In line with the values of the Total Group, and in line with the directives of the
Federal Government of Nigeria, this policy is issued to all Staff and contractors of Elf Petroleum Nigeria Limited (EPNL), Total Upstream Nigeria Limited (TUPNI) and all other upstream subsidiaries of the Total Group in Nigeria.

• Staff and Contractors are prohibited from making any cash payments to any third party including members of communities or community-based organizations, without contractual backing.

• No payments shall be made for the purpose of gaining access to or working in or around any of the company's operational or administrative locations.

• Any request received by Staff or Contractor, for cash payments without contractual backing, should be reported to Management.

The above rules shall be incorporated into terms of contracting with Elf    Petroleum Nigeria Limited, Total Upstream Nigeria Limited and all other    upstream subsidiaries of the Total Group in Nigeria.

All Staff and Contractors of Elf Petroleum Nigeria Limited, Total Upstream
Nigeria Limited and all other upstream subsidiaries of the Total Group in Nigeria are required to comply with this policy.

Management shall take all necessary action to ensure the effective implementation of this policy.

Jacques Marraud des GROTTES
Managing Director / Chief Executive