China National Petroleum

Corporation (CNPC)

Integrity and Compliance

Guidelines
 China National Petroleum Corporation (CNPC)

Integrity and Compliance Guidelines

Message from the Chairman

China National Petroleum Corporation (CNPC) is an integrated internation-

al energy company with businesses covering oil & gas operations, oilfield
services, petroleum engineering and construction, equipment manufactur-
ing, financial services and new energies development. Operating in various
countries and regions, the Company needs to follow relevant laws and inter-
national rules, respond to demands and expectations of stakeholders, and
especially, get through a more challenging external environment. All these re-
quire that CNPC remain committed to our value of integrity and compliance
and act as a role model in compliance with laws and regulations.
Law and regulation-based governance is our guideline for corporate man-
agement, and the guarantee for vitality and sustainable development. We
always take integrity and compliance as the fundamental requirement, and
operate in strict accordance with the code of business ethics, so as to
strengthen management, prevent risks and ensure development on the basis
of full compliance with laws and regulations.

Every employee is obliged to ensure integrity and compliance. And the rep-
utation and sound development of the Company count on the effort of the
entire staff. Each of us must foster the awareness of integrity and compli-
ance, abide by laws and regulations, observe contracts, honor commitment,
maintain full compliance in our operations, and make sure the red lines of
compliance are never crossed. The new edition of the Integrity and Com-
pliance Guidelines provides a clear code of conduct and guides to action.
Each employee is expected to read the Guidelines carefully, keep integrity
and compliance in mind and act accordingly, in an effort to improve CNPC’s
image and reputation and facilitate its high-quality development for the Com-
pany to be a world-class integrated energy company built to last.

Chairman of CNPC
Contents

Notes to Users 2

Production and Construction 4

1. Ensuring Safe Production

2. Protecting the Environment

3. Improving Quality of Products and Services

Business Engagement 8

1. Establishing a Good Business Partnership

2. Prohibiting Bribery

3. Abiding by Anti-Monopoly Regulations

4. Prohibiting Unfair Competition

5. Avoiding Sanctions and Export Control Risks

Labor and Employment 14

1. Establishing a Harmonious Employment Relationship

2. Avoiding Interest Conflicts and Other Misconducts

Financial Affairs, Taxation and Assets 18

1. Strict Enforcement of Fiscal and Taxation Systems

2. Properly Using and Protecting Company Assets

3. Abiding by Anti-money Laundering Regulations

Information Protection 22

1. Keeping Confidential Information

2. Protecting Personal Information

3. Safeguarding Information Security

Governments and Communities 26

Index 28
 Notes to Users
Scope of Application of the
Integrity and Compliance
Guidelines

The Guidelines apply to all CNPC em-

ployees. All CNPC representatives (or
agents) and other personnel conducting
any business operations in the name of
CNPC must abide by relevant provisions
of the Guidelines.
In the Guidelines, “CNPC”, “the Compa-
ny” and “we” all refer to China National
Petroleum Corporation and/or Petro-
China Company Limited and all their
branches and subsidiaries. “You” and
“CNPC employees” refer to all CNPC
employees, including members of the
board of directors, board of supervisors,
and senior management.

2
 How to Use Consequences of Viola-
the Guidelines tions against Applicable
Laws and Regulations and
the Guidelines

The Guidelines summarize the basic We should recognize that any violation
principles and the code of conduct for against applicable laws, regulations and
all CNPC employees to understand and the Guidelines may cause serious neg-
observe. In addition, employees should ative consequences to the Company
also comply with laws, regulations and and/or relevant individuals.
other rules and regulations of CNPC.
The Company may suffer the following
In overseas business, if local laws and serious consequences:
mandatory provisions are inconsistent
with the provisions in the Guidelines, the ◎ Damages to reputation and brand
strictest ones should prevail. value;
◎ Liabilities for compensation, confis-
In absence of specific provisions on rel-
cation of income, fines or penalties;
evant matters in the Guidelines, CNPC
◎ Loss of business opportunities and
employees should make judgments in
economic loss if the Company is black-
consideration of the followings when
listed.
making decisions related to such mat-
ters: The individuals may be subject to dis-
ciplinary measures by the Company.
◎ Whether such matters are in confor- For those committing serious violations,
mity with applicable laws, regulations their labor contracts may be terminated
and the Company’s rules and regula- and they may even be investigated for
tions; criminal liabilities.
◎ Whether such matters are in confor-
mity with the Guidelines;
◎ Whether such matters are in con-
formity with the Company’s values and
principles;
◎ Whether such matters will have neg-
ative impact on the Company’s reputa-
tion.

3
 Production and Construction

Upholding the philosophy of “People-oriented, quality foremost, safe-

ty first, environment prioritized”, we rigorously comply with the QHSE
related laws and regulations in countries (regions) where we operate.
The Company has always adhered to the quality principles of “honest,
credible, and better always” and pursued the quality goals of “Zero
accidents, zero defects, domestic leader and world-class player”. The
Company is committed to its HSE policies of “People oriented, giving
priority to prevention, all staff participation, and continuous improve-
ment”, and spares no efforts to achieve the HSE targets of “Zero inju-
ries, zero accidents and zero pollution”. It wins the society’s trust with
quality products and services, and excellent HSE performance.

Our contractors, suppliers and other business partners play a direct

and important role in our efforts to achieve quality and HSE targets.
We further strengthen our access management and communicate our
integrity and compliance principles and objectives to our business part-
ners for mutual compliance.

4
 Production and
Construction
1 Ensuring Safe Production

We are engaged in a business which involves high risks, and safety is always
the top priority. We always keep “never seeking development at the cost of
safety” in mind and have fostered the notion of “all accidents can be avoid-
ed”. In the meantime, we carefully identify risks and hazards, work hard to
eliminate accidents, explicate the primary responsibility, to ensure safe pro-
duction and continuously improve safety profile.

You should You should not

Fully understand and strictly follow Take on work-related matters for

safe production laws, regulations, which you are not qualified;
as well as relevant protocols and
Operate in violation of relevant
operation specifications of CNPC
protocols or specifications, or
regarding the responsibilities of
give commands or orders to do
your position;
so;
Identify hazards, evaluate risks
Initiate operations even though
and master proper control meth-
you are aware of potential haz-
ods before you start to work;
ards that may cause major acci-
Wear and use necessary protec- dents, without taking measures
tive equipment; to eliminate the risk;

Report potential safety hazards Conceal, delay reporting or

and issues; falsely report safety accidents;

Get familiar with emergency re- Drink or use illegal substances

sponse plans for safety accidents on working premises and/or
and participate in emergency drills. during working hours.

5
Production and Construction  CNPC Integrity and Compliance Guidelines 2021

2 Protecting the Environment

The Company earnestly implements the concept of “Lucid waters and lush
mountains are invaluable assets”. It always adheres to the principle of “de-
veloping while protecting, protecting while developing, and giving priority to
the protection of environment”, and never makes concession in ecological
and environmental protection. In the meantime, the Company vigorously
implements Green & low-carbon Strategy and accelerates the development
of clean production and environmental protection industries, thus building
a low-carbon energy supply system, and promoting green and low-carbon
transition.

We embrace international treaties and agreements regarding ecological en-

vironment protection, and participate in international cooperation on climate
change. We also carry out environmental impact assessment, follow regulato-
ry requirements regarding pollutant discharge permits, adhere to the principle
of simultaneously designing, constructing and applying pollution prevention &
control facilities together with the main projects, thus forming a “mechanism
featuring simultaneous operations in three aspects” that matches our project
investment and environmental protection responsibility.

You should You should not

Fully consider the actual or po- Operate without necessary envi-

tential negative impact of your ronmental permits;
behavior on the environment and
Discharge pollutants or dispose
the ecology;
wastes in violation of the regula-
Save resources; tions.

Immediately report any leakage

of harmful substances or other
situations that may damage the
environment, as required.

6
 Production and
Construction
3 Improving Quality of Products and Services

Quality is the lifeline of a company. We uphold the concept of “quality brings

safety and benefits”, implement full-process quality control and keep improv-
ing the quality of products and services with science-based management
systems and advanced technological methods.

We carry forward the “craftsmanship spirit”, honor our commitment on quali-

ty, and earnestly safeguard the interests of consumers.

You should You should not

Learn about the laws, regulations Adulterate products or offer fake

and standards regarding quality; or shoddy products;

Strictly abide by various require- Sell expired or deteriorated prod-

ments and specifications during ucts;
the production processes.
Forge or fake quality marks.

7
 Business Engagement

We uphold the principles of honesty, equal consultation, mutual ben-

efits, and win-win cooperation, and comply with business ethics, laws
and regulations in business activities.

8
 1 Establishing a Good Business Partnership

Our business partners include suppliers, contractors, sub-contractors,

agents, distributors, joint venture partners and customers. The development
of the Company cannot be separated from the support and help of our busi-

Engagement
Business
ness partners, and we look forward to establishing a partnership with mutual
respect and trust with them. We treat all business partners fairly and equally.

We prudently select our business partners based on in-depth understanding,

investigation and evaluation of their performance on integrity and compliance,
and organize due diligence when necessary. Any improper behavior of busi-
ness partners will not only harm the Company’s interests and reputation, but
also cause legal liabilities for the company.

You should You should not

Treat all business partners in an Encourage, hint or tacitly allow

honest, respectful and responsi- business partners to employ any
ble manner; behavior in violation of laws or
business ethnics;
Fulfill contractual obligations in
good faith. Delay delivery and/or payment
without any legitimate reason
when fulfilling the contract.

9
Business Engagement  CNPC Integrity and Compliance Guidelines 2021

2 Prohibiting Bribery

Bribery, as an act of unfair competition, not only harms the interests of stake-
holders, but also poses serious damage to the market order of fair competition.
We strictly abide by all the applicable anti-bribery laws and international con-
ventions, and resolutely oppose and prohibit all forms of bribery.

To maintain our good cooperation with business partners, the Company allows
moderate gifts and hospitality, but prohibits any improper gift and hospitali-
ty. When making donations and sponsorships, we must be cautious to avoid
any risk of bribery. More importantly, we should never get involved in any poli-
tics-related donations or sponsorships. Legal discounts and commissions are
allowed, but only between business partners and never with individual employ-
ees.

For specific anti-bribery requirements, you may refer to the Company’s Anti-brib-
ery Guidelines and corresponding policies and protocols..

You should You should not

Strictly follow the Company’s reg- Offer/ accept gifts or hospitality

ulations and standards, and fulfill that are not in conformity with the
Company’s regulations or that may
relevant approval and registration pose an influence on business
procedures when offering gifts decision-making (including those
and hospitality; offered at your own expense);
Make payments to the management
Be more cautious when providing or employees of business partners
in the form of commissions, referral
governmental officials and public
fees, reimbursement, etc;
servants with gifts or hospitality; Demand gifts or hospitality from
business partners;
Be explicit when offering dis-
Give bribery directly or through any
counts or commissions, and third parties;
make truthful records accordingly. Make any facilitation payment
(allowed only when the life of em-
ployees or assets of the Company
are in danger, provided that such
payments are reported to the Com-
pany and truthfully and accurately
recorded in financial accounts).

10
 3 Abiding by Anti-Monopoly Regulations

Monopoly disrupts the market order of fair competition, and harms the inter-
est of consumers and the society. We always engage in fair and free competi-
tion within the legal framework, strictly abide by the anti-monopoly laws of the

Engagement
countries (regions) where we operate, and prohibit all monopolistic behaviors

Business
that undermine fair competition.

Monopoly is the act of excluding and restricting competition, which typically

features monopoly agreement with competitors, abuse of dominant market
position, and concentration of undertakings that may hinder competition. We
should keep an eye on these monopolistic behaviors when we participate in
market competition.

For more specific anti-monopoly regulations of the Company and/or if you

have any questions, please refer to the Company’s Guidelines on Anti-monop-
oly or consult the Legal Department.

You should You should not

Submit marketing plans, pricing Share or discuss any competition-

strategies, joint venture cooperation sensitive information with com-
and merge & acquisition docu- petitors;
ments to the Legal Department for
Reach agreement with competi-
review;
tors on the followings:
Definitely refuse to discuss the
  - Fixing or changing commodity
following sensitive information re-
prices;
garding market competition with
competitors: price, cost, sales,   - Production or sales volume
customers and clients, terms of of products;
transaction, markets, R&D, etc.;
  - Market segmentation, etc.
When interacting with competitors,
Involve in bid-rigging;
be cautious to evaluate monop-
oly risks, and consult the Legal Restrict the resale prices of dis-
Department in a timely manner in tributors;
case of any doubt. Abuse dominant market position.

11
Business Engagement  CNPC Integrity and Compliance Guidelines 2021

4 Prohibiting Unfair Competition

Laws also prohibit other forms of unfair competitions in addition to bribery

and monopoly. We should strictly abide by relevant regulations and partici-
pate in competition fairly and legally in accordance with the principles of “vol-
untary, equal, fair and honest.”

You should You should not

Show respect to competitors and Discredit or slander your competi-

other market players; tors;

Objectively and truthfully advertise Organize sweepstakes in violation

the Company’s products and ser- of the regulations;
vices;
Counterfeit trademarks, trade na-
Consult the Legal Department mes, packaging, etc.
when planning sweepstakes and
other promotion campaigns.

12
 5 Avoiding Sanctions and Export Control Risks

Economic sanctions are commonly imposed on specific countries, specific

industries and/or entities/ individuals of specific countries for national security
or foreign policy purposes through restrictions on transfer of funds, trade and

Engagement
Business
economic resources. Export control usually takes the form of permit appli-
cation system, ban on the export/ re-export to specific countries, specific
end-users, or ban on the export/ re-export of specific end-use items based
on the list of controlled items (dual-use items or sensitive products and tech-
nologies, etc.).

You should You should not

Fully understand specific regu- Engage in any business in viola-

lations regarding sanctions and tion of sanctions or export control
export control, as well as relevant laws and regulations;
counter laws, get familiar with the
Tr y t o g e t a ro u n d a p p l i c a b l e
specific targets and contents of
sanctions or export control laws
such sanctions and control, and
and regulations through any third
consult the Legal Department and
parties (e.g. logistics suppliers,
relevant professionals if you have
agents or distributors).
any questions.

13
 Labor and Employment

14
15
Labor and
Employment
Labor and Employment  CNPC Integrity and Compliance Guidelines 2021

1 E stablishing a Harmonious Employment

Relationship

Keeping the concept of “people-oriented” in mind, we strictly abide by ap-

plicable international conventions concerning labor and human rights, and
relevant laws of the countries (regions) where we operate, respect and safe-
guard the legitimate rights and interests of employees according to law, value
their safety and health, and build a sound platform to promote their all-round
development, thus realizing the common improvement of their personal value
and enterprise value.

We establish employment relationship with employees based on the princi-

ples of “fairness, legitimacy, equality, free will and honesty”. We form labor
safety and health systems, optimize the occupational health management
standard, and make all endeavors to avoid accidents during work and occu-
pational hazards, thus safeguarding the legitimate rights and interests of em-
ployees.

You should You should not

Respect colleagues with different Have words and behaviors that

nationalities, races, genders, eth- may offend, insult and harass col-
nic customs and religious beliefs; leagues;

Follow the Company’s labor and Engage in activities not related to

work disciplines, work in a civ- work in the workplace and during
ilized manner, and treat people working hours;
politely;
Spread rumors or other defamato-
Unite with colleagues and help ry and discriminatory information
one another; about colleagues;

Make complaints and appeals in Inquire and disseminate colleagues’

a lawful and proper manner. privacy.

16
 2 A voiding Interest Conflicts and Other

Misconducts

Employees should correctly handle the relation between their personal inter-
ests and interests of the Company. Whether they are carrying out job duties
or personal affairs, they must never do anything that can harm the interests of
the Company or its reputation. Employees are expected to avoid any conflict
between their personal interests and the Company’s interests, and no one
would illegally transfer the Company’s interests to other enterprises and indi-
viduals by leveraging job convenience.

Employment
Labor and
You should You should not

Take the initiative to report any Invest directly or indirectly in

possible conflict of interests; non-listed enterprises that com-
pete with the Company without
Take avoidance when handling
the Company’s consent;
matters that may involve conflict
of interests; Assist others in competing with
the Company;
Obtain approval and authorization
before making decisions on behalf Take part-time jobs without the
of the Company. consent of the Company;

Seek improper benefits and inter-

ests for yourself or others by using
the Company’s assets and infor-
mation.

17
 Financial Affairs,
Taxation and Assets

18
 1 Strict Enforcement of Fiscal and Taxation

Systems

Abiding by relevant laws and accounting standards, we truthfully, accurately

and completely record accounting information, prepare financial statements,
establish accounting archives, and resolutely say no to financial fraud. We
fulfill our duty of tax declaration, tax payment and tax withholding and remit-
tance according to law, disclose tax information according to regulations, and
preserve true, accurate and complete tax-related materials that satisfy the
requirements of relevant tax authorities.

You should You should not

Taxation and Assets

Financial Affairs,
Follow relevant review and ap- Apply for reimbursement for ex-
proval procedures when making penses that have not actually
external payment, advancing pay- incurred or were incurred in activi-
ments, or applying for reimburse- ties other than duty performance;
ments;
W ithhold, misappropriate and
Issue and obtain invoices for ac- transfer the Company’s funds;
tual expenditures.
Re-sell or purchase invoice in vio-
lation of the laws.

19
Financial Affairs, Taxation and Assets  CNPC Integrity and Compliance Guidelines 2021

2 Properly Using and Protecting Company

Assets

Company assets are the material foundation for the Company’s sustainable
development, which include tangible assets such as oil and gas wells, pipe-
lines, facilities, buildings, machines, and equipment, and intangible ones such
as mining rights, land usage rights, intellectual property rights and goodwill.
Loss, misappropriation or abuse of Company assets caused by improper
management or use will have serious adverse impact on our production and
operation, so each of us should properly use and protect Company assets.

You should You should not

Keep and use Company assets in Use Company assets for illegal
accordance with relevant systems purposes;
and regulations;
Waste or damage Company assets;
Protect the Company’s intellectual
Dispose of Company assets with-
property rights;
out permission;
Maintain the Company’s brand
Infringe on others’ intellectual prop-
reputation.
erty rights.

20
 3 A b i d i n g b y A n t i - m o n e y L a u n d e r i n g

Regulations

Money-laundering is the hiding and disguising of the source and nature of

illegal gains and proceeds by an individual or organization by using various
measures so as to create the appearance that such gains and proceeds orig-
inate from a legitimate source. Money laundering is prohibited by law, which
seriously affects the reputation of enterprises. We must comply with all appli-
cable Anti-money Laundering laws, and establish corresponding systems and
procedures to prevent ourselves from being taken advantage of by criminals
who intend to launder money.

Taxation and Assets

Financial Affairs,
You should You should not

Do due diligence on the legality of Engage in money laundering;

the transaction counterparty and
Rent or lend the Company’s li-
the source of transaction funds.
censes, accounts, bank cards,
Immediately consult relevant de- USB keys and QR codes for re-
partments and preserve evidenc- ceiving or paying money without
es in case of suspicious money authorization.
laundering activities.

21
 Information Protection

22
 1 Keeping Confidential Information

Confidential information concerns the interests of the Company. We further

strengthen the confidentiality awareness of all personnel, establish a confi-
dentiality system, and improve confidentiality measures to avoid losses and
leaks of confidential information.

You should You should not

Properly keep, use and transmit Disclose confidential information in

confidential information; violation of regulations;

Immediately report and take time- Refer to confidential information in

ly rectification measures for any public places and private commu-
leak or potential leak of confiden- nication;
tial information.
Post confidential information on
social media;

Disclose confidential information

during interviews and in published
articles;

Save and transmit confidential in-

Information
formation through non-secret-relat-

Protection
ed devices and facilities;

Disclose the Company’s confidential

information without authorization
and approval.

23
Information Protection  CNPC Integrity and Compliance Guidelines 2021

2 Protecting Personal Information

It is our duty to protect personal information. We must strictly abide by the

laws on information protection of international organizations and countries
(regions) where we operate, and collect, store and use personal information
according to law.

You should You should not

Obtain the consent of individuals Collect personal information by

before collecting their personal fraud and deception;
information;
Obtain personal information from
Use personal information according illegal channels;
to law;
Publicly disclose and sell personal
Properly keep personal information information.
to avoid any loss or leak.

24
 3 Safeguarding Information Security

The development of Internet technology has greatly facilitated our work and
life, but information security risks emerge accordingly. It is vital for the Com-
pany to effectively prevent these risks. We implement a graded protection
system on network security, and take necessary measures to prevent the
Company’s network from attacks, breaches, interference and sabotage, so
as to keep the network in stable and reliable operation and ensure informa-
tion security.

You should You should not

Learn and acquire knowledge re- Log in illegal websites or download

garding information security, and malicious software;
participate in information security
Click to check suspicious e-mails
training;
or links;
Stay alert to harmful programs
Disclose or disseminate illegal in-
and network attacks;
formation.
Report information security risks
Information
Protection
and incidents without delay.

25
 Governments and Communities

The support from governments, communities and residents are ex-

tremely important to the Company’s sustainable development. The
Company emphasizes the communication and cooperation with gov-
ernments, makes positive effort in building constructive and strategic
relationship with governments, and accepts the supervision and man-
agement of governments. We take concrete measures to fulfill social
responsibilities, actively participate in community public welfare under-
takings and attach importance to the public interests of local communi-
ties so that they can benefit from our actions.

26
 You should You should not

Respect the culture, customs and Seek illegal and improper benefits
religious beliefs of countries (re- by leveraging the relationship with
gions) where we operate; governments;

Apologize promptly and sincerely Engage in production activities

if you unintentionally break local with no regard for any possible
taboos. adverse impact on local commu-
nities and residents;

Engage in behaviors that impair

the legitimate rights of local com-
munities and residents;

Use taboo words or pictures or

illustrations in relevant countries
(regions) in business communica-
tion and the advertisement and
publicity of the Company.

Governments and
Communities

27
Index  CNPC Integrity and Compliance Guidelines 2021

Index

A Discriminatory…………………………… 16

Advertisement and Publicity……………… 27 Dominant Market Position……………… 11

Anti-money Laundering…………………… 21 E

Anti-monopoly…………………………… 11 Ecology…………………………………… 6

B Environmental Protection………………… 6

Bribery……………………………… 10,12 Ethnic Customs…………………………… 16

C F

Commissions……………………………… 10 Financial Statements……………………… 19

Community………………………………… 26 Fiscal and Taxation System……………… 19

Company Assets…………………… 17,20 G

Competitors………………………… 11,12 Gifts………………………………………… 10

Concentration of Undertakings………… 11 Governments………………………… 26,27

Confidentiality……………………………… 23 H

Conflict of Interests……………………… 17 Health……………………………………… 16

Contractors………………………………4,9 Honest………………………… 4,8,9,12,16

D I

Disclose………………………… 19,23,24,25 Integrity……………………………………4,9

Discount………………………………….10 Intellectual Property Rights……………… 20

28
M S

Monopoly…………………………… 11,12 Slander…………………………………… 12

P Sweepstakes……………………………… 12

Part-time Jobs…………………………… 17 Supplier……………………………… 4,9,13

Public Welfare Undertakings…………… 26 T

Q Tangible Assets…………………………… 20

QHSE……………………………………… 4 Third Parties………………………… 10,13

Quality………………………………… 4,7,16 Transaction…………………………… 11,21

R U

Reimbursement……………………… 10,19 Unfair Competition…………………… 10,12

Religious Beliefs……………………… 16,27 W

Work Disciplines………………………… 16

29
 Letter of Commitment

I hereby confirm that I have carefully read and learned the con-
tents of the CNPC’s Integrity and Compliance Guidelines. I fully
understand the integrity and compliance requirements and conse-
quences of violating them, and hereby make a formal commitment
to complying with relevant rules and regulations.

Signature:

Date:
Clean Energy Supply for Better Environment

© China National Petroleum Corporation, 2021.

All rights reserved. The Guidelines, in part or in whole, may not

be reproduced, translated, republished, propagated, or used
in any other improper way without prior written permission
from China National Petroleum Corporation.

For more information, employees may log on the Compliance

Management Information Platform
(http://ecp.cnpc) via the internal network.

Printed using recycled paper.