CHEMOIL ENERGY LIMITED
CONCERN REPORTING POLICIES AND PROCEDURES

PURPOSE & SCOPE

Chemoil Energy Limited (“the Company”) does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by its employees in the course of their work. The Whistleblowing Policy (“the Policy”) is intended to provide a framework to promote responsible and secure reporting without fear of adverse consequences. External parties, such as suppliers, customers, contractors and other stakeholders, may use the procedure set out in this Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, insider trading, collusion with competitors, serious breaches of the Company’s global policy manual, unsafe work practices, environmental and labor issues or any other matters involving fraud, corruption and employee misconduct.

REPORTING MECHANISM

The Company encourages employees and external parties to put their names to their allegations whenever possible. All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process. Submissions of complaints/concerns should be made to the attention of the Company’s General Counsel by email to legal@chemoil.com or by postal mail to Chemoil Energy Limited, 1 Temasek Avenue, #36-01 Millenia Tower, Singapore 039192. All submissions will be reported to the Chairman of the Audit Committee for review within a reasonable time frame, and after due consideration and inquiry, a decision will be made as to whether to proceed with a detailed investigation.

SAFEGUARDS

Any effort to retaliate against any person making a complaint in good faith is strictly prohibited and shall be reported immediately to the Company’s General Counsel. However, any allegations made frivolously, maliciously or for personal gain, would warrant disciplinary action to be taken against the complainant and appropriate action taken including reporting the matter to the police when warranted.

HANDLING OF COMPLAINTS

Reported violations will receive prompt and appropriate investigation and resolution. Employees and directors are expected to cooperate fully in any investigations made by the Company into reported violations; and any failure to cooperate in an investigation or any instance of deliberately providing false information during an investigation shall be subject to strict disciplinary action up to and including immediate dismissal. All information disclosed during the course of investigation will remain confidential except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

The Company reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the compliant, the subject of the compliant may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations.

If, at the conclusion of an investigation, the Company determines that a violation has occurred or the allegations are substantiated, effective remedial action commensurate with the severity of the offence will be taken.

MODIFICATION

The Company may modify the Policy to maintain compliance with applicable laws and regulations and/or accommodate organizational changes within the Company.