Policies, Guidelines and Legal Notice

Corporate Social Responsibility Policy

Corporate Commitment
WesternZagros is committed to acting in a socially responsible manner and will continue to integrate Corporate Social Responsibility (CSR) principals thinking into our business practices. The company ensures that systems are in place to achieve compliance with our CSR and related policies and commitments. We aspire to be an industry leader with respect to our corporate social responsibility policy and set high standards for our behavior. We consider social responsibility to be an integral component in creating value for our shareholders. Accordingly, we will adhere to the following principles of ethics:

Human Rights
Our commitment to human rights is supported by our Code of Ethics and Business Conduct, in which we seek to provide a safe, orderly and tolerant work environment for our employees and contractors.

Operations and Conduct in Local Communities

We maintain the highest standards and respect for local rights and property in the regions in which we operate. We strive to form working partnerships with local communities, contractors, local businesses, suppliers and non-governmental organizations. We seek business partners that align with our standards, as we pre-screen suppliers and mandate that they comply with all applicable laws and corporate policies regarding business practices and promotion of human rights. We have a policy to apply priority to locals and communities in our procurement and hiring practices.

WesternZagros has established procedures in place for hiring local nationals. All appropriate documentation for hiring is filed in accordance with local security and government requirements.

Social Projects
It is a priority of WesternZagros to assist the local communities we operate in to achieve developmental progress. In addition to providing local employment, our projects focus around three categories: health, water and education. We listen and communicate with various local community leaders to understand their needs. We also seek to coordinate with local and international non-governmental organizations in implementing and planning of our projects. Our goal is to develop sustainable projects that the local communities will take ownership of.

Health, Safety and Environment Policy

WesternZagros is committed to:
• Protect the environment;
• Prevent harm to people;
• Respect our neighbours and contribute to the communities in which we operate;
• Manage Health, Safety and Environment (HSE) matters as any other critical business activity;
• Promote a culture in which all WesternZagros employees share this commitment.
• Monitor, observe and influence our operating partners in non-operated ventures.

Senior Management will:
• Establish, implement and maintain a HSE Management System;
• Ensure compliance with the law and company policies and standards.
• Set and monitor objectives and targets for improving HSE performance;
• Require contractor organizations to manage HSE in line with this policy
• Continue to promote a culture which encourages employees to take personal responsibility for HSE.
• Monitor, observe and influence our business partners who are the operators of WesternZagros ventures to follow the same or higher standards as WesternZagros. This will include requesting field trips and auditing of these business partners and their operations.

Supervisors will:
• Develop and maintain practices, operating procedures and programs, to provide a safe and healthy workplace;
• Minimize our impact on the environment through pollution prevention, control of emissions and the efficient use of natural resources;
• Provide employees and contractors with the necessary HSE awareness to perform work safely;
• Include HSE performance in the appraisal of staff and reward accordingly
• Regularly review and communicate HSE performance and identify opportunities for continual improvement; engage in consultation with neighbours and impacted communities.

Employees and contractors will:
• Comply with applicable practices, operating procedures and programs; and
• Be responsible to work towards a zero incident culture.

Application

WesternZagros’s Code of Ethics and Business Conduct (the “Code”) applies to all directors, officers, employees and independent contractors. For greater certainty, independent contractors includes all consultants and other persons performing services for or on behalf of WesternZagros who are not directors, officers or employees.

The Code has been compiled based on the ethical and legal obligations of WesternZagros’s directors, officers, employees and contractors of all geographic locations and job positions.

Purpose

WesternZagros has earned a reputation for honesty and integrity by maintaining the highest standards of business ethics in all interactions with co-workers, governments, local communities, shareholders, customers, suppliers, competitors and the public. The commitment of every director, officer, employee and independent contractor to abide by the letter and spirit of the Code is essential to our continued success.

Policy

WesternZagros’s directors, officers, employees and independent contractors are expected to comply with all aspects of the Code and adhere to the highest ethical standards in all business activities. It is our duty to consider how our actions, decisions and responses reflect on WesternZagros.

International Code of Ethics for Canadian Business

WesternZagros has adopted the International Code of Ethics for Canadian Business and will follow that code when conducting business abroad.

Fair Dealing

WesternZagros endeavors to deal fairly with customers, suppliers, competitors, and others with whom we do business. WesternZagros will make every effort to avoid taking unfair advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing.

Anti Corruption Compliance

WesternZagros is subject to legislation that prohibits corrupt practices in dealing both with foreign public officials and with other private sector parties, including the Corruption of Foreign Public Officials Act of Canada, the Foreign Corrupt Practices Act of the United States and the Bribery Act 2010 of the United Kingdom.  These laws make it an offence to offer, promise or give a financial or other advantage, whether directly, or indirectly through a third party acting on WesternZagros’s behalf, to any other person intended to bring about the “improper performance” by such person of his or her relevant function or activity or to reward such improper performance.  Improper performance means performance which amounts to a breach of an expectation that such other person will act in good faith, impartially, or in accordance with a position of trust.  The offence applies to bribery relating to any function of a public nature, connected with a business, performed in the course of such person’s employment or performed on behalf of a company or another body of persons, thereby covering both public and private sectors.