BW LPG Conflict of Interest Policy

Purpose

The BW LPG Conflict of Interest Policy is to avoid any conflict between personal interests and those of BW LPG, in dealing with business associates and/or any person doing or seeking to do business with BW LPG.

Policy Statement

  • Employees must disclose any personal relationships, ownership or business interests whether direct or indirect, that they or a member of their immediate family has with any person, or in any business or enterprise that:
    • competes with BW LPG; or
    • purchases, sells, or seeks to purchase or sell, goods or services to or from BW LPG.
  • Employees must also disclose any internal personal relationships which might give rise to apparent or actual conflicts of interest.
  • Contractors, agents, temporary staff, and any other individuals empowered to make commitments on behalf of BW LPG are required to disclose to BW LPG any conflicts of interest with parties with whom there is a reasonable possibility of BW LPG conducting business.

In order to achieve this, BW LPG shall:

  • Disclosure is required for all employees through a mandatory annual disclosure process. Contractors and agents should reach out to BW LPG for disclosure.
  • Transactions involving a conflict of interest worth US$250,000 or less will be evaluated by the CEO; if the value is greater, the evaluation will be done by the Audit Committee.
  • Various factors are evaluated to determine the approval or rejection of the transaction, including:
    • the proximity or relationship of the third party to BW LPG and the transaction decision;
    • the materiality of the transaction to BW LPG, including the dollar value of the transaction;
    • the business purpose for and reasonableness of the transaction;
    • whether the transaction is comparable to a transaction that could be available on an arms-length basis;
    • the effect of the transaction on BW LPG’s business and operations, including BW LPG’s internal control over financial reporting and system of disclosure controls or procedures; and
    • whether the transaction would cause BW LPG to be in violation of any listing rules

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