FIRST E&P respects its Employees’ right to privacy in their personal affairs and activities. However, a conflict of interest can arise where an Employees’ personal, social, financial or political interest may influence or appear to influence, the employees’ loyalty to, or objective exercise of their duties for FIRST E&P.

Where an Employee or Personnel who works at or with FIRST E&P believe that they have or may have a potential or actual conflict of interest then they must immediately register the conflict with their line manager. In turn, the line manager is responsible to escalate this to the relevant Executive Director.

An increasing number of countries are adopting laws to prohibit bribery even if it takes place outside of their borders. Under both the UK Bribery Act and the US Foreign Corrupt Practices Act (FCPA), a bribery offence can be committed by provision of a financial or “other advantage” to an individual. Inappropriate and conflicted personal/business relationships could, under certain circumstances, amount to an advantage which could lead to an individual being accused of bribery.

Notification and management of actual or potential conflicts of interest will help FIRST E&P and its employees from committing an offence under the UK Bribery Act and the US FCPA. The objective of this Policy is to ensure that potential or actual conflicts of interest are identified, disclosed and effectively managed.

Conflict of Interest