The aim of this Code of Ethics and Conduct is to establish the moral principles and rules that must guide the behavior and conduct of PERUPETRO S.A. executives, officers, and employees (henceforth PERUPETRO) in performing their functions.

PERUPETRO workers will act in accordance with the following principles:

-Excellence: Proceed with effectiveness and efficiency, when performing their functions,and find the most appropriate and timely result.​

-Commitment: Empathize with PERUPETRO and its functions in a proactive manner.​

-Responsibility: Fulfill their functions assigned, taking full responsibility of their actions and decisions.​

-Confidentialityy: Maintain confidentiality concerning information workers are aware of, due to their functions, and refrain from spreading or using it for their own benefit or third parties’ benefit, or for purposes outside the scope of their functions.

-Probity: Proceed with righteousness, integrity, and honesty, trying to satisfy PERUPETRO legitimate interests, its clients and society, and putting aside personal profit or advantage, attained by themselves or an intermediary. Believe in and exercise clear rejection to corruption in all areas and comply with rules in force.

-Veracity: Behave demonstrating authenticity in labor relations with all members of the company and third parties.

-Steady Improvement: Search for steady improvement of processes by applying new methodologies and tools.

1. ETHICAL DUTIES

PERUPETRO workers have the following ethical duties for the exercise of their functions:

-Neutrality: Act with absolute impartiality, whether it is political, economic or other nature in the performance of their duties demonstrating independence to their relations with individuals, political parties or institutions outside.

-​Transparency: Perform their work activities in a transparent manner; this implies that such actions are accessible to the understanding of citizenship through existing mechanisms and legislation in force.

-Personnel selection: Subject to the requirements established to be a PERUPETRO worker, the people responsible for the selection and recruitment of employees should do such activities based on the capabilities of the candidates to perform their work, without any discrimination of race, religion, color, sex, marital status or any other impairment that is not directly relevant to the work to be performed and the skills required for that purpose. Likewise, selection and recruitment must take place without there being any personal or political pressure.

-Privacy and confidentiality of information: Keep issues and information at hand secret, when performing their functions and developing their services, irrespective of their duties and responsibilities even if they are aware of illegal actions or actions against public order and good conduct.

-Commitment with Community, Social Responsibility and Environment: Perform a safe, efficient and responsible operation regarding community and environment, based on a cohesive teamwork that involves employees, contractors and suppliers. Also, if their position allows, they should seek to provide mechanisms to improve living standards of people in the community, respecting different existing cultures, especially those related to native ethnic groups.

-Proper exercise of position: When performing their duties, workers should not take any form of retaliation nor should they repress another worker or other individuals.​

-Report: Report any act contrary to ethics, waste, fraud, abuse or corruption, by any worker, through presential or remote channels that have been established by PERUPETRO without affecting compliance with legislation in force.

2. ETHICAL PROHIBITIONS

Workers are not permitted to:

1. Have relationships outside work that affect or influence their functions.
2. Allow situations where their personal, professional, economical or financial interests may affect the fulfillment of their duties and functions.
3. Advise, promote or represent, directly or by a third party, citizens or institutions, on issues or topics related to any PERUPETRO area or board.
4. Obtain or facilitate undue benefits or advantages, for themselves or others, through their position, authority, influence or apparent influence.
5. Carry out political proselytism activities, through their position, or using infrastructure, goods or resources that belong to PERUPETRO, whether for the benefit of or against political parties or organizations or candidates.
6. Misuse of Privileged Information, participate in financial transactions or operations, using privileged information belonging to PERUPETRO or information they are able to obtain because of their position, or allow misuse of such information for the benefit of any kind of interest.
7. Lobby, threaten or harass sexually that might affect personal dignity, or lead to commit intentional crimes.
8. Exercise the power to appoint or hire staff, or influence directly or indirectly when appointing staff, hiring non-staff services or processes in order to select staff, concerning relatives within the fourth degree of consanguinity and second degree of affinity or by marriage.
9. Receive donations, gifts, liberalities, present or future, from PERUPETRO, as well as from those natural or legal persons having contractual relations with PERUPETRO, or from those who are under evaluation, negotiation or contracting process, as well as from those individuals or corporations that are directly or indirectly referred to above.

1. Incentives

The General Management will implement measures to promote probity and transparency culture prescribed by the Code. It also establishes mechanisms and incentives in order to have correct, transparent and loyal worker´s behavior.

2. Penalties

Failure to comply with this Code, following a determination of the Committee of Ethics, will be considered work misdemeanor according to work legislation and Internal Working Rules, an administrative fault in conformity with Law 27588, Law 27815 and Law 27444, and corporate fault in accordance with FONAFE Corporate Guideline of Business Management and Corporate General Law rules.

PERUPETRO is responsible for applying proper penalties within the scope of its competence.

Applicable penalties due to transgression against the Code do not exempt administrative, civil nor criminal liabilities.

FONAFE will be responsible for determining the corresponding penalty that might be applied in case the Committee of Ethics determines non-compliance with the Code by PERUPETRO Directors or by representatives before PERUPETRO General Shareholders Meetings.

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

First

Revoke and annul all provisions which are contrary to those of the Code.

Second

The Code enters into force on the day following reporting the General Management on the transcript of the Board Agreement that approves it.