assurance that the management or mitigation of significant BP risks
of a financial nature is appropriately addressed by the GCE
Receive and review regular reports from the GCE or his delegate, the Group Internal
Auditor and the Group Compliance and Ethics Officer which evidence the GCE's adherence
to the relevant Executive Limitations and his management in responding to risk
Monitor and obtain assurance that the legally required standards of disclosure are being
fully and fairly observed
Review all financial disclosure documents including quarterly results, annual accounts,
prospectuses, information and offering memoranda to be placed before shareholders
or filed with regulatory bodies and make recommendations to the Board about their
adoption and publication
Monitor and review the effectiveness of BP's internal audit function
Review BP's internal financial controls and its systems of internal control and
risk management
Review and monitor the external auditor's independence, objectivity and the
effectiveness of the audit process. Recommend to the Board the appointment,
re-appointment and removal of the external auditor and to approve their remuneration
and terms of engagement
Implement and monitor policy on the engagement of the external auditor to supply
non-audit services to BP
Review the systems in place (including Open Talk) to enable those who work for BP
to raise, in confidence, any concerns about possible improprieties in matters of financial
reporting or other financial :ssues and for those matters to be appropriately investigated
Recommend to the Board any changes or "urther delineation of the Executive
Limitations in relation to financial matters
(e) Results Committee (Chairman (or his Non-Executive nominee).
the GCE and the CFO)

Authorise upon the instructions of the Board, the release of the periodic financial
and divide1d announcemer1ts
(f) Nomination Committee (Chairman and the chairs of the SEEAC,

Audit and Remuneration Committees)
Identify, evaluate and recommend candidates for appointment or reappointment
as directors
Identify, evaluate and recommend candidates for appointment as Corrpany Secretary
Keep under review tho mix of knowledge, skills and experience of tho Board to
ensure t'le orderly succession of directors
Rev:ew the outside directorship/commitments of the Non-Executive di'ectors.
BP02237
BP02238
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Understand your role as an ethical leader
The business case for culture change at BP
How you can create an environment where people speak up,

listen and take action
Understand your responsibility under Our Code
BP02332
Supporting ethics and compliance activities in BP
Making sure all your team members understand the requirements of Our Code
and local legal requirements, and have the resources to adhere to them
Holding your team members accountable to behave ethically and

follow Our Code and legal requirements
Enforcing Our Code consistently
Supporting your people to ask questions and raise any ethical concerns by:
Making sure that no one who speaks up suffers retaliation
Dealing with concerns when they are raised
Encouraging them to speak up
Being a role model for ethical leadership
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Consequences and reinforcement
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People who love what they do
The value of patience, as it takes time to build greatness
A culture based on clear values, discipline or self-control
Cultural change with a clear sense of purpose
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BP02337
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Improving employee perceptions related to speaking-up
Other demographic data reveal weaker results for older, more tenured or
lower grade level employees separately
Results vary by business segment and grade level
Weakening perceptions of leadership listening behaviours
'Trust and respect' of BP management declined 6%> behind benchmark
'How the current BP values relate to me,' declined by 10%
Priority given to the code declined by 4% prior to the 'We are BP' launch
and year-end code of conduct certification
Weakening perceptions of the ethical environment
BP02338
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maragerrenl of BP
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50%
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I can speak up aoout domg the nght thmg

Without fear of reprisal
Lcacers in my part cf the busrness

rigcrously apo!y standards
Leacers in my part cf the busmess

listen carefully to all perspectives
Leaders in my pan of the business

encourage the development of capabrhty
encourage teal'l'M'Ork and collaboratron
Leaders m my part of the busrness
My supervisor emphasizes the ifl1'0rtance ot domg

the rigbt thing even wtlen .Or king under pressure
BP has created an environn'len: that encourages me

to perform to the best of my abilities
I tru:::;t ara ;espect
I unders';and how the current BP Vaives related to me
BP g1ves priorit't to the code of conduct

m pursuing the way :t does business
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2011 benchmark
of large multinational businesses: American Express. Bank af America, Google. Nation;ll Grid. Rolls--Royce, Solv;ay ;and TNT
3. BP data: PUse Survey 2008. 2009. 2011
2 Thf! 'current BP values refet"to the lhe"'-P.XIstl"'g values iProgresSive, ResponSible, Jmovahve. Performance driven). not the refreshed values released tn November(Sa1ety, Excellence. Respect. Courage. and One Team)
1. Sc01.,9 ranges ,.,a dec fer :he
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Leaders by Example
Ethical environment
Ethical leadership and culture indicators from BP Pulse surveys
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The belief that when they speak up, nothing will happen
Self-censorship
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with the situation
It's not about gender, education or income levels
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BP02349
Create a 'safe community' by listening to the quietest voice in the room
Always thank people for raising an issue and acknowledge the effort
they have made and the courage they have shown
Always be honest with people about what you are or are not going to do
with the information they have given you
Always give feedback on the outcomes; do not leave a void
Look for signs of retaliation and act immediately if you suspect it
Encourage your teams to use all available communication channels

including OpenTalk
You need to talk, you need to listen and you need to act
Be a role model and speak up yourself
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BP02350
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vocal team members regularly hijack these sessions. I 'm still finding my feet and don't
want to appear pushy ... but it's really getting frustrating and, in all honesty, some
battles are worth fighting, anyway I am not sure this is one of them. I am wondering if I
am really needed at these meetings."
"I have been a member of a small global team for a few months now. We get to meet
up twice a month and there's always a lot to get through. Despite the fact that we each
have a regular agenda item, and are all expected to contribute, a couple of the more
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to live. No wonder they are in good spirits. Apparently it's all down to James in my office.
It came as a surprise to me but he is a director of his wife's new corporate housing
business, it seems he is spending all his spare time working on his new family
enterprise, I am glad my friends have got places to go but I am not sure this feels quite
right."
telling me that after two months of constant searching they both finally found somewhere
"It's good to grab a bite and some time together. Anyway these two colleagues have
been out of the country for, well it must be about three years now and now they are
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BP02354
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available for the whole group ... so now what do I do?
for them before. So anyway I was just getting the bookings finalised when I get a call
from one of the leaders, obviously I am all ears, he has been in the company years, he
is really well respected. Anyway there are two hotels in the area and he is telling me he
wants me to arrange it that he and his team stay in the more expensive one. He says
it's got a better bar and he wants to do some team building or something but I know for
a fact that the other hotel is much cheaper has a perfectly good bar and enough rooms
"I have been asked to take care of the travel and accommodation for some leaders and
managers in my business who are all going to the same event. I know some of these
people pretty well and although I say it myself, I have organized lots of successful trips
BP02356
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Yes he is certainly a forceful character and people know that about him and I have
always taken it lightly but now there is a formal complaint and I can't just ignore it."
team members. He says he is being bullied and harassed by him and he thinks this
behavior reflects on all of us at BP. You know the thing is as his team leader I have
known him for a very long time, but I have never seen anything like this before.
"A third party contractor has just phoned to have a private word about one of my
BP02358
What is already in place that you can build on?
What are the barriers to successfully embedding?
What do you need to do to make this happen?
How can you involve others most effectively?
What support do you need from others in BP?
What do you need to do immediately?
-What do you need to do to reinforce your commitment?
/')
V\/t]
t:(:C:d ]
BP02359
HR or Legal
Ethics & Compliance Tag
Ethics & Compliance Leader (ECL)
OpenTalk
Employee Assistance Program (EAP)
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Your own line manager is usually a good place to start

but there are other resources available to you:
to
..
BP02360
,.-,
Role model - remember your commitments and responsibilities

under Our Code
Attend the Ethical Leadership training course which is mandatory

for all Gls and SLLs
Remember the impact you have as a leader- what you say

isn't always what they hear
Speak up yourself and encourage others to do so too
Always listen and always act
Deliver on commitments you make
Ask for help and guidance if needed
,li
BP02361
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Mr.

o Will continue to review

o Contactor injury rate 60/o higher compared to employees.

o Over 60o/o of the hours worked

f -to ' t ..; : :-:.---

o Exploration & Production Segment Defined Practice

o BP Group Recommended Practice

o Group-wide Operating Management System

o Group Anti Bribery and Corruption Standard

Learnings from within BP and 21 major organisations across 6 sectors:

Understand how organisations manage contractors involved in high impact activities

Phase I of the contractor management project is complete

2010 Sustainability Review;

implement a structure that drives predictable outcomes

focus on the operational activities needed to make the relationship work

We have been, and are in action on each of these 6 themes

6. Assurance that contractor personnel are competent

5. Intensive oversight and verification

4. Clear and specific contracts

3. Detailed and systematic selection of contractors

2. Fewer contractors to enable deeper, longer-term relationships

1. Consistent standards and priorities

BP leadership has identified six key themes:

value fewer, deeper, and longer relationships with contractors

o Continuing to improve our Standards

o Executive Team members review of potential high

o Our priorities are clear

o Consistent standards & priorities delivered though

Approximately 50% of overall global project spend over the next

o Executive sponsorship and regular performance reviews

o Strategic contractors identified based on risk and spend

o Focus on potential high consequence activity

o long-term integrated relationships

o Approved Vendor Lists

o Contracts governance boards established in our Developments and

- Standard contract terms and conditions

o Potential high consequence activity contracts:

o Operations shutdown, paused or delayed

o Operational inspections of Wells activities

o Safety and Operational Risk Committees established

- A recruitment programme is underway

- PSCM standard structure in place

- Commence Phase II, across the BP Group

- Linking our systems and processes together

- Updates to our systems and processes

- Implement Phase I, starting with drilling rigs.

o In action - more to do:

ancl lo cY... doVvr.

including contit11:1encv ana testing prooedures

c to de,.elo p subsea engineering oert ificat:o n

w-e II co nt rol dnd rIg saT ety-cnt rca I eq u rpme nt

-.::.; -..-.-.. ,,;,

Technical work for subsea rigs completion estimate

Rec:ommend::tt1on completion estimate

itl::::::;:;::::;::::r::;:M::::::::m:;:;::m:;:m:;::;::ltM:m:::;:::::!:tl:::::;::m:::;::;:;:t::::E:ll:J:::::;:;::;:::::::mli !Iii Ill I I[ :

We continue to make progress against

14 t 9t ab Irs h Kl-' I s t I) r \lt/e II Integ r rty.

13 Strengtt1en BP's rig audtt prooessto imprave closure and verification