Organizational Code of Conduct

GeoEnergy and its employees must, at all times, comply with all applicable laws and regulations. GeoEnergy will not condone the activities of employees who achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates, and bribery. GeoEnergy does not permit any activity that fails to stand the closest possible public scrutiny.

All business conduct should be well above the minimum standards required by law. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing GeoEnergy’s operations.

Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, who, if necessary, should seek appropriate legal advice.

General Employee Conduct

GeoEnergy expects its employees to conduct themselves in a businesslike manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job.

Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer.

Conflicts of Interest

GeoEnergy expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of GeoEnergy. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.

Outside Activities, Employment, and Directorships

All employees share a serious responsibility for GeoEnergy’s good public relations, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to GeoEnergy and is encouraged.

Employees must, however, avoid acquiring any business interest or participating in any other activity outside GeoEnergy that would, or would appear to:

• Create an excessive demand upon their time and attention, thus depriving GeoEnergy of their best efforts on the job.
• Create a conflict of interest – an obligation, interest, or distraction – that may interfere with the independent exercise of judgment in GeoEnergy’s best interest.

Relationships with Clients and Suppliers

Employees should avoid investing in or acquiring a financial interest for their own accounts in any business GeoEnergy that has a contractual relationship with GeoEnergy, or that provides goods or services, or both, to GeoEnergy if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of GeoEnergy.

Gifts, Entertainment, and Favors

Employees must not accept entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or organization with whom or with which GeoEnergy has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with GeoEnergy might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.

Kickbacks and Secret Commissions

Regarding GeoEnergy’s business activities, employees may not receive payment or compensation of any kind, except as authorized under GeoEnergy’s business and payroll policies. In particular, GeoEnergy strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law.

GeoEnergy Funds and Other Assets

Employees who have access to GeoEnergy funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in GeoEnergy’s policies and procedures or other explanatory materials, or both. GeoEnergy imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that GeoEnergy can promptly investigate further.

When an employee’s position requires spending GeoEnergy funds or incurring any reimbursable personal expenses, that individual must use good judgment on GeoEnergy’s behalf to ensure that good value is received for every expenditure. GeoEnergy funds and all other assets of GeoEnergy are purposed for GeoEnergy only and not for personal benefit. This includes the personal use of organizational assets, such as computers.

Organization Records and Communications

Accurate and reliable records of many kinds are necessary to meet GeoEnergy’s legal and financial obligations and to manage the affairs of GeoEnergy. The Organization’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and record keeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:

• False expense, attendance, production, financial, or similar reports and statements
• False advertising, deceptive marketing practices, or other misleading representations

Dealing With Outside People and Organizations

Employees must take care to separate their personal roles from their Organization positions when communicating on matters not involving Organization business.

Employees must not use GeoEnergy identification, stationery, supplies, and equipment for personal or political matters.

When communicating publicly on matters that involve Organization business, employees must not presume to speak for GeoEnergy on any topic, unless they are certain that the views they express are those of GeoEnergy, and it is the Organization’s desire that such views be publicly disseminated.

When dealing with anyone outside GeoEnergy, including public officials, employees must take care not to compromise the integrity or damage the reputation of either GeoEnergy, or any outside individual, business, or government body.

Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the public and others in GeoEnergy, all employees must make every effort to achieve complete, accurate, and timely communications – responding promptly and courteously to all proper requests for information and to all complaints.

Privacy and Confidentiality

When handling financial and personal information about customers or others with whom GeoEnergy has dealings, observe the following principles:

• Collect, use, and retain only the personal information necessary for GeoEnergy’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
• Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
• Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.

This form must be completed by all members of the board of directors, standing committee members, as well as staff, staff interns and staff volunteers upon their joining GeoEnergy. The undersigned, by their affixed signature, accept and agree to abide by the Code of Conduct policy.

QHSE POLICY STATEMENT

It is the policy of GeoEnergy petroleum service to pursuing the highest standards of health, safety, security and environmental performance. It is the policy of the Company to be in compliance with all applicable laws and regulations within the areas of our operation, to conduct all operations in a manner that promotes safe work practices and avoids risk to our employees, our neighbors, and the environment, and to implement the programs, training, and internal controls necessary to achieve these goals.

Our Management’s goal that no one suffers an injury or illness and that no harm comes to the environment. We are committed to protecting the integrity of the Company’s human, physical, and financial resources.

The Company’s objectives are:

• Create a safe work environment by eliminating hazards and reducing risk. We will accomplish this by providing resources, training, and professional staff to implement and support this policy.
• Ensure that HSE matters have equal status with all other primary business objectives.
• Comply with all relevant and applicable international, national and local government regulations and laws, and industrial standards and guidelines.
• Protect the environment, prevent pollution, and seek improvements in the efficient use of natural resources.

In order to achieve these objectives, the Company shall:

• Consult, listen and respond openly to our clients, employees, neighbors, contractors and others who may work with us.
• Work with partners, suppliers, competitors, industry groups, and regulators to raise HSE standards within our industry.
• Report our performance openly.
• Recognize those within the Company who contribute to improving HSE performance.
• At a minimum, comply fully with all legislative requirements, and implement stricter standards when those legislative requirements are insufficient.
• Provide suitable and sufficient training for our staff and others such that we have a technically competent staff and an active HSE culture.
• Participate in risk management, loss control, and monitoring processes, both internally and with our clients, to provide the assurance that our HSE Management Systems are functioning correctly and that hazards and risks are assessed and minimized.
• Maintain the confidence of others in the integrity of our operations.