Corporate Policies

1.0 Purpose and Scope
This Code of Business Conduct ("Code") sets forth the legal and ethical standards for all directors, officers, employees, and third-party vendors operating on behalf of Viceroy Petroleum LP globally.

1.1 Anti-Corruption and Bribery (FCPA)
Viceroy Petroleum maintains a zero-tolerance policy against bribery and corruption. Employees must never offer, promise, make, or authorize a payment or provide anything of value to any government official or private individual to secure an improper business advantage. Strict adherence to the U.S. Foreign Corrupt Practices Act (FCPA) is mandatory across all global operations.

1.2 Conflict of Interest
Employees must avoid situations where their personal interests could conflict, or appear to conflict, with the interests of Viceroy Petroleum. Any potential conflict must be disclosed immediately to the Chief Compliance Officer.

1.3 Fair Dealing and Antitrust
Viceroy competes vigorously but fairly. Employees must not engage in price-fixing, bid-rigging, market allocation, or any other anti-competitive behavior. We do not use deceptive practices or misrepresent our products or those of our competitors.

2.0 Commitment to the Environment
Viceroy Petroleum recognizes that environmental stewardship is fundamental to our long-term success. We are committed to conducting our upstream, midstream, and downstream operations in a manner that protects the environment, the communities in which we operate, and our personnel.

2.1 Regulatory Compliance
All facilities must operate in strict compliance with the Environmental Protection Agency (EPA), the Texas Commission on Environmental Quality (TCEQ), and all applicable international environmental regulations. Ignorance of environmental law is never an excuse.

2.2 Emissions and Flaring
Under our "Target Zero" framework, routine flaring of natural gas is strictly prohibited except during critical safety emergencies or authorized testing protocols. Fugitive emissions monitoring using optical gas imaging (OGI) cameras must be conducted quarterly at all production sites.

2.3 Spill Response and Containment
Any loss of primary containment (spill) must be reported immediately to the 24/7 Emergency Response Center. Secondary containment systems are required for all fluid storage vessels exceeding 500 barrels.

3.0 Information Security Framework
The protection of Viceroy Petroleum's intellectual property, financial data, SCADA telemetry, and employee personal information is a critical corporate priority. Our cybersecurity framework aligns with ISO/IEC 27001 standards.

3.1 Access Control and Authentication
Access to corporate networks requires mandatory Multi-Factor Authentication (MFA). Access privileges are granted on a "least privilege" basis and are reviewed bi-annually by the IT Security division.

3.2 Handling Sensitive Data
Proprietary seismic data, well logs, unreleased financial results, and vendor contracts are classified as "Strictly Confidential." Transmitting such data outside the corporate firewall requires end-to-end encryption. The use of unauthorized cloud storage or personal external drives is strictly prohibited.

3.3 Incident Reporting
Any suspected phishing attempt, unauthorized access, or loss of corporate devices (laptops, mobile phones) must be reported to the IT Helpdesk within one hour of discovery.

4.0 Ethical Labor Practices
Viceroy Petroleum respects internationally recognized human rights and is committed to ensuring that our operations and supply chains are free from labor abuses.

4.1 Forced Labor and Human Trafficking
We prohibit the use of forced, bonded, or indentured labor, involuntary prison labor, slavery, and human trafficking in our operations and throughout our supply chain. All work must be voluntary.

4.2 Child Labor
Viceroy strictly prohibits the employment of children. We comply with all applicable minimum age laws and regulations. Suppliers must not employ anyone under the local legal minimum working age.

4.3 Safe and Healthy Workplace
We are committed to providing a safe, secure, and healthy working environment. All employees and contractors have "Stop Work Authority" if they observe unsafe conditions without fear of reprisal.