Code of Ethics


December, 2011




The Code of Ethics of PERUPETRO S.A. Staff, aims to provide guidance to their employees in finding an ideal of human behaviour, that transcends the position or function they currently occupy, and that may lead to the benefit of those who are part of it, our customers, suppliers, contractors and the Peruvian State.  


Ethical problems are not created by the people themselves, but come to them, forcing them to confront.  The outlines of this Code of Ethics discussed a range of situations for which it should be ensured, but not detail all the problems that can occur in everyday work.  Thus, eventually, may have more doubts about what is the most correct conduct to be adopted.

Therefore, every worker has the obligation to report immediately to the Manager or Head of dependence whenever appears a situation that may characterize a conflict of interest, or when or suspects or has knowledge of facts that could damage the Company seem to oppose or contradict the provisions of the Code of Ethics of PERUPETRO S.A. Staff presented below.


The function of the Administration Manager is the spreading of the Code of Ethics, proposing an update and supports its application to other Managers and Divisions.




PERUPETRO S.A. staff acts according to the following principles:


-     Acts with decency and honesty, trying to satisfy the legitimate interests of the company, its customers and society as a whole, rejecting the benefit or advantage, obtained by himself or by third person.


-     Professes and practices a clear rejection of the corruption in all areas of performance of the Company and fully complies with current regulations. 


-      Provides quality in each of the work in charge, and finds the most appropriate and timely result. 


-      Expresses with authenticity in labor relations with all members of the company and third parties. 


-      Acts in a responsible, loyal and supportive way with the members of the company. 


-      Acts with restraint and care in handling the information that knows or is available. 





1.     Regard to the Company


1.1   Decorum in the Image of the Company. PERUPETRO S.A. workers are responsible for preserving the reputation of the Company as a value that belongs to all, a value that is shared by the mere fact of belonging to it and participate in the common ideal.  Staff should not engage in activities or transactions that may affect it.


1. 2  PERUPETRO S.A. Goods. PERUPETRO S.A. workers are responsible for the proper and rational use of property owned by the Company that have been assigned for the exercise of their functions, should prevail in the concept of permanent austerity.


         In this regard, they should protect and preserve the goods of the company to avoid its abuse, waste or misuse and do not use or permit others to use company goods for a particular purpose or purposes other than those for which they had been specifically targeted.


2.     Transparency, Neutrality and Non-Discrimination


2.1   Transparency. Every worker of PERUPETRO S.A. must perform acts of its work transparently, this implies that such acts are accessible to the understanding of citizenship through legal mechanisms, according to the provisions of the Transparency Directive approved by FONAFE.


2.2   Neutrality. Every worker of the Company must act with absolute impartiality political, economic or other nature in the performance of their duties demonstrating independence to their links with individuals, political parties or institutions outside. Therefore, it is forbidden to engage in political campaigning through the use of own labors or through the use of infrastructure, property or resources of the Company, either for or against political parties, political organizations or candidates.


2.3   Contracting and procurement of goods and services. PERUPETRO S.A. workers that participate in the contracting and procurement processes of goods and services must observe the principles established in the Consolidated Text of the Law of Contracting and Procurement of the State, its Regulations and other additional rules apply.


2.4   Personnel Selection. Subject to the requirements established to be a PERUPETRO S.A. worker, the people responsible for the selection and recruitment of employees, should be made based on the capabilities that show the candidates to perform their work without putting the subject of any discrimination of race, religion, color, sex, marital status or any impairment that is not directly relevant to the work to be performed and the skills required for that purpose.  The selection and recruitment must take place without there being any personal or political pressure.


3.     Of the Information of the Company


3.1   Privileged information. PERUPETRO S.A. workers will refrain from using for their own benefit, directly or indirectly or third parties, that information they had agreed as their conditions or the exercise of their function.  Also, PERUPETRO S.A. workers are obliged to respect professional secrecy and ensure adequate preservation of the reserve of documentation that the laws have qualified as such.  This prohibition does not apply for public documents held by the institution or the outreach work that the institution takes on its powers.  


3.2   Advancement of opinion. PERUPETRO S.A. workers must refrain from expressing any opinion on third parties regarding the meaning of that statement be issued on an issue or matter that they were aware in the exercise of their functions.


4.     Of the act of the members of the Company


4.1   Personal interests. PERUPETRO S.A. workers avoid their personal interests are in conflict with the performance of duties in the exercise of their functions, they have been entrusted. In this regard, shall take the necessary measures so that under no circumstances their personal interests will interfere with the normal exercise of their duties and responsibilities.


         For the same reason are prohibited to maintain relationships of labor, civil, business or commercial nature with the customers, contractors or suppliers of goods and services of the Company, except in those cases in which relationships are associated with the procurement by the worker, or other public services offered under similar condition in the market1.


         On the other hand, the staff of the Company is prohibited from obtaining or seeking improper benefits or advantages for himself or others, using his position, influence or appearance of influence. 


4.2   Gifts and presents. In performance of their duties, PERUPETRO S.A. workers will not accept gifts or benefits, present or future, from those natural or legal persons having contractual relations with PERUPETRO S.A. or are under evaluation, negotiation or contracting process, as well as those individuals or corporations that are directly or indirectly referred to above.


Under some circumstances, a gift offered can be accepted, provided that non-cash means of payment or equivalent, and has no commercial value oran object or article is consistent with the practice of promoting or advertising the company that provides [1].  In cases where the gift does not meet the above and cannot be returned to the company that delivered it, shall remain under the Administration Management, until it can be donated to a charity, or reached the destination that the Board of Directors of the Company revealed in due course.


People who PERUPETRO S.A. workers request a donation, a promise or any undue advantage to promote, perform or omit a step, either in compliance or in violation of their duties, may denounce such acts, indistinct or jointly, to PERUPETRO S.A. Internal Audit Management or the Public Ministry, without prejudice to any civil or criminal actions that could take place.


5.     Of the information Requested to the Worker 


5.1   Transfer of position. Workers responsible for PERUPETRO S.A. units should lead, in their respective level and with the possible anticipation, transfer processes or their position orderly, effective and documented to ensure continuity of service.


5.2   Affidavit of Income, Property and Revenue. PERUPETRO S.A. workers obliged to submit their Affidavit of Income, Property and Revenue, shall be made in a timely and complete in accordance with statutory provisions.


6.     Of activities outside the position as contamplated in


6.1   Sponsorship in PERUPETRO S.A. and against the State. For the duration of the exercise of their duties, PERUPETRO S.A. workers shall refrain from exercising their own sponsorship, advice, assistance or representation, either directly or indirectly to any person engaged in petroleum activities in any subject or issue that they demand or require. Also, PERUPERTRO S.A. workers shall not sponsor, advise, assist or represent, directly or indirectly to any person in any matter in court proceedings in which the State is plaintiff or defendant 


6.2    Litigation against PERUPETRO S.A. PERUPETRO S.A. workers shall not sponsor, advise, assist or represent, directly or indirectly to any person in any matter or issue that they demand or require before administrative, arbitration or judicial organ, against the interests of PERUPETRO .S.A.  Also, PERUPETRO S.A. workers refrain from intervening in administrative or judicial cases or specific issues in which the official or employee has taken decision, opinion or direct involvement until one year after his resignation, termination, contract termination, dismissal or redundancy. 



7.     Of the relationship with Customers, Community Social Responsibility and Environment


7.1   Commitment to Customer needs. Should be reflected in respect for their rights and in finding solutions that meet their interests, always in accordance with the objectives of PERUPETRO S.A.


7.2   Commitment with the Community, Social Responsibility and Environment. Workers should worry about making a safe, efficient and responsible operation, based on a cohesive teamwork of employees, contractors and suppliers.  Also, if their job allows, should seek to provide tools that allow the improvement of living standard of people in the community, and creation of opportunity, respecting the diverse cultures that exist especially those related to the native ethnic groups.


8.     Of the relationships in the work environment


8.1   Appropriate interaction. The relationship in the work environment should be governed by the courtesy and respect.  There is an implicit commitment to collaborate in order to prevail loyalty, trust, tolerance and general behavior consistent with the values and Code of Ethics of PERUPETRO S.A. Staff, combined with the search results. 


         It is prohibited to exert pressure, threats or harassment that may affect person’s dignity or induce performing malicious actions.


8.2    Recognition and opportunities. It is important to recognize the merit of each and to promote equal access to existing professional development opportunities, according to the characteristics, qualities and contributions of each worker.  Not support any decision that affects the careers of subordinates based on personal relationships.




The Internal Working Regulation, in item Obligations of the Workers states that these workers are obliged to respect and obey the provisions of that document and other rules issued by PERUPETRO S.A.  For this reason the Code of Ethics of PERUPETRO S.A. Staff sets a number of additional obligations that shall be borne by workers.


After approval by the Board of Directors of the Company, the observation and compliance of the Code of Ethics of PERUPETRO S.A. Staff, incumbents with each of its workers, being extended to its Board of Directors, staff that provide services under contracts other tan those of work as well as professional practitioners and pre-professional.


Each Manager and Head of Division assumes the responsibility to guide their staff towards compliance with the Code of Ethics established.  Breach of Code of Ethics will be considered, as appropriate, as professional misconduct under the labor standards and the Internal Working Regulation, as an administrative or lack of corporate status under the Directive of Directors approved by the Board of Directors of FONAFE and General Corporation Law, as determined by the actions constitute conduct punishable under existing laws.  When any sanction must be applied related to breach the Code of Ethics, it must be reported to the General Management, so that gradually they can unify the criteria most appropriate action in cases where a breach occurs. 


Each Manager of Head of Division assumes responsibility in cases where, being aware of a fact that goes against the provisions of the Code of Ethics, has not implemented the measures.


FONAFE is up to determine the fault that may be applied in the case of any default on the Directors of the Company.






PERUPETRO S.A. workers in the performance of their duties become aware of corruption in the administration and management of PERUPETRO S.A., under the responsibility have the duty to report all acts contrary to the provisions contained in this Code of Ethics to PERUPETRO S.A. Internal Audit Management.


People, who have filed complaints that are dismissed by improper or unfounded, will be responsible for damages that may have caused.


PERUPETRO S.A. worker who makes a proper complaint has the right to his identity be reserved in cases where it is deemed necessary.


1  To be generated doubts about whether a particular situation is complying with the established, pursuant to the above in the section on Presentation of this Document, the worker will make the query case to the Manager of Head of the unit where he Works, who resolves the matter directly orif necessary, after consultation with the General Manager.